Draft Black Country Plan

Comment

Representation ID: 22431

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

1.4 St Philips seeks to work constructively with the Black Country Authorities (‘BCA’) as it progresses towards the submission and adoption of the BCP and trusts that the comments contained within this document will assist Officers in this regard.
1.5 It is noted that the publication of the replacement (20th July 2021) National Planning Policy Framework (‘NPPF’) post-dates the publication of the BCP (approved at BCA cabinets on 5th and 7th July 2021) and therefore its revised contents will not have been accounted for in the consultation document. The representations draw on the revised provisions where relevant in responding to the questions posed, though it is noted that the BCA recognises the need for future stages of the BCP to take into account the revised NPPF.

Comment

Representation ID: 22434

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

Land North of Little Aston Road, Aldridge, Walsall
St Philips
October 2021

1.0 Introduction
Purpose
1.1 These representations to the Draft Black Country Plan (‘the BCP’) have been prepared by Lichfields on behalf of St Philips. We focus on the strategic matters that are contained within the BCP and relate specifically to St Philips’ land interests at land north of Little Aston Road, Aldridge, Walsall.
1.2 The site was submitted through the Call for Sites process and has been assessed accordingly:
Table 1.1 Call for Sites Submission
Site ID: 173
Form ID: 10173
Address: Land at Little Aston Road, Aldridge
Site Area (ha): 7.8
Source: Black Country Plan Interactive Site Map
1.3 A Vision Document is submitted alongside these representations which demonstrates how up to 137 dwellings could be delivered on land north of Little Aston Road, Aldridge, Walsall. [Entered as a separate submission]

2.100 As earlier indicated, there are several shortcomings in the Black Country Green Belt Study: Stage 1 and 2 Report (Land Use Consultants, September 2019), and it is considered that the omission of several sites submitted through the Call for Sites is unsound on the basis that the Green Belt Study has applied an inconsistent and flawed approach in the assessment of sites submitted through the Call for Sites.
2.101 This is because the Stage 1 Contribution Assessment has been prepared at such a strategic level as to render its findings on the extent of the potential harm to the Green Belt purposes, as a result of development, questionable when applied to smaller individual potential development sites adjacent to the urban areas.
2.102 By way of example, the geographical scale of some parcels is extremely vast (e.g. between 100-500 ha) whilst others are of a much smaller scale (e.g. between 1-50 ha).
2.103 This varying scale will undoubtedly have a negative and inconsistent impact on the scoring identified in the Green Belt purposes ratings for each parcel, as set out at Table 5.1 within the Stage 1 Findings (page 44).
2.104 St Philips considers the larger Green Belt parcels are capable of logical sub-division based on defensible boundaries. It also recommends that all of the parcels should be of a similar size and that care should be taken to ensure that a consistent approach is taken in respect of the assessment of different parts of the Black Country. This could be achieved through the subdivision of some parcels to ensure that they are all more equally sized. Indeed, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale.
2.105 The approach taken in respect of generating the land parcels for assessment is set out at paragraph 4.29:
“By combining the lines marking variations in contribution to Green Belt purposes, a list of land parcels was generated, each of which has a reference number and a rating for contribution to each purpose. The parcels are the product of the assessment rather than a precursor to it. The reasoning behind this approach was to draw out variations in contribution to inform the site-specific assessments undertaken at Stage 2, avoiding broad variations in contribution within prematurely and more arbitrarily defined parcels. Avoiding significant variations in contribution within defined parcels prevents the need for ratings to be generalised to reflect the strongest or average level of contribution within a defined area.”
2.106 Whilst the Stage 2 Harm Assessments consider the sub-parcels at a smaller scale, it is noted that not only are some of these sub-parcels still at a significantly large and inconsistent scale (some extend to <10ha whilst others are >100 ha), but that the assessment of harm is effectively an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.
Land North of Little Aston Road, Aldridge, Walsall
2.107 This issue is evident through the assessment of land north of Little Aston Road, Aldridge, Walsall (Call for Sites ID 173).
2.108 St Philips is promoting land north of Little Aston Road, Aldridge, Walsall and submitted the site accordingly through the Call for Sites process. A Vision Document is submitted alongside these representations which demonstrates how up to 137 dwellings could be delivered at the site.
Stage 1 Contribution Assessment
2.109 Within the Stage 1 Contribution Assessment, the site forms part of Parcel Reference B93 (East of Walsall) with a parcel size of 1768.3 ha, as illustrated below.
Figure 2.4 Parcel B93 at Stage 1 Contribution Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
Figure 2.5 Parcel B93 at Stage 1 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.110 As can be seen, the parcel boundary incorporates a vast swathe of the east Walsall. Ultimately, it is considered that 1768.3 ha is too large of a geographic area such that meaningful conclusions can be drawn as to the Green Belt Purposes of sub-parcels within the wider parcel. By way of comparison, a large proportion of other parcels within Walsall have been drawn significantly smaller at between 1-50 ha.
2.111 As earlier established, it would logically follow that the larger and wider a parcel is delineated, the stronger the parcel performs in terms of its Green Belt purposes as, inherently, it encompasses a greater geographic scale. This inconsistent approach has therefore unfairly resulted in parcel B93 being assessed as performing generally strong against the Green Belt purposes:
Table 2.5 Performance of parcel B93 against Green Belt purposes [see PDF of representation] Source: Black Country Green Belt Study Appendix 2 - Stage 1 Contribution Assessments
2.112 This inaccurate scoring has consequently followed through into the Stage 2 Harm Assessment.
Stage 2 Harm Assessment
2.113 Within the Stage 2 Harm Assessment, the site form parts of Sub-Parcel Reference B93D (Little Aston Road) with a parcel size of 96.8 ha, as illustrated below.
Figure 2.6 Parcel B93D at Stage 2 Harm Assessment (Constraints Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
Figure 2.7 Parcel B93D at Stage 2 Contribution Assessment (Aerial Map) [see PDF of representation] Source: Black Country Green Belt Study Appendix 3 - Stage 2 Harm Assessments
2.114 Whilst the Stage 2 Harm Assessments has considered the sub-parcel at a smaller scale, it is not broadly aligned with promoted site reference #173 and fails to illustrate promoted site reference #332. Additionally, the assessment of harm of ‘Very High’ has effectively been derived from an average of the scorings identified at Stage 1, therefore ultimately being skewed by the Stage 1 findings.
2.115 This is a fundamental flaw in the methodology of the Green Belt Study which results in a failure to account for a more localised assessment of how sub-parcels and promoted sites perform against the Green Belt purposes. As a result of this shortcoming, the land at Little Aston Road, Aldridge, which would have otherwise been selected for Green Belt removal, has been artificially omitted.
2.116 The Green Belt Study methodology should be reviewed and amended to address this issue, and the land at Little Aston Road should be proposed for removal from the Green Belt and allocated for housing accordingly.

