Draft Black Country Plan

Comment

Representation ID: 23072

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CC4 – Air Quality
New development is expected to be ‘air quality neutral’ within Policy CC4. Further clarity is sought as to whether this includes mitigation.

Comment

Representation ID: 23073

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy CC7 – Renewable and Low Carbon Energy and BREEAM Standards
The Policy requires that major developments should achieve a 19% carbon reduction improvement and incorporate renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion. These requirements are considered to be over and above the requirements of PPG which states that Local Plans “can set energy performance standards for new housing or the adaptation of buildings to provide dwellings, that are higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes” (Reference ID: 6-012-20190315).
The PPG also states that if a Council is “considering policies on local requirements for the sustainability of other buildings, local planning authorities will wish to consider if there are nationally described standards and the impact on viability of development” (Reference ID: 6-009-20150327). The Viability and Delivery Study (May 2021) has assumed £4,615 per unit for this policy. We consider that this is a significant amount of money per dwelling just to meet energy requirements without any of the other requirements being sought in the plan to be taken into account e.g. affordable housing, specialist housing, accessible dwellings, Green – Belt compensation and other S106 contributions and CIL monies that will be sought by the Council and statutory consultees.
In relation to developments providing at least 20% of energy from renewables, consideration should be given to the capital cost and land take involved to achieve this requirement which we do not consider has been undertaken in the Council’s evidence base. Furthermore, it should be noted that it is now the case that sourcing energy from the National Grid can actually, in some cases be more sustainable than small scale renewable energy production as each year they are sourcing more of their energy from renewable sources.
We consider that the policy should be amended to ‘encourage’ development to apply the energy hierarchy to reduce energy demand and minimize carbon dioxide emissions. The policy should state that this will be subject to viability and suitability considerations at the application stage.

Support

Representation ID: 23074

Received: 11/10/2021

Respondent: St Philips

Agent: Savills

Policy WSA9 – Land to the east of Chester Road, north of Pacific Nurseries, Hardwick
We support the allocation of our client’s land to the east Chester Road as part of Site Allocation WSA9. Our client’s land has limited site constraints and is suitable, available and achievable for development. As set out elsewhere in our responses to the Plan, there are a few matters which we welcome further discussion on with the Council:
- Confirmation of the Council’s approach to SLINCs. As stated in our response to Policy ENV1, we do not consider that there is justification to designate the northern part of our client’s land as a SLINC as it is arable farming land. We also do not consider that there is any evidence to justify SLINCs being afforded the same protection as SINCs in the Black Country. If they are then this will have implications on the net developable areas of the proposed strategic allocations.
- The plan for Policy WSA9 shows a ‘potential primary school’ in key but nothing shown on the plan. Confirmation is required from the education authority to confirm education requirements for the site.

Policy ENV5 – Historic Character and Local Distinctiveness of the Black Country

St Phillips’ land to the west of Chester Road is located within a proposed AHHLV and APA.
St Phillips’ western Chester Road site is located within the wider AHHLV 3 Bourne Vale and the wider Bourne Pool APA 3. However, within the submitted Vision Document, our client has demonstrated that the site only contains a few features that characterise the Archaeological Interest of these Areas, these being the cropmark of the Loaches Bank Enclosure and 19th century field boundaries. All other features that contribute to the APA’s significance and the AHHLV’s character are located beyond the site boundary. Whilst these area distinctions highlight the historic environment interest of the part of the site to the west of Chester Road, they are not defined by adopted planning policy and their presence should not present an in-principle constraint to the site’s development. These designations have been considered when producing the high level masterplan for the site and can be assessed in further detail at planning application stage.
In short, we consider that the benefits of allocating to the west of Chester Road for housing and a community facility / primary school as part of a wider strategic allocation of Site WSA9 would far outweigh any impact on the AHHLC or APA and mitigation could be proposed to limit the impact of development on these designations.

Policy ENV4 – Provision, retention and protection of trees, woodlands and hedgerows

Additionally, we consider that this requirement, in combination with others proposed in the plan (e.g. 10% net gain and 3 to 1 replacement tree planting) will have serious implications on the net developable area of the site and as the BCA cannot currently meet its housing needs, this may result in an even greater shortfall and additional sites will be required to meet this shortfall.

Policy ENV1 – Nature Conservation

In light of the above, as part of the Council’s local plan process, a review of call for sites has been undertaken and as a result, the BCWT has designated additional SLINC’s across the BCA. Within proposed allocation Site WSA9, the northern part of our client’s land has been designated as a SLINC with land to the north (Site WAH 230). Our client’s land assessed by the BCWT, and subsequently allocated as a SLINC, is identified as ‘semi-improved grassland’ in the ‘Birmingham & Black Country Local Sites Assessment Report’ was under arable cultivation until as recently as April 2018. Therefore we question whether this habitat can be described as ‘semi-natural’ given it is at most 3 years old.
Additionally, the Site Assessment Report states that “Based on the values attributed against each of the criteria a judgment must be made as to whether a site merits Local Wildlife Site status. Those sites scoring mostly ‘Highs’ will tend to meet the threshold for SINC status whereas those scoring mostly ‘Mediums’ will tend to meet the threshold for SLINC status. Sites scoring mostly ‘Lows’ will tend not to meet the threshold for selection as a Local Wildlife Site” (page 2). We do not consider that the report’s scoring system (High, Medium, Low) against the various criteria is sound. For example, the site is given a ‘High’ score for ‘Size or Extent’, however this is based on the size of our client’s land to the east (included in site WSA9) and west (not included in WSA9) of Chester Road (total 23.92ha) whereas the area proposed for SLINC designation is only a fraction of this (less than 1.5ha in total). Similarly, the scores given for ‘Habitat Diversity’ and ‘Species Diversity’ refer to the range of habitats across the whole site rather than the few habitats proposed for designation.
In light of the above, we do not consider that there is sufficient justification to support the proposed SLINC on our client’s land or to afford SLINCs the same protection as SINCs. However, regardless of the SLINC designation, as part of future development proposals, these areas could be retained as far as possible within the green infrastructure of the development layout as part of good design, and if some loss is unavoidable, this could be mitigated elsewhere within the site.

Policy HOU5 – Education 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.

Policy HOU2 – Housing Density, Type and Accessibility

Paragraph 6.18 states that investment will be sought to improve any facilities where there is an identified gap in service provision. We understand that Walsall Council has not received input from health or Education to date to confirm their requirements. Therefore, the ‘Key Large Sites Viability and Deliverability Study’ (May 2021) has not been able to assess the level of investment which may be required for the strategic allocations and how the contributions sought are reasonable. Health and education requirements for each site should be confirmed and addressed accordingly within the plan. If these are required on site, then adjustments will need to be made to the housing figures proposed for sites which will likely result in an increased housing shortfall or a need for additional land to be identified around site allocations which could deliver a larger development to support the required infrastructure, such as land to the west of Site WSA9.

Policy HOU1 – Delivering Sustainable Housing Growth

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.

Policy HW2 – Healthcare Infrastructure

. 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.

Policy DEL1 – Infrastructure Provision

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.

