Black Country Core Strategy Issue and Option Report

Question 1: Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you think should be the scope of the review?
2.3 In response to Question 1 and whether it should be a partial review or not, whilst the existing strategy identifies the most sustainable locations for growth in the context of delivering development requirements identified by the Regional Strategy (RS), there is now a new and much bigger challenge ahead in meeting the arising needs for homes identified by the latest evidence and there is concern that the existing spatial strategy may not facilitate the delivery of these needs. The Black Country authorities, therefore, need to be mindful of this and not attempt to put "a square peg in a round hole".
2.4 It is our view that urban regeneration can be achieved whilst pursuing development on the urban edge. Indeed, the scale of housing need is so large that both must be encouraged in order to meet current and arising housing needs within the Black Country.
2.5 It is extremely important that in reviewing the Core Strategy it fully takes account of and facilitates the delivery of strategic economic plans, as recognised in paragraph 1.15. All too often these strategies are ignored and, accordingly, development plans could effectively frustrate economic growth from being realised.
2.6 In terms of the Plan period proposed in paragraph 1.17, whilst a 15 year time period from adoption is appropriate, there is concern that the preparation of plans is often delayed (due to reasons beyond the control of the LPAs) and it may be prudent to stretch the period further to prevent such an issue from occurring.
2.7 It is welcomed that the Issues and Options document recognises that it will not be possible to accommodate all future development needs within the urban area and that an examination of the potential for development land outside the existing urban area, which is effectively land within the Green Belt, will take place as part of the Core Strategy review process.
3. THE BLACK COUNTRY TODAY - THE EXISTING STRATEGY
3.1 As set out within this section, the delivery of both employment and housing land has not come forward as originally envisaged in part due to the after effects of the recession. Surplus employment land which might have been available for housing has not come forward due to a strengthening economy and local firms being more robust than anticipated. In addition, the range of locations available has not in all cases met with market expectations as to where people want to live.
3.2 In terms of the employment land, it is important that sufficient land is provided for new employment and that there is not an overreliance on land that is currently in use. It is impressive that despite generally poor economic performance local businesses have performed well. Should the economy significantly improve within the Plan period in line with LEP aspirations (considered later in this response), there is concern that it may become difficult to transfer existing employment locations to housing allocations. It is appropriate, therefore, for the Council to ensure the evidence contained in the Strategic Housing and Employment Land Availability Assessment is reviewed and updated regularly. This will enable the land supply to be responsive to arising needs and not rigidly be wedded to delivering commitments that are unlikely to be realised.
3.3 What is further emphasised by the analysis in this section is that urban regeneration cannot be delivered quickly and that there are a number of factors beyond the control of the Black Country authorities that may have implications on the delivery of the strategy. This further emphasises the need for a mix of types of sites (brownfield, brownfield compulsory purchase, greenfield and Green Belt) of different forms of development (high density, mid and low density family homes) in a variety of locations, which will maximise the opportunities to deliver a successful Local Plan.
3.4 Finally, in respect of the proposal to maintain 300 hectares of employment land that will become vacant by way of general churn over the Plan period. Whilst the principle is considered acceptable, there should be appropriate evidence to support the assumption.
3.5 Our experience is that there are employment sites that clients are looking to secure a residential allocation on that have not been identified thus far. In light of these changing circumstances, the Black Country authorities should ensure that the policy approach is flexible to allow sites in appropriate locations to be brought forward for housing throughout the Plan period and likewise, sites that have been allocated for housing but have not come forward should be removed from the supply.
4. THE STRATEGIC CHALLENGES & OPPORTUNITIES
4.1 It is welcomed that the Black Country authorities are updating their evidence base. Indeed, the adopted Core Strategy took the development requirements from the adopted Regional Strategy (RS), which has since been revoked and is unquestionably out of date. Since the RS was published there has been a number of population and household projections published showing increasing dwelling requirements in the Black Country, which were largely ignored and, therefore, it should come as no surprise that there is a significant increase in forming households.
4.2 In terms of the list of evidence either prepared or due to be completed, it appears to be sufficiently comprehensive.
4.3 A separate review of the housing evidence based, including the Strategic Housing Market Assessment for the Black Country and South Staffordshire, is contained at Appendix A. The key conclusions arising from the report as summarised as follows:
* The OAN identified by the SHMA for the Black Country and South Staffordshire is generally supported, however, there are concerns with regard to the methodology and it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline.