Comment

Representation ID: 22613

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

LITTLE ASTON ROAD ALDRIDGE
Vision Document - March 2018
The Vision
The proposals for Little Aston Road, Aldridge will ensure the creation of an exciting high quality new residential development that celebrates existing landscape assets. The development will be shaped by an integrated and multi-functional green infrastructure that will provide significant benefits to both the new and existing community. The proposals will recognise the sites sustainable location of the site and provide new accessible connections.
1. Introduction
This vision document has been prepared on behalf of St Philips Ltd to support the proposals for residential development at Little Aston Road, Aldridge.
The purpose of this document is to support the promotion of residential development of the site. Key aims and objectives of this document are:
» To review the site in the context of current Planning and Green Belt policy through the review of the Black Country Authorities Core Strategy;
» To present an initial understanding of the site within the local context;
» To provide a summary of current site assessment undertaken to date; and
» To present the emerging concept masterplan, accompanied by an explanation of the key design principles that have informed it.
THE SITE
The site is located approximately 1 kilometre (km) east of Aldridge town centre, and lies within the Walsall Council administrative area. It is approximately 7.8 hectares (Ha) in size and mostly comprises grassland divided into grazing paddocks, hardstanding with stables located to the east of the site. Mature tree planting is located to the north-west.
The boundaries of the site are defined by tree and hedgerow planting to the east, the A454 and mature planting to the south, a post and wire fence with scrub planting to the north, and a chicken-wire fence to the west.
2. Planning Policy Context
2.1. LOCAL PLAN
STRATEGIC HOUSING NEEDS STUDY
The Strategic Housing Needs Study was prepared by the 14 local authorities which make up the Greater Birmingham Housing Market Area and which include the four Black Country Councils. The aim of the study was to understand the level of housing need that exists across the Greater Birmingham Area.
The report sets out that:
» The Greater Birmingham Housing Area, as a whole, has a minimum shortfall of 37,600 over the Plan period to 2031;
» New housing development is needed within easy reach of Birmingham and to a lesser extent Solihull; and
» The remainder of the shortfall should be within easy reach of Sandwell and Walsall. Having analysed the current demand and supply position, the report identifies a number of scenarios by which shortfalls in housing land could be accommodated. It surmises that “to accommodate the strategic housing shortfall the HMA will need to rely on Greenfield sites for most of its strategic housing shortfall. The resulting supply will be additional to the proposals in existing plans, which already maximise brownfield development.”
Of all the options considered, additional urban extensions are recommended. However, the report recognises that “it is unrealistic to assume entirely that new proposals can make a large difference to the strategic housing shortfall by 2031.”
Black Country and South Staffordshire SHMA
The Black Country and South Staffordshire Strategic Housing Market Assessment (PBA, March 2017) assessed housing need, specifically in the Black Country over the Plan period 2014 – 2036. The report concludes that the Black Country (excluding South Staffordshire) has a housing need of 78,190 dwelling. The Black Country authorities have confirmed work relating to how housing can be provided and where this will be located is on-going. However, the first stage has involved determining the housing capacity of the Black Country administrative area. This work is detailed in the current Strategic Housing Land Availability Assessment and is summarised in the Housing Background Paper published by the combined authorities in May 2017. Stage 2 will assess additional capacity to 2036 (BBCS Review Period) and will include any identified windfall sites.
The Black Country Authorities have set out that it is expected that housing completions and the identified land can deliver around 48,815 dwellings leaving a requirement for an additional 30,005 dwellings to meet the identified need. In addition, windfall sites have the potential to deliver 8,335 dwellings reducing the shortfall to 21,670. It is acknowledged that a key source of supply under the existing spatial strategy will be the release of surplus employment land for housing. This will be a critical decision during the review process and this source of supply is expected to deliver around 10,400 dwellings. This leaves a further shortfall of 11,270 dwellings.
EMERGING EVIDENCE Greater Birmingham and Black Country HMA Strategic Growth Study (G L Hearn)
The Greater Birmingham and Black Country HMA Strategic Growth Study was commissioned by the 14 Greater Birmingham Housing Market Area Council’s and was published on 14 February 2018. The purpose of the study is as follows:
“The scale of the housing shortfall in the Greater Birmingham and Black Country Housing Market Area (GBHMA) has been formally acknowledged through the adopted Birmingham Development Plan and the PBA Strategic Housing Needs Study. The purpose of the study is to build on this and other evidence to identify more specific options and broad locations for addressing the shortfall, which can be delivered by the market.”
The outcome from the study identifies a minimum shortfall of 28,150 dwellings for the period 2011-2031 and a minimum shortfall of 60,855 dwelling from 2011-2036, The figures differ somewhat from those set out in the earlier PBA studies on the basis that the LPA’s have identified additional urban capacity since 2015 and given the extended timeframe to 2036.
The G L Hearn study identifies 24 areas of potential search for growth options ranging from potential new settlements to urban extensions. It is clear, however, that the study forms an independent review which the Council’s will need to take into account in identifying their options going forward.
It is understood that the study outcomes will help inform how the authorities propose to incorporate the housing land shortfall into their respective Local Plans, rather than forming definitive growth options.
BCCS Review: Issues and Options Report
The first stage of the review, Issues and Options, was consulted on from 03 July 2017 to 08 September 2017. This presented several options that would respond to growth across the four Black Country authorities, including whether the use of employment and Green Belt land is appropriate to accommodate housing developments. The information collated during this process will form the basis for the Preferred Spatial Option report, which is anticipated for publication in September 2018.
The BBCS Review: Issues and Options Report presents the first opportunity for formal consultation on potential development options during the Review process. The extant strategy sets out that development will be directed to the Growth Network, which is made up of Strategic Growth Centres and Regeneration Corridors, as summarised in this table.
Stage Options Description
1 – Continuing the role of the Growth Network 1A Continue and strengthen the Growth Network with some corridors being housing led and other being employment led. Remaining housing and employment land growth to be accommodated in the Green Belt.
1B Restructure the existing Growth Network, with some occupied employment land being redeveloped for housing in Regeneration Corridors. Remaining housing and employment land growth, and replacement employment land, to be accommodated in the Green Belt.
2A – Housing Development outside of the Growth Network H1 Rounding off the Green Belt and meeting housing needs through a large number of small sites.
H2 Identification of a limited number of large Sustainable Urban Extensions in the Green Belt.