Policy GB1 – The Black Country Green Belt

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.

Policy CSP3 – Towns and Neighbourhood Areas and the Green Belt

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.

Policy CSP1 - Development Strategy

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.

 
 
Waterworks Farm, Streetly | Vision

August 2020
1. INTRODUCTION 7
2. LOCAL CONTEXT 21
3. OPPORTUNITIES & CONSTRAINTS 35
4. DESIGN PRINCIPLES & CONCEPT 51
5. SUMMARY AND NEXT STEPS 60
 
[All supporting images and maps can be found in the ‘Vision Document’ Attachment]





Waterworks Farm, Streetly | Vision
1.1 INTRODUCTION
This Vision Document has been prepared on behalf of St Philips Ltd to support the promotion of the Waterworks Farm site for residential development through the Black Country Core Strategy.
The key aims and objectives of the document are:
» To review the site in the context of current planning and Green Belt policy;
» To present an initial understanding of the site within the local context;
» To provide a summary of current site assessments undertaken to date; and
» To present an emerging concept masterplan, accompanied by an explanation of the key design principles that have informed it.
The Site
The site is 24 hectares (ha) in size and is located on the northern edge of Streetly; it benefits from easy vehicular connections to both local and national destinations. Local destinations include Aldridge and Walsall, located approximately 2.5 kilometres (km) north west and 6km west of the site respectively. In a wider context, national destinations can be accessed via junction 6 of the M6 located approximately 5km to the south-west, with central Birmingham approximately 15km south of the site.
The site comprises a mix of agricultural land and grassland, with hedgerows generally defining internal field boundaries. Chester Road (A452) bisects the site, creating eastern and western site areas. The western site area is also bisected by an existing quarry track which crosses the site in a broad east -west direction. The boundaries of the site are defined by existing planting and woodland to the north, fields, residential development and Pacific Nurseries Garden Centre to the south, an existing freight railway line to the east and existing planting, woodland and Aldridge Rugby Club to the west.



1.2 PLANNING CONTEXT

Adopted Planning Policy
This section outlines the relevant planning policy context for the site which is located within Walsall Council’s Local Planning Authority (LPA) boundary. The adopted development framework plan for the site comprises the following documents:
» Black Country Core Strategy (2011);
» Walsall Site Allocation Document (January 2019);
» Walsall Unitary Development Plan Saved Policies (March 2005).
In the adopted development framework plan, the site is located within the Green Belt.
Black Country Core Strategy
The Black Country Core Strategy (BCCS) sets out the vision, objectives and strategy for future development in the Black Country up to 2026 and beyond. It forms the basis of Walsall’s Local Development Framework and will guide future development decisions throughout the Black Country. The BCCS was adopted in February 2011.
Walsall Site Allocations Document
The Site Allocation Document (SAD) identifies specific sites to meet the current and future needs of Walsall. It covers the whole of the borough excluding Walsall Town Centre and the District Centres of
Aldridge, Brownhills, Bloxwich, Willenhall and Darlaston. The SAD replaced many of the policies in Walsall’s current Unitary Development Plan (UDP), in particular the Proposals Map which shows the land uses that are currently allocated for individual sites. The SAD was adopted in January 2019.
Walsall Unitary Development Plan (Saved Policies)

View towards eastern site area and Chester Road from existing quarry track
The Unitary Development Plan (UDP) was adopted in 2005 and covered the period up to 2011. The UDP contains some policies and sections of text that no longer form part of the statutory development plan, due to not being ‘saved’ by the Secretary of State or due to being superseded by the BCCS.
More recently some of the UDP Policies have also been superseded by Walsall Site Allocation Document (SAD) and Walsall Town Centre Area Action Plan (AAP) which were adopted in January 2019.
Neighbourhood Plan
The site is not within a Neighbourhood Plan Area.
Emerging Planning Policy
The Black Country authorities are currently reviewing the BCCS. The review will plan for the Black Country’s future development needs and ensure the necessary services are in place to meet these local needs, along with making sure that the necessary level of investment is attracted to create jobs and wealth in the Black Country.
An Issues and Options Consultation was held between July and September 2017. Representations were submitted to the Black Country Plan Issues and Options consultation and this site was submitted through the Call for Sites process.
The Black Country Plan’s Revised Local
Development Scheme was published in July 2020. The timetable for the production of the Black Country Plan is as follows:
» Draft Plan Consultation: August –
September 2021
» Publication Plan Consultation: August – September 2022
» Submission: March 2023
» Examination: April 2023 – March 2024 » Adoption: April 2024
The Black Country Authorities are holding another Call for Sites consultation in July / August 2020 seeking additional sites or any updated technical information for sites that were submitted through the previous Call for Sites process. The Authorities also published a range of evidence base documents in December 2019, January 2020 and July 2020. These studies include: a Green Belt Assessment; a Landscape Sensitivity Assessment; an Ecological Study; an Urban Capacity Study Update; a Strategic Flood Risk Assessment; and, a
Historic Landscape Characterisation Study.
Urban Capacity Review
An Urban Capacity Review was published by the Authorities in December 2019. The Review concludes that due to the significant need for both housing and employment land across the Black Country over the new Black Country Plan period and the extent of already identified urban sites and limited opportunities for identifying other potential urban land, it is not possible to meet all of these needs in the urban areas of the Black Country.
In order to meet housing and employment land needs, the findings of the Urban Capacity Review demonstrate that there are exceptional circumstances to trigger a Green Belt review in the Black Country.
Green Belt – Exceptional Circumstances
The NPPF is clear that there must be justification for development on Green Belt land to be permitted. Inappropriate development such as new housing is referred to as requiring “exceptional circumstances” to be permitted, as set out in paragraph 136 of the NPPF. A key paragraph in relation to the consideration of these “exceptional” circumstances is paragraph 136 which states:
“Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period.”
Paragraph 137 of the NPPF states that
“the strategic policy-making authority
should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy:
a) makes as much use as possible of suitable brownfield sites and underutilised land;
b) optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c) has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.”
In light of this, we set out below the exceptional circumstances which we consider outweigh any harm that is considered to be caused to the Green Belt.
1. Greater Birmingham and Black Country Housing Market Area
The Birmingham Development Plan adopted in January 2017 identified an unmet need of 37,900 dwellings for the plan period 2011-2031. In addition to the Greater Birmingham and Black Country Housing
Market Area (‘GBBCHMA’) shortfall, the
Issues and Options version of the BCCS Review suggested that there may be an additional housing shortfall of up to 22,000 dwellings (2016 – 2036). The GBBCHMA commissioned a Strategic Growth Study (February 2018) which identified that the outstanding minimum shortfall was 28,150 homes to 2031 and 60,900 homes to 2036. As this is a minimum shortfall, it is expected that more houses may need to be accommodated across the HMA.
The Strategic Growth Study (February
2018) and the Black Country Urban Capacity Review (December 2019) provide justification for the GBBCHMA that there are not enough brownfield sites (NPPF paragraph 137(a)) to accommodate all of the Black Country and HMA housing shortfalls nor will increasing densities on sites meet the entire shortfall (NPPF paragraph 137(b)).
In accordance with paragraph 24 of the
National Planning Policy Framework (NPPF), local planning authorities “are under a duty to cooperate with each other, and with other subscribed bodies, on strategic matters that cross administrative boundaries”. In light of this, neighbouring authorities within the GBBCHMA, such as Walsall, will be expected to accommodate additional housing in order to address the housing shortfall. A Statement of Common Ground has yet to be signed but it is understood that the GBBCHMA authorities are working together to accommodate the housing shortfall across boundaries (NPPF paragraph 137(c)).
In light of the above, it is therefore considered that there are exceptional circumstance which can justify changes to Green Belt boundaries within Walsall and the other GBBCHMA authorities. We consider that there are exceptional circumstances that justify the release of land at Waterworks Farm from the Green
Belt.
2. Direction of Growth
Policy CSP2 of the adopted BCCS states that development outside of strategic centres and regeneration corridors will be focussed on locations with best access to services (where appropriate) and areas of lowest flood risk. Land at Waterworks Farm is located within flood zone 1 and is adjacent to the existing urban boundary which provides a range of services and facilities. Therefore this site represents a location which supports the Council’s strategic direction of growth.
3. Affordable Housing
The release of Green Belt for the delivery of housing will also boost the supply of affordable housing. The adopted BCCS requires sites of 15 or more dwellings to provide 25% affordable housing. Land at Waterworks Farm could provide 25% affordable housing in order to assist the Black Country Authorities in meeting their affordable housing targets (Policy HOU3 states that the affordable housing requirement within the Black Country between 2006 – 2026 is 11,000 new affordable dwellings).
4. Contribution to Community Facilities
The proposed development of Waterworks Farm will provide contributions towards education and health facilities. This will ensure that improvements to existing local community facilities are provided to provide public benefits. Public open space and a contribution towards leisure facilities will also provide further benefits to potential residents.
5. Economic and Environmental Benefits
Release of the site from the Green Belt would also provide an increase in support to existing shops and services and contribute to the vitality and viability of uses within the existing urban area. The site is unconstrained by significant environmental features and will provide a range of green infrastructure which will improve the environmental quality of the site.
Conclusions
Both individually and cumulatively, we consider these points provide the exceptional circumstances that, when taken together, clearly outweigh the harm by way of inappropriateness. It is concluded that the “Exceptional Circumstances” required by the NPPF in order to approve inappropriate development in the Green Belt exist in this instance and that the proposals accord with Green Belt Policy.