* There is concern that the economic growth scenarios do not use the latest economic forecast data and that the methodology translating the job growth into dwelling growth is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances and also more aspirational job growth targets, such as those arising from the SEP.
* In terms of providing uplifts for market signals, a 25% uplift for South Staffs is appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, it should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack within the housing market and prevent house prices from increasing at an accelerated rate.
4.4 In addition, consideration of the Housing Background Report is also contained in the Housing Evidence Based Review Paper contained at Appendix A. The key findings from reviewing the evidence is set out below:
* Clearly a lot of work is yet to be done to determine what the housing land supply position is in the Black Country. Given that much of the existing evidence is based on the adopted Core Strategy, it is recognised that the SHLAAs across the four authorities will need to be updated, both in terms of revising the methodology and range of sites assessed, to reflect a potentially different approach to locating development.
* It is commendable that the Housing Background Report has examined existing sources of supply in an attempt to provide additional homes from sites within the urban area. There is concern, however, that by changing policies, for example, to increase the minimum density on sites has wider policy implications to take into account than simply increasing the number of homes.
* The Housing Background Report suggests a continued allowance for larger windfall sites. It is suggested that it is inappropriate to include an allowance for this source as there is no certainty that this land will come forward for development.
* Other sources, such as converting employment sites to residential sites, based on the evidence presented and feedback from the development industry, it is known that there are employment sites functioning well as employment sites but are to be converted to residential and other employment sites that are unoccupied and undesirable that are to be retained as employment sites. Clearly, there is a mismatch between employment land need and employment land supply. It is advised that the qualitative assessment of employment informs future land supply recommendations and allocations are revised where necessary.
4.5 As a result of the dwelling requirements generated by the SHMA and the land supply identified from the Housing Background Report, it is concluded that there in insufficient urban land to provide for the development requirements and that a Green Belt Review should be conducted. It is noted that scoping is underway and that the work is to be completed in mid 2018. It is hopeful that the development industry will be involved in defining the methodology of the work to ensure that it is conducted in a robust way.
4.6 Another very important piece of work to be taken into consideration will be the Greater Birmingham and Black Country HMA Strategic Growth Study. It is unclear at this stage what role the Black Country authorities will play in meeting the wider needs of Birmingham and, indeed, whether it can now contribute given that meeting the needs of the indigenous population will be a tall order. Further, there is uncertainty with regard to how far the study will go in identifying locations for growth and how this evidence will be taken forward in emerging Development Plans, particularly given that it is premature to the Green Belt Review for the wider Black Country area. It is our view that there are sites within the Green Belt that will provide sustainable locations for growth and that their removal will not compromise the purposes of the Green Belt and, accordingly it will remain purposeful and functional.
Question 2: Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there are any particular issues that should be taken into account in considering development on any particular sites or in any particular areas, please provide details
4.7 It is considered that the evidence contained within Table 1 is comprehensive, however, as suggested above and below, a number of concerns have been highlighted and it is therefore suggested that these are addressed in order to improve the soundness of the next iteration of the Core Strategy Review.
4.8 It is welcomed that an updated qualitative assessment of employment land has been undertaken in order to identify if the sites are fit for purpose, alongside the quantitative employment land study. It has been identified that a number of employment land sites that have been suggested for residential land allocations remain in occupation as functioning employment sites. These sites should be removed from the housing land supply. Conversely, there are vacant employment land sites that have been marketed over a period of time where no market interest has been forthcoming and, therefore, it is recommended that these sites should be considered for housing delivery.
4.9 It is noted that Viability Studies are identified as evidence base documents that are still to be prepared. Whilst not specifically identified, it is recommended that affordable housing viability is a key matter that needs to be addressed as part of this evidence base to ensure the level suggested by the SHMA Part 2 is deliverable. If this is not the case, the delivery of both market and affordable housing could be compromised and prevent the successful delivery of any new strategy.