Stage 1 explores the opportunities that currently exist to maximise the growth potential of the urban area by testing how existing land is used within the Growth Network, with a focus on employment land as the main ‘variable’. Stage 2A options consider the capacity of new sources of land supply outside the urban area for both housing and employment, identifying possible means to achieve required growth.
Spatial Option H1 comprises identifying a large number of small to medium sites located within the existing Green Belt. It is acknowledged that all land located outside of the settlement boundaries in the Black Country is located within the Green Belt, with some parcels encroaching into urban areas where sufficient services exist. These locations present ideal opportunities for ‘rounding off ’ the urban edge, and would provide new defensible boundaries to the Green Belt.
Spatial Option H2 sets out a more centralised approach by identifying a smaller number of large scale Sustainable Urban Extensions (SUEs). The Strategic Housing Needs Study defines an SUE “as a development on the edge of a settlement which can accommodate up to 500 – 5,000 homes and is of a scale appropriate to the size of the settlement being extended.” The Core Strategy sets out that no SUEs are currently being promoted in the Black Country and that at this stage, no size of SUE has been ruled out.
The adopted Core Strategy (2011) sets out a hierarchy of centres. Aldridge is identified as a Town Centre under the Strategic Centre of Walsall. Whilst Policy CEN2 largely relates to the economic growth of centres through investment in retail and other appropriate uses, it gives a clear indication of the town’s role in relation to other settlements within the Walsall administrative area and, thus, where development outside Walsall will be directed in the first instance.
With this in mind, it is considered that the land at Little Aston Road in Aldridge aligns with Spatial Option H1 and H2 in meeting future housing growth for Walsall. The site provides an opportunity for a smaller Sustainable Urban Extension to Aldridge which would help accommodate the future growth requirement of Walsall and the town.
2.2. GREEN BELT
The Borough of Walsall does not have sufficient land to meet the quantum of housing targeted for delivery across the plan period, resulting in a need to release Green Belt land for future development and growth. In order to demonstrate that the site at Little Aston Road is suitable, achievable and deliverable now, we have tested it against the five purposes of the Green Belt as set out in the NPPF (Paragraph 80). These include:
» To check unrestricted sprawl of large built-up areas;
» To prevent neighbouring towns merging into one another;
» To assist in safeguarding the countryside from encroachment;
» To preserve the setting and special character of historic towns; and
» To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
TO CHECK UNRESTRICTED SPRAWL OF LARGE BUILT-UP AREAS
Consideration has been given to how well contained the urban area is by the site. The site has clearly defined boundaries that will not need to be altered and that follow clearly defined physical features:
» The northern boundary is interspersed with woodland that provides a strong well defined limit.
» The east is bound by the Fairlawns Hotel and Spa.
» The south is defined by the A454.
» The west is defined by Aldridge Court Nursing Home.
In this regard, the site is not bordered by any open landscape, typical of more rural Green Belt locations. It is therefore considered that future extensions to development would be restricted due to these limitations. In addition, the site’s location between the Fairlawn Hotel and Spa and Aldridge Nursing Home does not act as a significant containment barrier for the urban area of Aldridge. It is concluded that removal of the site from the Green Belt would not result in unrestricted sprawl of large built-up areas.
TO PREVENT NEIGHBOURING TOWNS MERGING INTO ONE ANOTHER
The Green Belt, in this location, serves to protect against the coalescence of the built up areas of Aldridge and Little Aston/Four Oaks, located to the west of Aldridge.
It is understood that the minimum separation distance between these two settlements is approximately 2.5km. The site therefore sits in a gap of 1-5km between urban areas. Notwithstanding this, the gap is considerably smaller to the south (1.16 km).
It is proposed that the land to east of the development site will be free from development, rather afforded to amenity open space, which will assists in maintaining the existing separation distance from Little Aston/Four Oaks. In addition, the site is not defined as a ‘strategic gap’ within the Black Country Core Strategy (2011) or within the emerging Issues and Option Document for the Core Strategy Review.
A strong gap would be maintained between the urban areas of Aldridge and Little Aston/Four Oaks, therefore, the removal of the site from the Green Belt would not result in the merging of neighbourhood towns.
TO ASSIST IN SAFEGUARDING THE COUNTRYSIDE FROM ENCROACHMENT
Strong, durable boundaries assist in the protection of the countryside from future development. The site accommodates strong defensible boundaries around the entirety of its boundary. The proposed landscaping and open space to the west, south and east of the site would enhance the existing containment features.
It is acknowledged that the release of the site from the Green Belt would be a natural extension to the urban area of Aldridge and that the site, in its present form, is generally characterised and adjoined by existing countryside. However, this is primarily due to the limited development currently present, including stables and equestrian service buildings. Notwithstanding this, it is considered that development of the site would not adversely impact the remaining open countryside.
TO PRESERVE THE SETTING AND SPECIAL CHARACTER OF HISTORIC TOWNS
The site is located adjacent to Aldridge Conservation Area, but has limited views of landmarks and/or the historic core. Existing dense tree planting to the west of the site screens it from the edge of the Conservation Area.
The nearest listed building is located circa. 650m to the west of the site; The Moot House – Grade II. In addition, there is a Grade II Listed Building, The Old Irish Harp Pub, located circa. 700m from the site to the east, however, it is considered that the Fairlawns Hotel and Spa and campsite screen this asset from the development.
The closest Grade II* Listed Building is located circa. 590m to the west of the site at The Green; the Church of St Mary the Virgin. It is considered that there is sufficient development between this building and the development site, resulting in limited harm to the heritage asset.
In addition to the above, a proportion of open space and formal play is proposed to be located to the west of the development site, together with enhanced tree planting and landscaping. This will provide further screening and protection to the identified heritage assets. It is therefore considered that the site’s removal of the Green Belt would not adversely impact the setting and special character of Aldridge’s Conservation Area and/or historic assets.
TO ASSIST IN URBAN REGENERATION, BY ENCOURAGING THE RECYCLING OF DERELICT AND OTHER URBAN LAND
The BCCS outlines a strategy that emphasises the delivery of homes on previously developed brownfield sites. Notwithstanding this, the Strategic Housing Needs Study acknowledges that such sites are already maximised in existing plans and therefore address a requirement to identify alternative sites, including those located within the Green Belt. This is exacerbated by the Walsall’s shortfall, together with undersupply from the wider HMA.
Notwithstanding the above, the site will be appropriately phased so as to ensure that regeneration schemes across the Borough and within the surrounding Black Country Authorities administrative areas are not impacted.
Development of the site would not adversely impact urban regeneration or the recycling of derelict and other urban land.
SUMMARY
In conclusion, it is evident from the above test that the removal of the Land at Little Aston Road, Aldridge from the Green Belt would not comprise the five purposes of the Green Belt and would not, therefore, result in any material harm to the Green Belt in this location. We therefore conclude that the allocation of the proposed development site would present a suitable site at which future growth in Walsall and the Black Country could be accommodated.