Existing overhead cables and quarry track
Defining Green Belt Boundaries
Paragraph 139 of the NPPF sets out guidance when defining Green Belt Boundaries.
a) “ensure consistency with the development plan’s strategy for meeting identified requirements for sustainable development;
b) not include land which it is unnecessary to keep permanently open;
c) where necessary, identify areas of safeguarded land between the urban area and the Green Belt, in order to meet longerterm development needs stretching well beyond the plan period;
d) make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following an update to a plan which proposes the development;


Green Belt Study
The Black Country Green Belt Study (LUC, September 2019) published in January 2020 is divided into two stages:
» Stage 1: analyses how each area is performing against the NPPF purposes
» Stage 2: assesses the levels of Harm to the Green Belt if the land is released.
The study area is broken into several parcels of various sizes for Stage 1 assessment. These parcels are further subdivided for Stage 2 assessment.
In Stage 1, the site lies within parcel B93 – East of Walsall, which at 1768.3ha is a considerably large parcel. The site is located in the north-eastern edge of this parcel and constitutes only 1.4% of the area. Each purpose within Stage 1 has been rated on a three-point scale of Weak/No Contribution, Moderate Contribution and Strong Contribution. All parcels have been scored the same for Purpose 5.
Parcel B93 is further sub-divided for the Stage 2 assessment of Harm and into different scenarios based on area of land to be released. The site lies within the northeastern edge of sub-parcel B93C. The site to the west of the A452 is considered under B93Cs2 ‘Release of any land between the woodland around Bourne Vale and the A542 Chester Road’. The site to the east of the A452 is assessed within B93Cs3 ‘Release of land to the east of the A542 Chester Road’.
The Stage 2 study notes that the sub-parcel B93cC “makes a strong contribution to preventing the sprawl of the West Midlands conurbation, maintaining the separation of Aldridge and Streetly (adjoining Sutton Coldfield), and preventing encroachment on the countryside.”
However, it continues to state that the land part of B93Cs2, “east of the welltreed Bourne Vale, contained by inset development to the south and by washedover but urbanising development to the north, could be released with less impact on Green Belt integrity, in particular, in terms of the separation of Aldridge and Streetly (adjoining Sutton Coldfield).” B93Cs2 was assessed to have a High Harm rating in comparison to B93Cs1 (land further west) which is Very High levels of harm.
B93Cs3 was assessed to have ‘Moderate-
High’ levels of harm if released from the
Green Belt. The Study indicates that “the A452 Chester Road forms a clear boundary that would contain release of the area to the east without having too great an impact on the settlement gap, and the railway line with associated tree cover that forms its boundary to the east would limit impact on the countryside beyond.”
It should be noted that a majority of the subparcels are assessed to be Very High Harm around Walsall, with some sub-parcels rated as High Harm. Very few sub-parcels are present, that are Moderate- High Harm or of a lower harm rating in this area as illustrated in the plan extract from the Study..



Proposed Green Belt Change
The opportunity exists to release land at Waterworks Farm to deliver additional housing. The release of land would allow:
» The new Green Belt boundary to follow recognisable physical features that are durable and likely to be permanent including existing highways –Little Hardwick Road; existing railway line – Sutton Park Line; existing hedgerows & tree cover; existing garden centre Chester Road.
» Creation of a new and resilient Green Belt boundary along existing physical features.
Purpose 1 NPPF: (a) to check the unrestricted sprawl of large built-up areas Proposed Green Belt Change
The proposed changes to the Green Belt boundary would be localised and small scale. The Green Belt would sit along clearly defined boundaries that are likely to be durable and permanent..
» Land released would not cause unrestricted sprawl north west towards Aldridge.
» Corporation Wood and Tower Covert Ancient Woodland sit to the west of the site and would prevent any westward sprawl towards Aldridge.
» Thick vegetation, existing residential properties and the pump house would limit sprawl northwards.
» Creation of a new and resilient Green Belt boundary along existing physical features.
Purpose 2 NPPF: (b) to prevent neighbouring towns merging into one another
The proposed Green Belt boundary would not cause neighbouring towns to merge into one another. The proposed boundaries would sit along clearly defined elements that are likely to be durable and permanent.
» The proposed Green Belt would be approximately 1.001km deep between Streetly and Aldridge, at its narrowest.
» Development of the site would not cause Streetly and
Aldridge to merge into one another
» Elements in the landscape which would contribute to Green Bely being likely to be permanent include:
1. Woodland
2. Farmland
3. Sutton Park Line
Purpose 3 NPPF (c) to assist in safeguarding the countryside from encroachment
The proposed Green Belt boundary would not cause significant encroachment into the countryside as it sits on clearly recognisable features. The clearly recognisable features are:
» Residential housing, a garden centre and a pump house to the north of the site provide urban influences.
» Corporation Wood, Sutton Park Line and residential housing provide clear boundaries that would prevent encroachment of the countryside.
With the release of the Potential Development Site, the Waterworks Farm site would provide a sustainable extension to Streetly.