Question 3: Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.10 In terms of the extent of the sub market, which includes the Black Country and South Staffordshire, this is considered to be appropriate. It is recognised and welcomed that the Black Country authorities and South Staffordshire have jointly undertaken a SHMA for the sub area, which facilitates the preparation of an Issues and Options Core Strategy Review. There is concern, however, that the remaining constituent authorities within the wider Greater Birmingham Housing Market Area have not taken part and there is a danger that housing need for the whole HMA may not entirely be comprehensively captured due to the different time periods covered by the separate studies. It is advised that a SHMA, consistent with the guidance in the NPPF and Planning Practice Guidance, is prepared for the entire HMA over the same Plan period (as opposed to a housing needs study), which will properly consider all relevant factors in a consistent and comprehensive manner.
4.11 The OAN arrived at by the SHMA is generally appropriate in identifying the starting point for determining the dwelling requirement, however, it is suggested a further scenario should be tested to consider long term growth which includes balanced periods of economic prosperity and decline. There is concern that the economic growth scenarios contain potentially out of date employment forecasts and the methodology to determine appropriate dwelling requirements is not sufficiently robust to accurately determine the impact of forecasts based on existing circumstances. In addition, more aspirational job growth targets, such as those arising from the SEP, may not necessarily be appropriate for the Black Country (as discussed later in these representations).
4.12 In terms of providing an uplift for market signals, a 25% uplift for South Staffs is agreed to be appropriate. It is advised that dwelling requirements for the Black Country should not be reduced as a result of this and, accordingly, the application of such an uplift in South Staffordshire should not count towards meeting any unmet needs outside of the HMA as the main function is to provide slack or headroom within the housing market and prevent house prices from increasing at an accelerated rate, exacerbating issues of affordability.
4.13 Clearly, the evidence contained in the SHMA does not consider the potential to accommodate any of Birmingham City's housing needs and that this could result in increased dwelling requirements. We reserve our position in respect of this matter and await the publication of the HMA wide Strategic Housing Needs Study.
4.14 We shortly await a consultation publication from central Government in relation to providing a standardised methodology for generating dwelling requirements. This is anticipated in Autumn 2017. The Black Country authorities will need to take account of any proposed national policy changes identified through the consultation paper. We reserve our position on this matter, until the full details and implications for the Back Country are known. It is considered that, whilst a standard methodology will be helpful in identifying a baseline dwelling requirement, the consideration of long term trends and economic forecasts cannot be carried out in a mathematical calculation outside a demographic/ economic model. In light of this, the SHMA prepared for the sub-area could remain useful as evidence to inform the review of the Black Country Core Strategy.
4.15 In terms of meeting the dwelling requirements, it is understood that the 'Call for Sites' consultation will inform an updated SHLAA, which will assess sites both within and outside the urban area to determine the maximum number of dwellings that can be realistically delivered within the Black Country over the proposed Plan period. The Housing Background Report that has been published as part of the evidence base for the Issues and Options Core Strategy Review has considered assumptions contained within the SHLAA based on adopted policies and considers changes to the policies to boost the delivery of housing on existing sites. Whilst it is a commendable that the Black Country authorities are exploring all potential options to boost housing on urban land, there are wider implications of doing so and accordingly, caution is expressed in response to a number of the identified approaches proposed.
4.16 As confirmed in paragraph 3.15, it is extremely important that the Black Country authorities 'firm up' the housing supply in order to ensure that there is sufficient provision to meet the dwelling requirements. It is also considered appropriate to provide an additional buffer of housing land supply to provide a contingency when sites are delayed. As explained earlier in the Issues and Options Report, sites providing a total of 3,000 homes have not come forward as anticipated. It is considered that additional supply is required to provide flexibility and minimise any durations within the Plan period where the housing trajectory would otherwise dip.
4.17 In terms of the extent of a buffer for housing land, the Local Plan Expert Group suggested that additional land, equivalent to delivering 20% of the overall dwelling requirement, is added to the supply, which will provide a contingency of land to be used as and when necessary during the Plan period. It is suggested that this additional land will help ensure the dwelling delivery targets and housing needs are met in a timely manner, which will reduce the opportunity for households to become concealed or shared. Given the issues experienced in respect of delivery in the past, it could be argued that an increased buffer of circa 25% could be applied.