3. Assessing the Setting: Local
3.1. ACCESS AND MOVEMENT The site is well connected to public transports services and strategic highways links. The plan opposite shows the location of the site within the context of the local access and movement network.
WALKING
The site is well connected to the existing pedestrian network with a footway located along the southern side of the A454 (Little Aston Road). There is a continuous footway provision between the site and Aldridge town centre where a dense network of pedestrian routes is provided.
Immediately adjacent to the northern site boundary is a footpath (ALD51) linking to the wider Public Rights of Way (PRoW) network.
PUBLIC TRANSPORT
Little Aston Road is served by a regular bus service providing two services per hour between Walsall and Sutton Coldfield (via Aldridge) during the weekday daytime, with less frequent services on Sundays and evenings.
Blake Street train station is circa 4km east of the site which provides high frequency services to Birmingham New Street. Four Oaks station, although further from the site is on the same line and is accessible via bus as part of a multi-modal journey.
HIGHWAY NETWORK
The site is well connected to its surroundings via the local highway network. Little Aston Road forms the southern site boundary and provides direct access to Aldridge town centre to the west. Junctions 7 and 10, of the M6, are approximately 7.5km south and 8.5km west respectively of the site, providing access to Birmingham, Stafford and the wider strategic highway network.
3.2. LOCAL FACILITIES
The site is well located in terms of access to local facilities and services, as shown on the plan opposite, which includes indicative journey distance isochrones of 400m (5 minutes’ walk), 800m (10 minutes’ walk) and 1200m (15 minutes’ walk).
Aldridge town centre is located within the preferred maximum walking distance of the site according to IHT guidance.
EDUCATION
Cooper & Jordan C of E School is located approximately 450m west of the site on The Green, whilst Saint Mary of the Angels Catholic primary school is approximately 1.5km south-west of the site.
Secondary education is provided at St Francis of Assisi, which is located approximately 1km south-west of the site.
HEALTH
Anchor Meadow Health Centre, with a doctor’s surgery, dental practice and pharmacy, is located 1.2km west of the site, and is accessible via bus services along Little Aston Road, adjacent to the site.
RECREATION
Accessible open space is located at Aldridge Croft, which also features an equipped play area, approximately 600m walk west of the site. Aldridge Stick & Wicket Club provides facilities for cricket, hockey and football, and hosts regular running and fitness clubs.
3.3. LANDSCAPE CHARACTER OF THE SETTING
Natural England provide a nationwide classification of landscape character. The regional ‘profiles’ record landscape as National Character Areas (NCAs) and set out a description of the natural and cultural features that shape the landscapes, how the landscape has changed over time, the current key drivers for ongoing change, and a broad analysis of each area’s characteristics and ecosystem services.
NCA 67. CANNOCK CHASE AND CANNOCK WOOD
Aldridge and the Site sit within NCA 67. Cannock Chase and Cank Wood. The large area of the NCA extends north of the Birmingham and Black Country conurbation. It includes higher land consisting of sandstone and the South Staffordshire Coalfield. Natural England state that NCA 67 principally coincides with the historical hunting forest of Cannock Chase, with major remnants surviving within the Cannock Chase Area of Outstanding Natural Beauty (AONB), which supports internationally important heathland Special Areas of Conservation (SAC) and the Sutton Park National Nature Reserve.
In the south the NCA merges with the Arden NCA within the Birmingham conurbation, and here there are close links through the roads, railways and canals. The immediate setting of the site exhibits some of these characteristic components: the M6 runs through Walsall and Bloxwich to the west of Aldridge, the A454 Little Aston Road runs along the site’s southern boundary, the lines of railways: disused and operation are common; and the Daw End Branch of the Essington and Wyrley Canal cuts through Aldridge.
The character of the wider setting is the landscape of NCA 67: it is a varied landscape ranging from the open heathlands and plantations of Cannock Chase, through towns, reclaimed mining sites and new developments, to dense urban areas.
The ‘Key Characteristics’ of the landscape of the setting, that have particular relevance to the site and recorded by Natural England are:
» The predominant building material of the 19th and early 20th century buildings is red brick, with more modern structures within the urban areas.
» The settlement pattern is complex and contrasting, with some areas densely populated and others relatively sparse. The conurbation includes a mosaic of urban areas, former industrial land and patches of farmland, with an extensive urban fringe.
» The extensive network of canals and railways reflect the industrial history of the area. Major roads include the M6, the M6 Toll and the A5.
3.4. LOCAL LANDSCAPE CHARACTER ASSESSMENT
At a local level of study Walsall Council has not published landscape character assessments that apply to the site. Wolverhampton City Council, has however and the ‘Black Country Historic Landscape Characterisation’ (published 2009, updated 2010) places the site in the ‘Barr Beacon & Aldridge Fields Character Area’ (WL09). This is a comparatively large landscape character area and the study makes this summary:
“This area is the most rural landscape in Walsall, with field systems covering more than two thirds of its surface (although recreational land use 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.”
The rural quality of the WL09 area is an important landscape character attribute. The landscape character of the site however is defined by both rural and urban influences. The fields within the site are not deeply rural – they are grazed by horses with some boundaries that are made by hedges that are a characteristic of the immediate setting. The Druids Heath Golf Course to the north is not a farmed, or rural landscape. The presence of Aldridge immediately to the east of Aldridge Court (in combination with the housing along Branton Hill Lane) brings a strong sense of the settlement to the edge of the site, influencing its character at the rural- urban edge. Fairlawns Hotel and Spa and the housing south of the A454 also contribute a suburban character marked further by the A road.
4. Assessing the Setting: The Site
Technical surveys including an Arboricultural Assessment, Ecological Assessment, Landscape and Visual Assessment and a Preliminary Archaeology and Cultural Heritage report have been undertaken to ensure a robust site assessment.
4.1. HYDROLOGY
The Environment Agency Flood Map shows that the entire site is located within EA Flood Zone 1, and as such, there is less than 1 in 1000 chance of fluvial flooding.
The Environment Agency Surface Water Flood Map indicates that the site at ‘very low’ risk of surface water flooding, with an annual chance of flooding of less than 1 in 1,000.
From a review of the British Geological Survey ‘Groundwater Flooding Susceptibility Map’ and based on the anticipated geological conditions of the site, there is a potential for groundwater flooding to occur at the surface.
The site is not considered to be at risk of flooding from other sources, such as reservoir, sewer, lakes and canal flooding.
4.2. DRAINAGE
Surface water from the proposed development will be drained by a Sustainable Drainage System (SuD)s scheme.
Considering the geology of the site which is predominantly underlain by sandstone, it is likely that the ground conditions will be suitable for infiltration to discharge surface water into the ground. However, soakaway tests will be completed to confirm the permeability of the site and inform the surface water drainage strategy.
Should the soil be identified as not suitable for infiltration, a positive connection (with a limited discharge rate) to the existing public surface water sewer located within or very close proximity of the southern boundary of the site. For this surface water discharge option, on-site surface water attenuation will be required to limit peak discharge rates to greenfield rates for a 1 in 100 year plus 40% allowance for climate change storm event.
Foul water from the proposed residential development will be drained by a separate foul water drainage system. This foul water drainage system will discharge to the combined sewer located to the south-east of the site, beneath the A454. Considering the topography of the site, it is likely that a gravity connection to this combined sewer is feasible. A pre-development enquiry with Severn Trent Water has been submitted to confirm the peak foul water discharge rate and the connection point.
4.3. HERITAGE AND ARCHEAOLOGY
A Preliminary Archaeology and Cultural Heritage report was produced in December 2017. There are no designated heritage assets recorded within the site.
Within a 1km radius of the site there is one Grade II* Listed Building, the Church of St Mary the Virgin (1076396), approximately 590m to the west of the site, ten Grade II listed Buildings, and one Conservation Area. Whilst the Aldridge Conservation Area boundary is contiguous with the sites western boundary, all Listed Buildings are beyond 500m from the site. It is possible that there would be indirect impacts to designated heritage assets, which could be experienced as a consequence of changes within their settings.
Whilst it is anticipated that impacts of ‘substantial harm’ are extremely unlikely, impacts of ‘less than substantial harm’ are possible. However, any forthcoming planning application would be informed by a Heritage Statement in respect to the Conservation Area and Listed Buildings.
In respect to archaeology, there are no non-designated heritage assets recorded within the site. Within the 1km search area, the Staffordshire Heritage Environment Records (HER) records four non-designated heritage assets and the Wolverhampton and Walsall HER records 80. Whilst the presence of unknown archaeological remains within the site cannot be discounted at this stage, it would appear that settlement and funerary activity was focused elsewhere. It is probable that the site has been under agricultural use, certainly from the post medieval period onwards, if not earlier.
It is considered highly unlikely that any remains of high (national) importance would be present which would preclude development, however, any forthcoming planning application would be informed by a full Desk Based Assessment.
4.4. LANDFORM AND LANDSCAPE
The landform of the site is a key attribute and creates a strong influence on how the site relates to its immediate setting at its boundaries.
The ground rises progressively from a low area of 136m AOD at the south-east corner at the boundary with the A454 Little Aston Road, at gradients between 1:11 and 1:33), to the high point of 153m AOD in the north-west corner at the boundary with the grounds of Little Aston Hall. The land rises above the site to the north and west, with a high point in Aldridge of 183m AOD. It continues to drop below the site to the east and there is a local low point of 126m AOD on the A452 Chester Road.