 
2.1 ACCESS AND MOVEMENT & LOCAL FACILITIES




2.2 LANDSCAPE CHARACTER

The site lies within National Character Area 67: Cannock Chase and Cank Wood.
Local Landscape Character:
The Black Country Historic
Landscape Characterisation
Study (2019): Barr Beacons & Aldridge Fields (WL09)
The 2019 Historic Landscape Characterisation Study (HLCS) focuses on the history of the landscape, the forces for change that have made character driving influences on character and builds on the character areas as found within the previous 2009 The Black Country: A Historic Landscape Characterisation (HLC). The HLC divides the Black Country into several Character Areas. Fourteen separate Character Areas are identified for Walsall. The site and its surroundings are within the eastern part of character area: ‘WL09 Barr Beacon & Aldridge Fields’. The description of the character area has not changed in the updated HLCS and remains as presented within the HLC.
Barr Beacon & Aldridge Fields is a rural area comprising farmland and field systems between the settlements of Walsall, Aldridge and Birmingham. The HLC study describes the area as unusual for the Black Country, due to the area being mainly agricultural land and dispersed farms. The HLC notes that the field systems to the east were:
“…enclosed during the late 18th/early 19th century, which exhibit straight roads and boundaries typical of parliamentary enclosure”.
The WL09 Barr Beacon & Aldridge Fields character area extends to 2127.5 ha. and the site constitutes just 1.2% of the total area.
The HLC makes specific reference to surviving pockets of ancient woodland, dating back to the 18th and 19th century, and the Barr Beacon heathland. The ancient heathland at Barr Beacon described as:
“The only area of what had once formed part of Cannock Forest to survive the planned enclosures of the 18th/19th century”.
The high ground of the Beacon (227m AOD), is very nearly over 100m higher than the site at 130m AOD but it is over 2.5km distant to the south west of the site. The site sits low in the landscape of the wider setting and is visually discrete in the very expansive panoramic views from this local vantage point (Viewpoint 1).
The 2019 HLCS further notes Areas of High Historic Landscape Value (AHHLV) which are areas that contains landscape features (both historic and natural) which are considered to make a significant contribution to the historic landscape character of the Black Country. AHHLV 3 Bourne Vale lies west of Chester Road. It states that this AHHLV “represents a well preserved post-medieval agricultural landscape, with a high potential for surviving archaeological remains dating from the prehistoric to the Roman period. Such remains are rare within the Black Country and elsewhere within the region have been destroyed by later industry and residential development.” The AHHLV is assessed within the Heritage section.
National and Landscape
Character Area Plan



Black Country Landscape Sensitivity Assessment (2019)
The Black Country Landscape Sensitivity Assessment (LSA) (LUC, September 2019) was published in January 2020. The LSA provides an assessment of the extent to which the character and quality of the landscape abutting the West Midlands conurbation within the Black Country and around settlements in South Staffordshire is, in principle, susceptible to change as a result of introducing built development.
The assessment of landscape sensitivity to housing and commercial development uses a criteria-based process and was then provided with sensitivity judgements. The overall rating of the landscape sensitivity is based on a five-point scale – Low, LowModerate, Moderate, Moderate-High and High in an ascending order.
The site lies within the eastern part of Landscape Area BL33. “The landscape is considered to have an overall moderate sensitivity to residential development, based on the absence of pronounced landform features, some degree of rural character with regular field patterns, the combination of open and enclosed areas and the presence of prominent pylon routes.”
Extract from Black Country Landscape Sensitivity Assessment for Walsall
Walsall BoroughPotential SINC removal
Other Local Authority Sensitivity rating
Green BeltHigh
Landscape areaModerate - High
Landscape area in South StaffordshireModerate
Absolute ConstraintLow - Moderate
Potential SINC additionLow


Extract from Black Country Landscape Sensitivity Assessment showing sensitivity rating for Land Area BL33
 


Waterworks Farm, Aldridge | Vision
Landform of the Site and the Setting
Landform is a key component of landscape character. It also influences many other attributes in the landscape including: land use, settlement pattern, and tree cover etc.
The landform of the site has a gentle dip and fall with a north-west orientation. This gentle undulation in the landform becomes more marked near the north west corner and eastern boundary. The shape and form of the ground drops from a high point +140m AOD north of Pacific Nurseries across the site towards a low point +128m ADO in the north west corner.
This gentle rise and fall is recognisable in the landform of the immediate setting. Landform across the wider setting, within 15km of the site has a more varied character. A ridge of considerably higher ground runs with a broadly north-south alignment, from the north at Leighwoods at 183m AOD to Barr Beacon at 227m AOD in the south .
30
Land Use and Settlement Pattern
The site is situated at the northern edge of Streetly. It is also approximately 2km to the south of Aldridge (population of 26,988 in the 2011 Census). The centre of Walsall is situated approximately 6km to the west of the site. Walsall is not visible from the site.
The Sutton Park Railway Line, currently operating as a freight only line, adjoins the site’s eastern boundary and runs approximately under 1km to north of the site in a north-west to south-east direction. The M6 (toll) lies approximately 6km to the east of the site. The motorway is neither visible nor perceived from the site.
Chester Road (A452) runs through the centre of the site, dividing the site into an eastern and western part. Little Aston Road (A454) to the north of the site (approx. 800m) is another major transport route aligned in an east-west direction.
Sutton Park lies approx. 1.5km south east of the site and is one of Europe’s largest urban parks made up of a mosaic of heathland, woodland, wetlands and marshes. It is a Registered Park and Garden and a National Nature Reserve. Settlement pattern has been influenced by Sutton Park and it tends to spread outwards, away and around the park To the northwest the settlement continues to have spread in something of a radial pattern.
The 2009 Historic Landscape Characterisation study notes the presence of two small clusters of housing in the centre of the ‘WL09 Barr Beacon & Aldridge
Fields’ character area. The first at Bourne Vale, 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 landscape 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”.
Land to the west includes a range of recreational and outdoor activities, including Aldridge Rugby Club. The Beacon Hill Quarry is to the north of the site and the working quarry is accessed by a track that cuts through the site from the A452. Bourne Pool is on the lower lying land to the north of the site.