4.18 It is also appropriate to ensure that, as well as identifying the right amount of land, there is sufficient variety in the types of sites (brownfield, greenfield, Green Belt) are identified, reflecting different sizes, in a range of locations. This variety in provision will allow the best opportunity for multiple sites to come forward at the same time without market constraint and hence ensuring delivery targets are met. In addition, this approach will also provide market choice to existing and arising households looking to move into a new home in the Black Country, which will have wider social benefits (i.e. allow families to live nearby one another and provide an opportunity to diversify existing communities through providing alternative homes to the existing housing stock).
4.19 Indeed, as previously documented in the adopted Core Strategy, it is considered that the ambition to retain the young and professional population within the Black Country should be maintained and that suitable and attractive housing and complementary environments are encouraged.
4.20 Finally, it is welcomed that the Black Country authorities have agreed to test the dwelling requirement figures on an ongoing basis. It is hoped that the suggested changes/alternative scenarios suggested above are implemented in order to ensure the evidence base is robust and the resultant policies and proposals soundly based.
Question 4: Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain why they are not appropriate and in line with national guidance.
4.21 The Core Strategy review intends to utilise the Economic Development Needs Assessment (EDNA) for the Black Country, published in May 2017, to inform future employment land requirements. The EDNA uses forecasts produced as part of the West Midlands Combined Authority Strategic Economic Plan (SEP) to calculate long-term growth, noting that the 'Super SEP Economy+ Scenario' is the preferred aspirational scenario. This scenario assumes average annual growth in employment of 1.3% across the Combined Authority and presents an ambitious view of future growth in the area, with 500,000 jobs created between 2013 and 2030.
4.22 The SEP Technical Appendix breaks down the job forecasts for the three Local Enterprise Partnerships that form the Combined Authority (Black Country; Coventry & Warwickshire; and Greater Birmingham & Solihull). Jobs growth in the Black Country LEP is forecast to be around 1.1% per annum, whilst it is forecast at 1.5% per annum in the other two LEP areas. This averages out at annual growth of approximately 1.3%. Using data from the Business Register & Employment Survey, published by the Office for National Statistics, it is possible to look at employment trends over the last five to six years (2009-15) and this analysis suggests that the growth rate used in the aspirational growth scenario may be too ambitious for the Back Country:
4.23 Between 2009 and 2015, total employment in the Black Country LEP increased from around 450,000 to approximately 453,000. This equates to average annual growth of 0.1%. Walsall (1.5% p.a.) and Sandwell (0.9% p.a.) experienced jobs growth, although Dudley (-1.1% p.a.) and Wolverhampton (-0.8%) both suffered a fall in employment.
4.24 By contrast, both the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs saw total job numbers increase by 1.3% p.a. from 2009-13. A number of districts in these LEPs saw particularly strong growth over the period, notably Solihull and Lichfield in Greater Birmingham & Solihull, where employment grew by at least 3.0% on an annual basis. In short, the 1.3% average across the West Midlands Combined Authority Area is substantially bolstered by Solihull and Lichfield and therefore it is very ambitious to suggest this will occur across the Black Country area.
4.25 That said, growth in the Black Country needs to be faster than in previous years and the new Core Strategy has a vital role to play in supporting this, however the analysis presented above suggests that the growth targets need to be lowered to better reflect the local economic climate. It is considered unlikely that an annual increase of 1.0% or more will happen in the area in the long-term, especially with the Coventry & Warwickshire and Greater Birmingham & Solihull LEPs capturing new job opportunities at a faster rate in recent years. Lowering the employment growth rate means the amount of employment floorspace needed would be lower. This would not reduce the demographically based housing targets for the area but it would potentially free up previously allocated employment sites for other uses such as residential. This would help the Black Country meet its future housing targets and ensure that it has enough homes for its future workforce to live in.
4.26 As identified in the supporting report and above, it is known that employment sites that had previously been identified for housing are still operational with businesses continuing to use the land and, conversely, there are sites allocated for employment that have been vacant and subsequently market, however, remain unoccupied, which could be transferred to a residential use. It is therefore recommended that the Councils ensure that updated EDNA qualitative review conclusions are taken into account and correct uses applied where appropriate.
Question 5: Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?