The landform of the site sits in an unremarkable pattern of gently rising and falling ground. The site is neither prominently elevated, nor enclosed by low ground: it sits on a broad area of similar gentle undulation.
The landscape exhibits the appearance of an almost ‘relict’ landscape. The landcover is grazed pasture but the grazing is by horses not livestock. It is not a farmed field in productive agriculture. The boundaries are well defined and exhibit something of the character present in the pattern of enclosure of NCA 67. There are hedgerow trees within the hedges along the boundaries. The tree cover within the site is sparse with relatively prominent individual trees growing on the slightly higher ground to the north-west. These trees give a sense of parkland.
The Aldridge Conservation Area adjoins the western boundary of the site and includes Aldridge Court and Court Farm. Some of buildings in the Conservation Area are visible from the site.
High voltage, over-head power lines cross the south-eastern corner of the site. There is a pylon on site in the far north-east of the site, and the lines of cables and the pylon towers are visible running across the landscape to the south. The cables intrusion over the site, and the presence of the A454 Little Aston Road reduces the tranquillity in the landscape. The landscape of the site is not deeply rural. Disruption is caused by the A road, the over-head cables, the absence of productive agriculture and the proximity of the settlement.
4.5. ECOLOGY AND BIODIVERSITY
A site walkover was conducted in early 2018 by a fully qualified Ecologist to assess the site for the presence of, quality and potential of habitats to support protected and notable species of flora and fauna.
The county’s biological record centre was also consulted; no records of protected species were found within or in close proximity to the site.
The site is currently grazed by horses; therefore, the grassland has a low plant diversity. Mature trees present within the site provided potential roosting features for bats and should be surveyed before development. The stable blocks on-site also provided potential for nesting birds; however, none were observed. The hedgerows, on the eastern and southern boundary, are a notable habitat within the site and are listed as a UK Biodiversity Action Plan Priority Habitat. Therefore, they should be retained within a masterplan, with any gaps filled with native species as part of the development. Other boundaries on site, marked by fences could be replaced by species-rich hedgerows.
There was no evidence of protected or notable species or habitats recorded within the site. . Tree planting is recommended along the northern boundary A check of freely available online resources also shows that the soils in and around the site are generally freely draining, slightly acidic sandy soils. They are designated as having a low natural fertility.
Development of the site provides an opportunity to enhance existing and plant new hedgerows. This would constitute enhancement as required by national planning policy. There are also opportunities to increase biodiversity and ecological value of the site through planting green buffers and maintaining open space adjacent to notable habitats.
4.6. ARBORICULTURE
An Arboricultural Assessment has been carried out in accordance with guidance contained within British Standard 5837:2012 ‘Trees in Relation to Design, Demolition and Construction - Recommendations’.
The guidelines set out a structured assessment methodology to assist in determining which trees would be deemed either as being suitable or unsuitable for retention along with recommendations for considering the relationship between existing trees and how those trees may integrate into designs for development.
In summary, the report concludes that:
» Tree cover is predominately positioned along to the boundaries of the site, 15 mature specimens stand within the paddocks to the west.
» A mixture of native species is present on site with English Oak, Ash, Hawthorn and Scots Pine being dominant throughout the site along with a number of large sycamore trees.
Across the site a total of nineteen individual trees and six groups of trees were surveyed as part of the Arboricultural Assessment, of which six trees were considered to be high in quality and category A, seven trees and four groups of trees were recorded as moderate quality and category B and the remaining eight trees or groups of trees low in quality and retention category C.
To facilitate the proposed development of the site no significant tree loss will be required for the built form. Existing trees will need to be removed along the southern site boundary, to facilitate the proposed access although the proportion of loss is considered to be low in comparison to the amount of moderate quality being retained within the access arrangements.
The proposed development should be considered an opportunity, in terms of arboriculture, to improve and increase tree cover in the local area without the loss of any arboriculturally significant trees.
4.7. UTILITIES
An incumbent utilities search has been conducted to identify any existing services across the site. The search identified a number of constraints within the site, detailed below:
GAS
Cadent Gas (formerly known as National Grid) records show an iron 12-inch, medium pressure (MP) gas main apparatus following the northern site boundary, running in a west/east orientation. This apparatus follows the edge of the site turning at the north-east corner to follow the eastern boundary in a north/south orientation. This apparatus then passes through a valve and becomes 355mm polyethylene (PE) MP apparatus, continuing in a north/south orientation, approximately 12m to the east of the eastern site boundary. The apparatus then turns towards a west/east orientation approximately 100m north of Little Aston Road.
There is a 6-inch cast iron, low pressure (LP) gas main apparatus within Little Aston Road, which is capped at the south-eastern corner of the site. Approximately 150m west along Little Aston Road from the south-west corner of the site, there is another 6-inch capped, spun-iron, LP gas main apparatus which serves the nursing home to the west of the site via 3-inch, steel, LP apparatus.
ELECTRICITY
National Grid – There are 132kV overhead cables which cross the eastern portion of the site in a southwest/northeast orientation, with a pylon in the north-eastern corner of the site.
Western Power Distribution (WPD) – There is an underground, high voltage (11kV) electricity cable running along Little Aston Road, outside of the site boundary.
POTABLE WATER
South Staffs Water records show a 4-inch potable water main capped near the south-eastern corner of the site, in Little Aston Road. Approximately 40m along Little Aston Road from the south-west corner of the site boundary, records show a potable water hydrant which is fed from the west by a 90mm MDPE water main.
TELECOMMUNICATIONS
BT Openreach apparatus is shown to exist along Little Aston Road, outside the southern site boundary.
In summary, the existing utilities assessment has identified several assets for various utilities, and based on the obtained records, connection to these networks seems to be feasible. However, capacity enquiries will need to be submitted to the incumbent utilities providers to confirm capacity requirements.
4.8. NOISE
An appraisal of noise constraints, including an overnight noise survey, was carried out at the site in early 2018.
This appraisal was undertaken to assess the potential impact of existing noise sources at the proposed sensitive receptors, and the impact of noise from construction phase at existing receptors, in line with current guidance.
Road traffic on Little Aston Road has been identified as the main source of noise to have an impact at the proposed development. Therefore, monitoring was carried out adjacent to Little Aston Road, and near to the identified representative existing sensitive receptor.
Recommendations for noise mitigation have therefore been made so that the internal and external guideline levels can be achieved. This will consist of a stand-off from Little Aston Road and barrier combination to mitigate against the road traffic noise. It is also considered that the net increase in local road traffic due to the proposed development, may result in only a small, imperceptible increase in noise at existing properties. As such, with appropriate design noise levels on site would meet recommended internal and external noise guidelines.
4.9. GEO-ENVIRONMENTAL
A desk based review of geo-environmental information has been undertaken based on available records.
The review aimed to identify potential constraints to development, or the future use of the site related to ground conditions and or contamination. A summary of the pertinent information relating to the Site is provided below. A preliminary risk assessment based on the source-pathway-receptor principal has been undertaken and is outlined below.
PRESENT AND PAST USE
The Site has remained largely unchanged since the date of the earliest reviewed mapping edition. The site is currently in use as paddocks, with several small associated buildings present on the eastern boundary. Overhead electricity cables were noted to cross the eastern half of the site. The risk to future development from past and present uses of the site is considered to be low.
ADJACENT LAND USES
The land adjacent to the Site is noted to have been used predominantly for agricultural purposes. Progressive residential development is recorded to the west of the Site in Aldridge on historic editions of the mapping over the last 50 years. A sand pit excavation was recorded approximately 200m south of the Site since 1955. The risk to both humans and property or the environment associated with adjacent land uses is considered to be low.
ASBESTOS
There is a small possibility of asbestos being present in the buildings on the eastern boundary of the Site. Appropriate surveys of the buildings will be required prior to demolition at the site. However, the risk to future use of the site associated with asbestos contamination is considered to be low.
GEOLOGY AND MINING
There are no records of significant hazards posed from the geological setting or from mining activities within the vicinity of the site.
GROUNDWATER AND SURFACE WATER
The Site lies within a Source Protection Zone III, for a major public groundwater supply 869m southwest of the Site. Future use of the site will need to take account of the risk posed to the underlying aquifer and Source Protection Zone. However, with appropriate measures in place, the future development of the site should not pose a significant risk to the environment.
Based on the desk top review of available sources of information, it is therefore considered that the overall risk to the current and future users of the site and the risk posed by future development to the local environment is considered to be low.
4.10. SUMMARY OF OPPORTUNITIES AND CONSTRAINTS