Landform Plan
Waterworks Farm, Aldridge | Vision 32

Tree Cover of the setting
Tree cover is present within the wider setting (approx. 15km from the site) with parcels of broadleaved woodland dotted across the landscape. Much of the tree cover is within hedgerows and several woodlands scattered across the wider landscape and includes the Cannock Chase Area of Outstanding Natural Beauty (12 km from site).Corporation Wood, to the west of the site, is designated as an Ancient and Semi-Natural Woodland (ASNW).
Much of the tree cover in the local setting (under 5km from the site) is within:
» Corporation Wood bordering the site to the west,
» Lowlands Wood bordering the site to the north;
» Roundabout Wood 500m to the east of the site; and
» Sutton Park, a National Nature Reserve (1.5km to the south east of the site), contains a mix of ASNWs & Ancient Replanted Woodland.
ASNW is present to the south west including Towers Covert which adds to the tree cover along with Corporation Wood and Lowlands Wood, which covers Little Aston Golf Course. The HLC (2009) refers to small areas of woodland that have survived to the south of Aldridge originating from the 18th or 19th centuries. Overall, fields are mainly devoid of any trees and tree cover is situated to the edges of the site, marking the field pattern.
Looking west across the site from A452 Chester Road.
View from Daniels Lane looking south east towards the site.





 
3.1 OPPORTUNITIES AND CONSTRAINTS

The findings from the initial site and context assessment have been evaluated to identify the emerging constraints and opportunities relevant to the development of the site.
A summary of these initial findings is set out below:
Access
In total, two points of access are being promoted, and these are summarised below:
» A 4-arm normal roundabout inclusive of pedestrian facilities approximately centred 100 metres north of the access to Pacific Nurseries, and;
» A priority junction with right turn lane located a further 180 meters north of the proposed roundabout.
In deciding upon these access options, the potential quantum of development and rural setting of the development site has been fully taken into account. The roundabout option will accommodate the majority of development traffic and in keeping with the surrounding area, whilst creating a focal gateway into Streetly to the south.
Each of the above access proposals would be fully considered at planning/ detailed design stages and be informed by a Transport Assessment (including full junction capacity assessment) to ensure that a viable and a safe means of accessing the development site can be secured, meeting the needs of both motorised and non-motorised users.
Given the expansion of the built environment it also proposed that the current 30mph be extended commensurate with this, and the introduction of the roundabout will serve to control vehicle speeds to this new limit.
In conclusion, the initial investigatory work has demonstrated that suitable and safe means of accessing the development site(s) can be maintained, whereby the cumulative impacts of such would not be severe.
Flood Risk and Drainage Strategy
The risk of flooding has been assessed from all sources, including from fluvial, tidal, surface water, groundwater, existing and proposed drainage infrastructure and other artificial sources in accordance with the National Planning Policy Framework. The site is located predominately located within Flood Zone 1 (low risk of fluvial and tidal flooding) and the only exception is a small area in the north west corner where no development is proposed. The site is at low risk of flooding from the majority of other sources.
A large proportion of the site has the potential to be affected by reservoir breach flooding from Barr Beacon Reservoir located 2km south west of the site area as identified by the Environment Agency. The reservoir is operated by South Staffordshire Water and is maintained in accordance with the Reservoir Act. The risks associated with reservoir flooding reduce with distance and investigations show the last incident
at the reservoir occurred in 2011 due to a water main failure and not a failure of the reservoir itself. This resulted in flooding along Aldridge Road, Elmstree Road and Blackwood Road, approximately 1000m south of the site. The reservoir is considered to pose limited risk to the proposed development area.
Surface water runoff from the development will be restricted to pre-development (greenfield) runoff rates up to the 1 in 100 year plus 40% climate change rainfall event. In order to achieve this restriction, the use of a number of on site attenuation basins is proposed for the development. These would discharge to various locations around the development including existing Severn Trent Water surface water sewers in Chester Road and along the western boundary and to a local watercourse to the north of the site. Sustainable drainage systems shall be used throughout the development to provide amenity and biodiversity as well as mitigate against any pollution risk from surface water entering the local drainage systems.
A foul water sewer is located within Chester Road, both portions of the development site will require pumped foul water systems discharging to this sewer.



Ecology
A high-level assessment of the current ecological baseline within the site has been undertaken, based on a desk study and an Extended Phase 1 habitat survey.
No part of the site is covered by any statutory ecology/ nature designations with the nearest such site being Sutton Park Site of Special Scientific Interest (SSSI) and National Nature Reserve (NNR), located approximately 1.1 km south east of the site. No direct or indirect impacts on this designated site are anticipated.
No part of the site is covered by any non-statutory nature designation site, although a number lie adjacent to the site, including three Sites of Local Importance for Nature Conservation (SLINC) and four Potential Sites of Importance (PSI). These are: Corporation Wood and Tower’s Covert SLINC (Towers wood is also designated as an area of ancient woodland); Osier Bed SLINC; Bourne Pool SLINC; Bourne Farm
Nursery and Pool PSI; Bourne Vale PSI;
Sunny Bank Quarry PSI; and Sutton Park Line Railway PSI and Wildlife Corridor. Given the potential for the adjacent non-statutory sites to be affected by ground water run-off from the proposed site and the presence of ancient woodland at Towers wood, any development will need to be offset from these areas. Towers Wood ancient woodland will require a minimum offset of 15m, according to Natural England’s standing advice.
The site itself comprises areas of predominantly arable fields divided by hedgerows with occasional mature trees. An ecological evaluation of the Black
Country Green Belt was undertaken in
2020 to inform the emerging Draft Black Country Plan. This evaluation uses a number of criteria to establish the value of a given area, ranking areas using five ratings from low to high. As part of this evaluation the area of land to the west of Chester Road is considered to be of 3- Medium/high value and the area to the east of Chester Road is ‘2- Medium/ low’ value. The habitats adjacent to the western boundary of the site, which are designated as SLINCS are ranked as being of 4-High and 5- very high value.
Offsite ponds are present to the north and these may support a population of great crested newts (GCN). However, given the lack of suitable terrestrial habitat present within the site it is considered unlikely that GCN (if present within the offsite ponds in any case) would pose a significant constraint to any future development.
Hedgerows and mature trees are likely to provide foraging and roosting habitats for low numbers of common and widespread bat species and foraging and nesting habitat for birds.
Given the size of the site and its predominantly arable land use, whilst also acknowledging the presence of areas of existing ecological value within and immediately adjacent to the site, it is considered that there is scope within any future development for the enhancement of the retained habitats and creation of new habitats, along with the sympathetic management of these areas to provide a net gain for biodiversity..