The findings of site and context analysis have been evaluated to identify the key opportunities and constraints relevant to the development of the site. A summary of these findings is set out below.
LAND USE
» The development will consider existing properties that adjoin the site boundary, and ensure that the privacy and amenity of these dwellings is respected.
» Opportunity to provide a green infrastructure network, with accessible amenity open space that is integrated with development.
HYDROLOGY AND DRAINAGE
» The site is wholly located within EA Flood Zone 1, and as such, there is less than 0.1% chance of fluvial flooding. The site is suitable for development due to the minimal level of flood risk identified.
» The geology of the site is likely to be suitable for infiltration which is the preferred surface water disposal method by the Lead Local Flood Authority.
» The development will use Sustainable Drainage Systems (SuDs) to accommodate and manage surface water drainage.
» There is a public combined sewer located within close proximity of the site. Foul water from the proposed development can be discharged to this sewer, subject to a formal agreement by Severn Trent Water.
» Due to the site topography, it is likely that a gravity connection to the public sewer is feasible and pumping will not be required.
ACCESS AND MOVEMENT
» Vehicular access will be taken from the A454 (Little Aston Road) to the south of the site.
» Opportunity for pedestrian links to the Public Rights of Way (PRoW) network to be provided along the northern site boundary, offering an alternative pedestrian route to local facilities and the centre of Aldridge.
ECOLOGY
» Mature trees are present on site that have potential to support roosting bats. These trees should be subject to further surveys if they are required to be removed.
» Removal of the stables which present potential for nesting birds, should be undertaken outside of typical nesting bird season.
» Hedgerows are a priority habitat and should be retained within the masterplan. Compensation would be required if any loss of hedgerow is necessary to facilitate the development. To mitigate the impact of development upon notable habitats, hedgerows should be protected by the provision of an open space buffer, of at least 5m from any construction. To enhance the value and biodiversity of existing hedgerows, gaps should be planted up with native species.
» Boundary fences could be replaced with hedgerow planting to enhance connectivity around the site.
LANDSCAPE AND LANDFORM
» The site boundaries are well defined, with the opportunity to strengthen them through structural planting.
» The prominent individual trees give a sense of a parkland setting.
ARBORICULTURE
» There are six Category A trees within the site boundary, and none of the trees are covered by TPO’s.
» Existing tree and hedgerow planting will be retained and enhanced wherever possible.
» Opportunity to reinforce and enhance the screening function of existing tree and hedgerow boundaries. UTILITIES
» Appropriate easement for the identified utilities will be integrated into the masterplan proposals, including the overhead electricity cables crossing the site.
» The capacity requirements and new service connections associated with the proposed site will be calculated and appropriate infrastructure provided for the future development.
HERITAGE AND ARCHEAOLOGY
» The site is adjacent to the Aldridge Conservation Area, but there are no designated heritage assets within the site.
» The are no non-designated heritage assets of an archaeological nature within the site. It is considered highly unlikely that any remains of high (national) importance would be present which would preclude development.
NOISE
» A stand-off from the road and barrier combination have been specified so areas of proposed development will achieve those guideline levels.
GEO-ENVIRONMENTAL
» The underlying strata comprises a Principal Aquifer with no recorded superficial deposits across the site. It is likely therefore that soakaway drainage would be possible for development at the site.
» There is a potential for asbestos containing materials within the buildings on site.
5. Design Principles
5.1. CONCEPT MASTERPLAN
The Concept Masterplan (presented opposite) has been informed by the vision and technical analysis presented earlier in this Vision Document along with following design principles:
DEVELOPMENT FORM
» Provision of approximately 3.71 Ha of residential development land, achieving 137 dwellings at an average density of 37 dwellings per hectare (dph). These dwellings will be delivered in a mix of tenures and types.
» Development will be structured to ensure the creation of a legible and permeable place, with streets and spaces overlooked wherever possible.
» A minimum 20m offset from the A454 (Little Aston Road) will be accomodated within public open space, to mitigate against potential noise impact.
» Development has been orientated to ensure that views towards the existing pylon are minimised. An offset between the overhead electrical cables and residential development has been provided.
ACCESS AND MOVEMENT
» Vehicular access will be taken from the A454 (Little Aston Road).
» A new network of accessible informal pedestrian routes will be established within the site, providing circulatory walks which aim to encourage physical activity.
» Two potential pedestrian links to the existing PRoW (ALD51 footpath) are proposed, providing easy traffic free access to Aldridge town centre and local facilities.
OPEN SPACE AND LANDSCAPE
» The proposals promote a generosity of space, through retaining a large area of the site as pubic open space. This offers the opportunity to significantly benefit both the existing and proposed community, whilst respecting the privacy and amenity of existing properties surrounding the site. Open space will also accomodate areas for attenuation.
» Existing green capital has guided the location of development within the site; existing tree planting has been retained within public open space wherever possible.
» The provision of new woodland planting adjacent to the western site boundary will significantly enhance bio-diversity and ecology, whilst providing a landscaped corridor which responds to the setting of Aldridge Conservation Area.
» Formal play facilities are proposed, comprising a woodland play trail located within the western area of POS.
» The provision of a centrally located area of public open space will provide a key focal view point from the primary movement route. Accessible and visible from the surrounding residential development, its central location will benefit from natural surveillance and activity.
5.2. THE GREEN INFRASTRUCTURE AND THE LANDSCAPE STRATEGY
The objective of the Landscape Strategy is the delivery of a sustainable, attractive, planted and green framework that is informed by the existing attributes and character of the site and its place in the setting. The new landscape will form the structure of the development and the Landscape Strategy will be founded on a robust and well-connected Green Infrastructure (GI) network. The connectivity between settlement and country is central to the design response to the site and the setting. The early identification of key existing assets: the landform, the inherited ‘green capital’ in the hedgerows and trees; and the views over the Staffordshire countryside, has already fed into the initial concepts in this Vision Document. The design response to the character of the setting is being made in a manner that compliments the landscape and is part of the GI Strategy for the development.
Green Infrastructure is: “…the network of natural and semi natural features, green spaces, rivers and lakes that intersperse and connect villages, towns and cities. Individually these elements are GI assets, and the roles that these assets play are GI functions. When appropriately planned, designed and managed, the assets and functions have the potential to deliver a wide range of benefits – from providing sustainable transport links to mitigating and adapting the effects of climate change.”
(‘Green Infrastructure: an integrated approach to land use’. Landscape Institute. 2013)
The Green Infrastructure Strategy will realise the maximum potential of the key components in the landscape of the site and the immediate setting. Retention, protection, enhancement and management will be sub-strategies that will focus on the existing character defining attributes. The objective is to weave these existing attributes with the new buildings and the new green spaces in a manner that makes a sympathetic and successful fit in the landscape.
Strategies will be created that look to accommodate water management and habitat creation within the scheme in a manner that integrates the amenity and life-style benefits of these components with the design and style of the public open space: the new parkland. The appreciation of the landform, hedgerow pattern and watercourses and the views, will act as prompts and key drivers within the GI Strategy. The result will be public spaces that are welcoming, safe and highly attractive and have a strong sense of place and a responsibility for the role of the development as the edge of the settlement.
The GI strategy within the Landscape Masterplan looks to take best advantage of those habitats already present in the landscape of the site. These habitats will be taken into the new landscape, making connections in the wider network. This approach will realise the potential of both individual components as well as the greater network gains through a strategy of connection.
Development is to sit back from the site edges, behind new green spaces. The landscape of the future development will make a sympathetic and successful fit in the setting. It will deliver a strengthening of the existing elements at its boundaries, defining a strong and responsive edge of the scheme.
The aim is to deliver a scheme that endures and becomes a cherished place:
“People want to be reconnected with nature and they want to transform underused land to produce clean air and clean water, good micro-climates and good food. They recognise the urgent need to capture carbon and to create landscapes teeming with wildlife. At the same time, they want to be protected from flooding and they want access to land for health and wellbeing.” (‘Green Infrastructure: an integrated approach to land use’ (Landscape Institute. 2013)
6. Summary of Aspirations
This document has set out a vision, current site assessment undertaken to date and the emerging concept proposals for Little Aston Road, Aldridge.
In summary the proposals will deliver the following key benefits and qualities:
» A high quality and attractive residential development that can deliver up to 137 new dwellings.
» An accessible development in a sustainable location that benefits from easy pedestrian links to key facilities, including Cooper and Jordan Primary School and Aldridge town centre.
» A development shaped by existing landscape assets and the provision of significant areas of new accessible public open space, providing the opportunity for new formal play facilities and habitat creation.
» A new cohesive and vibrant community formed by the creation of an attractive, safe and legible place, based on best practice urban design principles.