Phase 1 Habitat Plan


Geo-environmental
Historically the majority of the site has remained undeveloped land used for agricultural purposes, with some minor development within the east of the site prior to 1950 and the construction of a concrete haulage road across the western half of the site prior to 2014.
Review of geological mapping indicates that the site is likely to be directly underlain by bedrock comprising Chester Formation (sandstone and conglomerate), with superficial River Terrace Deposits (sand and gravel) underlying the eastern and northwestern edges of the site. It is likely that a thickness of both topsoil and localised Made Ground are present across the site.
The site is considered to be developable and based on the anticipated ground conditions, a traditional foundation solution is likely to be suitable for the majority of the scheme. Limited potential sources of contamination have been identified, which would likely require straightforward mitigation measures, if necessary.
Arboriculture
A tree survey, compliant with BS5837:2012
Trees in Relation to Design, Demolition and Construction, has been undertaken of all trees within and adjacent to the site that could be affected by its proposed allocation and development.
The survey recorded a total of 50 individual trees, 5 groups of trees, 16 hedgerows and one woodland; totalling 72 items. Of these, eight have been classified as category ‘A’, of high quality and value; 20 as category ‘B’, of moderate quality and value; and 44 as category ‘C’, of low quality and value.
Four Tree Preservation Orders cover six trees, two groups and a woodland -Towers Wood, of which all but one of these are on the external boundary or at the margins of the site; with the other adjacent to the track to Branton Quarry.
The majority of boundaries surrounding the field parcels within the site are formed by hedgerows and occasional individual trees, with a small number of tree groups and one woodland forming the remaining boundaries. No trees are located within the actual field parcels.
The peripheral nature of tree cover is such that it should be possible to retain many of the trees and incorporate these into any development and therefore these should not constrain any future development of the site.
Root protection areas (RPA) for all category A, B and C items have been calculated using the methodology set out in BS5837:2012 to inform the masterplanning process. Category A and B items would be prioritised for retention due to their condition, age and retention span.
Noise
Noise surveys have been undertaken at two locations at the proposed site, to enable assessment of sound levels with reference to BS8233:2014 ‘Guidance on sound insulation and noise reduction for buildings’, and ‘Professional Practice Guidance on Planning & Noise, New Residential Development 2017’, to assist in specifying a suitable general noise mitigation strategy for the development.
The survey results and assessment show that sound levels in areas adjacent to Chester Road, the quarry access road (located within the north western area of the site) and the rail freight line (adjacent to the eastern boundary) currently exceed the recommended noise criteria, which is not unusual for residential developments located adjacent to transport sources.
To attenuate sound levels to meet the relevant criteria, the general mitigation strategy will comprise of all, or a combination of, the following measures:
» Careful design of the site layout, so that buildings provide screening of noise sources to gardens.
» The installation of acoustically sound barriers at site boundaries adjacent to transport sources;
» Installation of acoustically sound garden fencing, where required.
» Either 30m standoff from roads and 100m standoff distance from the rail line to the development; or
» No bedroom windows to face these noise sources, to enable a practicable glazing and ventilation specification; and
» Specification and installation of suitably attenuated glazing and ventilation systems.

Tree Survey Exert


Heritage
An initial desk-based appraisal has been undertaken in order to assess the archaeological potential of the site and the possibility for effects on heritage assets, through changes to their setting. In summary, no in-principle heritage constraints have been identified to the allocation of the site and its suitability for residential led development.
There are no designated heritage assets within the site or its vicinity, and no potential for any impact on off-site heritage assets has been identified through changes to their setting. The nearest designated heritage asset is a Grade II listed building, some 880m to the north of the site.
The non-designated, locally listed, 19th century Bournevale Pumping Station lies
c.40 to the north of the site. Elements of the setting of this building which contribute to its heritage significance are quite closely defined and development within the site could be accommodated without any adverse impact.
The remains of an Iron Age triple ditched enclosure known as Loaches Bank fall mainly within the northern part of the site. This survives exclusively as below ground archaeological remains, although the full extent of the enclosure can be seen on aerial photographs. The enclosure has previously been partly excavated, and investigation has also identified some medieval activity within it. Loaches Bank
is an important archaeological site, which would require careful consideration in the masterplanning of any development, although given its current state of survival it is not considered that this represents an in principle constraint to the allocation of the site.
The site is included within The
Black Country Historic Landscape
Characterisation Study (Oxford Archaeology, 2019) with part of the site to the west of Chester Road lying within the wider AHHLV 3 Bourne Vale and the wider Bourne Pool Archaeological Priority Area (APA 3). However, the site only contains a few features that characterise the Archaeological Interest of these Areas, these being the cropmark of the Loaches Bank Enclosure and 19th century field boundaries. All other features that contribute to the APA’s significance and the AHHLV’s character are located beyond the site boundary. Whilst these area distinctions highlight the historic environment interest of the part of the site to the west of Chester Road, they are not defined by adopted planning policy and their presence should not present an in-principle constraint to the site’s development.
Further assessment will be undertaken to establish the significance of any heritage assets affected, in line with the NPPF, and to feed into the design of any development. However, there is no reason to believe that the site would contain any archaeological remains which would constrain the deliverability of the site.
Air Quality
WMBC has declared a boroughwide Air Quality Management Area for exceedances of the annual mean nitrogen dioxide (NO2) objective. WMBC currently operates six automatic air pollutant monitoring sites across the Borough, the closest of which is located along Walsall Ring Road, approximately 5.5km west of the proposed development site.
With regard to air quality impact upon future receptors at the site, and existing receptors in close proximity to the site, relevant exposure is already present in the form of existing residential dwellings adjacent to local roads. As these have already been considered within WMBC’s Air Quality Review and Assessment process, it is expected that all air quality objectives will met at the proposed site, and at dwellings adjacent to local road links.
Detailed air quality assessment will be undertaken to predict NO2 and PM10 pollutant concentrations at the site, and to quantify increases arising from development traffic within the local area. Impact significance will then be established, and a mitigation strategy developed, with reference to national and local guidance.
A suitable mitigation strategy, proportionate to predicted development impact, will be identified. Proposed mitigation measures will support actions contained within WMBC’s Air Quality Action Plan. It is envisaged that the mitigation strategy would be developed in liaison with WMBC to maximise opportunities to improve air quality in the area.

Heritage Assets Plan
3.2 LANDSCAPE & VISUAL OPPORTUNITIES AND CONSTRAINTS

The site boundaries are defined:
» Bourne Farm Nursery to the north;
» Sutton Park Line Railway Line to the east;
» Pacific Nurseries; to the south
» Towers Covert and Aldridge Rugby Club to the west; and
» A452 (Chester Road) cutting through the middle of the site.
The site compromises 6 arable fields of an irregular pattern clearly delineated by hedgerows with some mature hedgerow trees. The landform of the site is gently undulating, sloping north ranging from 140m AOD to the south to 128m AOD to the south eastern edge.
The site has an irregular shape to allow for some of the existing built form and to take into account the existing field pattern. The site is divided into two parcels by the A452 (Chester Road), which traverses through the middle of the site in a north-south direction. Pylons pass through the site to the east with a tower on the southern boundary and one inside the site boundary to the north. Low density tree cover along the east of the site allows the railway track, which is raised on an embankment to be visible from the site in areas. A small group of new build residential properties in Waterworks Farm border the site in the south. Residential properties along Cottage Mews border the site to the north.
Tree cover is limited to trees scattered amongst the hedgerows within the site. Tree cover along the site boundary is dense along the north, east and west edges with small areas where it opens up to expose buildings and the railway track. Along the southern edge is almost no tree cover except for a few individual trees within the hedgerow to the south-west.
There are no public Rights of (PRoW) on site and the nearest PRoW (275) is 80m to the north of the site.
Subject to the land to the south being released, additional pedestrian and cycle linkages could be provided.
Landscape & Visual Opportunities and Constraints Plan



Views and Visual Amenity
The site is situated in an area where landform is gently rolling with a few areas of high ground. The site is afforded a degree of containment by the surrounding vegetation compromising tree belts, woodlands, dense hedgerows buildings.
From the north, views are afforded in close proximity from the site. These views are glimpsed or filtered through the existing vegetation from PRoW 275. Views from further north are limited due to dense vegetation along hedgerows, the railway line and the A454.
Views from the south are generally filtered by hedgerows and built form except for the occasional opening allowing a clear view from Little Hardwick Road and Foley Road (B4151). Due to intervening vegetation, residential properties along Little Hardwick would have limited views of the site.
Wide panoramic views are afforded from the Barr Beacon vantage point (227m AOD) to the south west of the site. The site in general is obscured from this location due to the extent of vegetation with the exception of some heavily filtered views.
To the south east the upper storeys of the residential properties on Leacliffe Way orientated towards the site, may have filtered views of the site through the branches of the trees
From the east views are non-existent from the immediate setting, due to the railway line and associated vegetation. Further south east along PRoW 1870, the site is visible although heavily filtered by a band of trees along the railway line. Views from the west are restricted by Corporation Wood. There are clear views from the A452 which passes through the site in all directions, providing an expansive view of the site.
View from Little Hardwick Road, looking north towards the site.
 
 




 
4.1 DESIGN PRINCIPLES AND CONCEPT
The Design Principles Plan and Concept Masterplan for the site are presented in this section. Both plans have been informed by the vision and site constraints and opportunities set out in previous sections of the document.
The scheme has also been shaped by the following design principles: »
»
»
» A primary movement ‘loop’ is proposed in both eastern and western site areas, ensuring that all areas of the development are accessible and legible through a clear hierarchy of streets. This concept will be further re-enforced through the provision of a new network of informal footpaths which respond to key desire lines within the site and provide recreation routes, promoting journeys via sustainable forms of transport and healthy lifestyles.
The proposals provide a significant amount of open space that will be multifunctional and accommodate areas for recreation, formal play, attenuation and ecological enhancement, whilst retaining existing tree and hedgerow planting wherever possible.
Open spaces will be linked via a network of attractive green corridors that are overlooked by development. They will vary in size, formality and function and benefit from being easily accessible from the majority of dwellings, promoting community interaction and cohesion.
Subject to the land to the south being released, further consideration will be given to wider connectivity opportunities.
»
»
» Provision of approximately 10.18ha of developable land, achieving approximately 375 dwellings, using an average density of 37 dwellings per hectare (dph).
Primary vehicular access to the site is proposed via a 4 arm normal roundabout junction located on Chester Road (A452). A priority junction with a right turn lane is proposed a further 180m north of the proposed roundabout.
The 30mph speed limit on Chester Road will be extended to the proposed primary access point, helping to reduce speeds and improve accessibility. This also provides the opportunity for the site to form a landmark gateway to Streetly; this could be defined by the use of increased storey heights and densities and a considered architectural style along the Chester Road frontage.


» The proposals recognise the opportunity to use positive elements of the existing built form (including scale, building form and architectural style) to guide the creation of a distinct character.
» The existing quarry access track will be retained in situ, with an appropriate offset between the track and existing dwellings provided. The hedgerow and tree planting that adjoins the track will be retained and supplemented by new planting, ensuring good levels of visual screening for dwellings.
» Utilities routes and their associated casements will be accommodated within the masterplan.
» The masterplan accommodates
appropriate noise offsets that are required from Chester Road and the freight railway line.
» The structure of development blocks has been considered where the site boundary adjoins existing development. Development will ‘back on’ to existing development, ensuring the retention of defensible rear boundaries and ensuring that the privacy and amenity of these properties is respected.
» A potential vehicular and pedestrian connection has been identified on the south western site boundary; ensuring that linkages are achievable with the potential development site to the south.


4.2 LANDSCAPE STRATEGY
The objective of the Landscape Strategy is to set the development into the host landscape in a manner that achieves a sympathetic and successful assimilation in the countryside at the settlement edge.
There are three key objectives for Landscape Strategy:
» to make an important contribution to integrating the development with the host landscape of the immediate setting;
» to create a public asset of attractive green space to serve the needs of the development and to establish a strong Green Infrastructure network; and
» to ensure the effects of the development are limited and contained in a manner that makes an attractive and effective new edge to the settlement.
Existing components: Public Footpaths, field pattern, boundary vegetation, hedgerow and trees will give form and structure to the new green infrastructure (GI). These existing components will be connected with new green spaces to form a network of biodiverse planted linkages. It will also provide linkage to other GI assets beyond the site. These components will be retained and enhanced where appropriate, with the development arranged around it, to provide strategic and meaningful space.
Green Infrastructure Components Plan



The Landscape Strategy has at this early stage of conceptual design work been identified by Landscape and Visual Appraisal work that is set out in this document. Landscape Character at a national level has informed the understanding of the site and its relationship to the countryside and settlement. A high-level GI and Landscape Strategy proposes the division and softening of the development, retention of the historic field pattern in places with the hedgerow boundaries. It also addresses the boundary edge in the centre of the site along the A452.
The development has been embedded into the surrounding countryside with green spaces being placed to the northern, eastern and western edges. Simultaneously the southern face of the site has been established to integrate it into the existing settlement.
The western area of the site will be converted to a public open space, enhancing the setting of Tower Covert Ancient Woodland and providing a biodiverse buffer between development and countryside. The various retained hedgerows will be supplemented in places with further green space and provide a green corridor through the site. To the east additional tree cover scatted amongst new public open space will assist in setting the development into the host landscape further and provide a defensible edge to the settlement. This will enhance the site’s relationship into the countryside. This new eastern woodland belt along the Sutton Park Railway Line would allow further green links to the Sutton Park National Nature Reserve.
There will be extensive areas of new publicly accessible open green space created within the development including three formal play area provisions for children. The public open space will be linked by informal footpaths. Future development to the south of the site has been considered and access is provided to allow for potential future integration.
The A452 will act as a tree lined central axis where the buildings will be set back providing a green buffer zone, whilst enhancing the GI of the area and providing a soft edge to the development.
The north of the site will be populated by waterside green spaces as part of the sustainable urban drainage system (SUDs). The SUDs will require shallow storage basins to be created to attenuate rainwater, along the site’s north boundary. These features have been located to serve drainage operational requirements. They also have a biodiversity role as well as providing an enhancement to the development. They will be designed, planted and managed in a manner that serves as a public amenity.