Support

Representation ID: 23054

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CSP1 - Development Strategy

1(a) states that the plan will deliver at least 47,837 dwellings. We understand that all of the Black Country (BC) housing needs may not be able to be delivered within the plan area, however we consider that there is capacity for the plan area to accommodate additional growth through further Green Belt release to reduce the amount of dwellings that need to be accommodated by the Housing Market Area (‘HMA’). The Duty to Cooperate Statement (July 2021) states that discussions to date have identified that circa 14,750 dwellings could be accommodated by adjacent authorities. Although we acknowledge that there could be capacity to increase this figure, this still leaves a significant shortfall (circa 14,000 dwellings). We consider that these are exceptional circumstances that justify the release of the Green Belt sites already proposed in the Draft BCP as well as additional Green Belt sites that are in sustainable locations but have been rejected by the Black Country Authorities (‘BCA’).
We support the proposed allocation of Site WSA9 and agree with paragraph 3.5 that the locations that have been identified for development are sustainable and deliverable. We consider that Streetly is a sustainable location that can accommodate the growth currently proposed in the plan (Site WSA9) as well as additional growth to assist the BC in meeting their housing needs.
St Phillips have worked collaboratively with Taylor Wimpey (adjacent landowner to the south) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached with this submission). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the draft plan at present and would allow for the inclusion of significant community infrastructure.

Support

Representation ID: 23055

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

A network of new Neighbourhood Growth Areas are proposed to provide 6,792 dwellings in highly sustainable locations on the edge of the Urban Area. We support the allocation of St Philips’ site as part of strategic allocation WSA9.

Paragraph 3.48 states that it is important that “Neighbourhood Growth Areas are master-planned together, regardless of ownership” and phasing plans will be required to set out triggers for the provision of required infrastructure. St Philips are supportive of this requirement and are willing to work with adjacent willing landowners to bring Site WSA9 forward comprehensively.

Comment

Representation ID: 23056

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy GB1 – The Black Country Green Belt
Alterations to the Green Belt require exceptional circumstances in accordance with National Planning Policy Framework (‘NPPF’) paragraph 140. Given the scale of housing need and an identified shortage of brownfield land to meet the need (Urban Capacity Report 2021), we agree with the BCA that there are exceptional circumstances to justify the release of Green Belt.
The policy states that compensatory improvements will be required to offset the impact of removing land from the Green Belt. The Viability and Deliverability Study (May 2021) has allowed for a compensatory contribution of £1,000 per dwelling. No details have been provided on the projects this contribution will fund nor whether improvements could be made on site or on other land within the same ownership/control in lieu of paying the contribution.
The BCA is currently not proposing to safeguard any land for future development within the plan. Paragraph 143 of the NPPF states that plans should “identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period” and “be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period” [Savills emphasis]. Given the BCA has determined that Green Belt release is already required to meet current housing needs and it is acknowledged that there is a significant housing shortfall arising from the BCA and wider HMA, it is accordingly expected that additional Green Belt release will be required to meet the development needs of the District beyond the plan period. It is also considered to be likely that additional Green Belt release will also be required within the plan period as well.
We therefore consider that in order to accord with NPPF paragraph 143, the BCA should be identifying additional land in sustainable locations which can be released from the Green Belt in the plan and safeguarded for future housing needs beyond the plan period. Our client’s land to the west of Chester Road (Call for Sites ID 107) is considered to be in a sustainable location and could be an appropriate addition to Strategic Allocation WSA9 within the plan or at the least, it could be safeguarded to assist the BCA in meeting future needs.

Comment

Representation ID: 23057

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy DEL1 – Infrastructure Provision

Policy DEL1 states that all new developments should be supported by the necessary on and off-site infrastructure. It is currently unclear what level of infrastructure is required to support Strategic Allocation WSA9 and whether this is required on-site or as an off-site contribution. The Viability and Deliverability Study (May 2021) states that no health or education input has been received for Walsall. Point 3 of the policy states that further detail will be provided by the Councils to confirm what level of infrastructure should be provided. We consider that this is required in order to ascertain what level of contribution is required for Strategic Site WSA9.
Our client’s land to the east of Chester Road is included as part of ‘Walsall Cluster 9’ within the ‘Key Large Sites Viability and Deliverability Study’ (May 2021). Density assumptions made within this plan correspond with the densities proposed in Policy HOU2, which we have responded to separately. Page 36 of the report states that Walsall Cluster 9 will deliver 644 units. However, the proposed allocation is for 415 units. We consider that a scheme of 644+ units is more likely to be able to support increased infrastructure requirements if required. St Phillips have worked collaboratively with Taylor Wimpey (adjacent landowner to the south) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Concept plan attached with this submission). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the draft plan at present and would allow for the inclusion of significant community infrastructure.

Support

Representation ID: 23058

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy DEL3 – Promotion of Fibre to the Premises and 5G Networks

The policy requires that all major developments will be required to deliver ‘Fibre to the Premises’ (FTTP) infrastructure to all individual properties. Paragraph 4.42 of the BCP states that the expected cost of FTTP is expected to be relatively small and “any costs to the developer could be balanced by increased sales values generated by fast and reliable broadband being available”. The Viability and Deliverability Study states that the cost of utilities provision has been included in the external works allowance so no specific figure has been quoted. The policy refers to ‘subject to practicality and viability’ which we support.

Comment

Representation ID: 23059

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy HW2 – Healthcare Infrastructure

The policy requires that major developments must be assessed against the capacity of existing healthcare facilities and where the development would have unacceptable impacts upon capacity then developers will be required to contribute to the provision or improvement of such facilities. Policy WSA9 states that appropriate local facilities, including local health facilities, should be delivered to support new residents and the existing area. Further clarity is required to confirm capacity of local facilities and whether existing facilities can be expanded or a new centre is required. If it is the latter, then further clarity if required to confirm the impact of providing a healthcare facility on site WSA9 to the net developable area.
The wider implications of reducing the developable area of strategic sites will inevitably result in more housing being required to meet the needs of the BC. Larger scale strategic allocations may be more appropriate to deliver education and health facilities. St Phillips have worked collaboratively with Taylor Wimpey (adjacent landowner to the south) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached with this submission). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the draft plan at present and would allow for the inclusion of significant community infrastructure.

Comment

Representation ID: 23060

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy HOU1 – Delivering Sustainable Housing Growth
Point 1(a) states that the plan will deliver at least 47,837 dwellings. We understand that all of the BC housing needs may not be able to be delivered within the plan area, however we consider that there is capacity for the plan area can accommodate additional growth through further Green Belt release to reduce the amount of dwellings that need to be accommodated by the HMA. The Duty to Cooperate Statement (July 2021) states that discussions to date have identified that circa 14,750 dwellings could be accommodated by adjacent authorities. Although we acknowledge that there could be capacity to increase this figure, this still leaves a significant shortfall (circa 14,000 dwellings). We support the proposed allocation of WSA9 and consider that there are exceptional circumstances that justify the release of the Green Belt sites in the plan.
In addition to the BC housing need and shortfall there is a wider HMA shortfall which has yet to be confirmed. Although the Draft BCP has not gone into detail at this stage on the wider HMA position. The HMA authorities have published three position statements to support their local plan reviews. The most recent statement was published in September 2020 (‘PS3’) and states that the 37,900 dwelling shortfall (from Birmingham’s housing shortfall not including the BCA shortfall) has decreased to just 2,597 dwellings. PS3 is now being relied upon by the HMA authorities to support their local plan reviews. We do not consider that this approach is sound given that:
- The PS3 only covers the plan period up to 2031 when the local plan reviews, including the BCA plan, are working beyond this period;
- The PS3 does not acknowledge the fundamental changes in the calculation of housing need since the adoption of the Birmingham Development Plan when the 37,900 dwelling shortfall was confirmed which has seen the Birmingham and Wolverhampton minimum housing need increase by 35%;
- The PS3 does not reflect the standard method housing figures and has no regard to other situations where the housing requirement should be higher than the standard method e.g. economic ambitions and affordable housing need;
- The PS3 has over-estimated housing land supply particularly in regards to strategic allocations in Birmingham (Langley site) and Stratford-on-Avon (Long Marston Airfield site).
- The 37,900 dwelling figure quoted in the PS3 also does not consider the BCA shortfall or any shortfall associated with Birmingham with the 35% uplift, and
- The data used to support the findings of PS3 has neither been made readily available nor tested at an Examination yet.
In light of the above, we consider that the HMA housing shortfall is greater than is currently being suggested by the HMA authorities. The NPPF states that in order to be ‘effective’ a plan should deal with cross-boundary strategic matters rather than deferring them to the next plan period (paragraph 35). Therefore, given the BCA has determined that Green Belt release is already required to meet current housing needs (which we consider is significantly lower than it should be), it is accordingly expected that additional Green Belt release could be required to meet the development needs of the District within and beyond the plan period.
St Phillips have worked collaboratively with Taylor Wimpey (adjacent landowner to the south) to produce a combined masterplan to show the potential for community infrastructure delivery across a wider strategic development site, including the land to the west of Site WSA9 (Illustrative Masterplan attached with this submission). This site has the potential to deliver circa 800 dwellings, land for a new school, local centre/health facility and significant public open space including a country park. This wider proposal may also be of a scale that could support a new/improved bus service on Chester Road which would enhance the sustainability credentials of the existing settlement. The scale of the combined proposals gives rise to a more comprehensive opportunity than the constrained and fragmented proposition contained in the draft plan at present and would allow for the inclusion of significant community infrastructure.