Object

Representation ID: 43844

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

1. INTRODUCTION
1.1. This is a representation to the Regulation 18 Draft Black Country Plan which is subject to consultation until 11 October 2021. It is made on behalf of St Philips in respect of land they are promoting for residential development at Blackhalve Lane, Wolverhampton.
1.2. A Vision Document for the site has already been submitted and is included again with this submission. The site largely falls within South Staffordshire with the area to the south falling within the Wolverhampton City boundary.
1.3. The Vision Document explains the background work that has been undertaken and how the site constraints and characteristics have influenced a framework masterplan, which St Philips would like both Wolverhampton City and South Staffordshire Councils to consider. Similar representations will be made to the South Staffordshire Preferred Options plan, where consultation is due to begin in the coming weeks.
1.4. The following document covers a number of policies and paragraphs in the plan which are considered to be relevant to St Philips and/or the site they are promoting. St Philips reserve the right make further representations in due course. It should be noted that not commenting on an aspect of the emerging plan does not mean they agree with that content.
1.5. The remainder of this representation document is as follows:
· Representation
· Conclusion

2. REPRESENTATION
2.1. St Philips would like to begin by expressing their support for the allocation of the land (inside the Wolverhampton CC boundary) at Blackhalve Lane, particularly as it relates well to the existing established settlement edge, with the opportunity to provide a more definitive boundary to the Green Belt beyond.
2.2. The following table summarises the policies that we have commented on in this representation: Table 1 – Policies/Paragraphs subject to comment:
Policy/Para Title Page
HOU1 Delivering Sustainable Housing Growth 89 (Table 3 and Table 4)
HOU2 Housing Density, Type and Accessibility 96
HOU3 Delivering Affordable, Wheelchair Accessible and
Self Build / Custom Build Housing 101
CC2 Energy Infrastructure 267
CC7 Renewable and Low Carbon Energy and BREEAM
Standards 290
HOU1 – Delivering Sustainable Housing Growth and WOH271 FPNGA - Land east of Wood Hayes Road, Wolverhampton and CSA2 Fallings Park Strategic Allocation.

2.3. The land east of Wood Hayes Road is proposed to be allocated for about 40 dwellings at a density of around 25 dwellings per ha. We consider this could be increased on the basis that there are opportunities within the wider side for compensatory access to open spaces, should the wider site be included as an allocation in the emerging South Staffordshire Local Plan. Moreover, a development density of around 30 dwellings per ha would be more aligned to the established densities within the immediate vicinity of the site.

2.4. The site would fall into the ‘Fallings Park’ strategic housing allocation for this edge of the city, which is proposed as an allocation under Policy CSA2 for around 300 dwellings, plus open space and other facilities.
2.5. It is noted that the council expect the partners within the allocation to enter into dialogue over the delivery of the allocation as a strategic whole and this is something St Philips welcome and would like to take part in, particularly where it relates to ensuring there is adequate apportionment over school place impacts, highways impacts, provision of green infrastructure (including recreational open space) and biodiversity net gain.

4. CONCLUSION
4.1. Overall St Philips welcome the inclusion of their site east of Wood Hayes Road as part of the Fallings Park strategic allocation and its removal from the Green Belt. We agree with the reasoned justification and evidence that underpins the approach the city council have taken so far. St Philips will make further representations to the emerging South Staffs Local Plan when the consultation begins as they believe there is an opportunity for further land to be included in this allocation within their administrative boundary.

4.2. They fully intend to cooperate with the other landowners/promoters of the parcels within the allocation and agree that a holistic approach is clearly preferable. Whilst St Philips have prepared a Vision document for the site, this is subject to further conversations with the other partners within the allocation.

4.3. We have made comments on more generic planning policies where we consider it is justified, and we urge the BC councils to consider the points we have made.

Object

Representation ID: 43845

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.6. The BC authorities aspire to deliver 47,837 new homes over the course of the plan period 2020 to 2039. We note that in Table 4, there has been a lapse rate allowance of 10% discounted to allow for some sites which may not come forward over the course of the plan. We would like to know whether this truly represents the historic lapse rate pattern, as we are aware of a substantial number of sites within Wolverhampton that have not come forward because of persistent viability problems associated with heritage, site contamination and other issues which include tensions between commercial/industrial land values being similar to those of residential (post-remediation). We are not clear whether this has been considered carefully enough.

2.7. Further, the BC authorities propose to ‘export’ 28,239 dwellings outside of its boundary – but as South Staffordshire Council have just publicised their preferred options Local Plan, it remains the case that they propose to take c.4,000 dwelling as (unmet need), but it is not clear whether this is unmet need from the GBSLEP area, or the Black Country. This needs clarification.

2.8. At 7,657 (Table 3), we consider the windfall allowance to be high – it represents around 16% of the total housing target for the plan period, which is a considerably proportion. Given the requirements of the NPPF, we consider the plan is at risk of not being ‘positively prepared’ given this (we feel) overreliance on unallocated housing in the emerging plan. Paragraph 71 of the NPPF sets this out clearly: ‘Where an allowance is to be made for windfall sites as part o f anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends. Plans should consider the case for setting out policies to resist inappropriate development of residential gardens, for example where development would cause harm to the local area. '

Object

Representation ID: 43846

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.9. We are broadly supportive of the densities proposed in the emerging plan, however for reasons already given, we consider that the densities on the land controlled by St Phillips within the Fallings Park allocation could be increased without compromising on the design quality and need to ensure the character of this edge of the site is maintained.

2.10. We would seek some flexibility in the application of accessibility standards – particularly as a result of the move towards more sustainable personal travel modes, such as electric cars.

2.11. We would also seek flexibility in the application of housing mix standards, where evidence from the availability of second hand stock within the immediate area demonstrates an oversupply of a particular size of dwelling.

Object

Representation ID: 43847

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.12. We are broadly supportive of the affordable housing policy but would suggest the policy is slightly reworded to make it absolutely clear that those minimum proportions should only be required where viability demonstrates it is deliverable. Setting minimum levels are laudable, but unlikely to make a difference in reality if viability is an issue (as is the case on many BC sites).

2.13. We are broadly supportive of the requirements to make more homes accessible for disabled people.

2.14. The 5% self-build requirement does raise some concerns, however – related to maintaining health and safety on large housing sites, as well as in relation to the ultimate control over phasing. Given the council’s strong reliance on windfall sites – many of which are likely to be self or custom build, we cannot see why the council can justify requesting a proportion of self-build on large housing developments that are proposed for allocation.

Object

Representation ID: 43848

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.15. We are concerned about the proposal to require a decentralised energy network on sites of 10 dwellings or more. We remain unconvinced that decentralised energy is always appropriate in anything other than unconstrained, strategic level development sites (000’s rather than 00’s of dwellings), and certainly not for smaller schemes.

2.16. This is because of the limitations this can place on the ultimate consumer – where decentralised energy can limit consumer choice in terms of energy provider and where the consumer may wish to add further energy saving measures – such as solar power, heat pumps, etc.

2.17. It is not clear from this policy why it would be beneficial: district heating systems have had a mixed result, where residents have had to sign up for long term contracts of 25 years or more. Efficiencies tend to be a lot lower for small schemes, as the infrastructure costs can be the same, so the larger the scheme, the more viable it could be. The industry itself is not regulated in the same way and physical problems with a district heating system or decentralised energy system can often result in whole areas being without heating or hot water for period of time.

2.18. We would therefore urge the BC authorities to reconsider the wording of this policy to ‘encourage’ the use of such systems, but not to stipulate that they must be used.

Object

Representation ID: 43849

Received: 05/10/2021

Respondent: St Philips

Agent: RCA Regeneration Ltd

2.19. We consider that, linked to the above policy CC2, the aims of CC7 are laudable, it is clear that there is some duplication between this planning policy and Building Regulations, which are delivered in any case. There are therefore elements of this policy which are not particularly justified or necessary, insofar as they effectively repeat Building Regulations requirements.