4.27 In respect of the Green Belt Review, on the basis of the evidence published setting out housing need and supply, it is agreed that it will be necessary to find sites outside of the existing urban area, which will require removing land from the Green Belt where it is appropriate to do so. This will provide an opportunity to identify strategic sites that can provide a significant amount of homes to contribute to meeting identified housing needs. It is considered that there are a number of locations whereby housing sites can be identified, without the purposes of the Green Belt being compromised, ensuring the function and integrity of the Green Belt will remain.
4.28 In addition, areas on the urban fringe have the potential to ensure new homes can be delivered in an established, well landscaped environment, which could be attractive to those young families and professionals that the Black Country authorities have had difficulty in retaining, often through out-migration to neighbouring Shire districts considered to represent more aspirational locations.
4.29 In terms of the process and methodology for undertaking a Green Belt Review, it is understood that the awaited Strategic Housing Needs Study (SHNS) will be accompanied by Strategic Green Belt Review across Greater Birmingham and that the Black Country authorities have been engaged in presenting potential opportunities. It is reassuring that this engagement between consultants and local planning authorities is taking place as there is a danger that logical locations fail to be identified due to a lack of understanding of environmental conditions and/ or local circumstances that are applicable to sites.
4.30 It is agreed and makes sense for the local planning authorities to conduct a Stage 2 Green Belt Assessment following the completion of the higher level work. Any input on reviewing the draft methodology for the Stage 3 Green Belt Review would be welcomed.
Question 6: Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be taken into account?
4.31 The key issues presented are considered to be relevant, however, there are a number of inconsistencies relating to matters identified above against the previous questions raised.
5. REVIEWING THE STRATEGY TO MEET NEW CHALLENGES & OPPORTUNITIES
Question 7: Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?
5.1 In the main, the Core Strategy Vision and sustainability principles are considered to be appropriate, all except for the principle to 'put brownfield first'. It is understood that the NPPF, whilst it encourages an efficient use of land and for brown field land to be recycled, it does not suggest a sequential approach to development. The is no evidence to demonstrate that the development of greenfield land will compromise the development of brownfield land. Often the type of developers of the different land categories are different and, given the scale of the housing need, it is appropriate that the early delivery of housing is encouraged from all types of sites. In particular, the larger, potentially Green Belt, sites will have a longer lead in time due to the time it takes to plan for, determine and implement a comprehensive scheme. Indeed, a recent study entitled 'Start to Finish', prepared by NLP, supports this claim. When planning the housing trajectory for the Core Strategy, the larger sites should be planned in to come forward as soon as practically possible.
5.2 It is, therefore, suggested that the reference to 'putting brownfield first' is inappropriate and that it should be replaced by 'ensuring an efficient use of land to meet the identified housing needs', which encourages the recycling of land and recognises the contributions of greenfield/ Green Belt land to meeting housing delivery targets.
Question 8: Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strategy policies?
5.3 Whilst the objectives outlined generally remain sound, there is concern that one of the NPPF's main priorities is absent. This is in relation to significantly boosting the supply of housing. It is suggested that an additional objective is added in order to ensure that meeting housing needs remains a priority within the Black Country. Once a preferred option is arrived at, spatial references as to where the housing growth will be delivered could be included (for example, meeting housing needs on urban (brownfield and greenfield) land and at extensions to the urban area).
5.4 Further, given the increased employment land requirements, the second objective relating to employment land being within the best locations within the Regeneration Corridors may no longer be appropriate. Indeed, as highlighted earlier, there is concern that there is a mismatch in land allocations, and it is appropriate for the Core Strategy review to ensure all employment sites are fit for purpose. This may conclude that employment opportunities should be identified on new land outside of the Regeneration Corridors. Should this be the case, the objective would be inappropriately worded.
Question 9: Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think should be made to Policies CSP1 and CSP2 in response to new challenges and opportunities?
5.5 It is agreed that the policies could remain, if the development requirements and related changes are made to ensure the policies are consistent with the overall strategy. The changes relate to both the quantum of development (homes, employment and retail space), the location of development (within and beyond the existing Regeneration Corridors) and the type of development (brownfield, greenfield and on land removed from the Green Belt). It is considered that references should be made to urban extensions (on land removed from the Green Belt) in Policy CSP2 specifically, to highlight the important contribution that such sites will make to meeting the development requirements of the Plan.
5.6 On a separate note, whilst a point mostly relating to the South Staffordshire Local Plan to which separate representations will be made, it is considered that the currently adopted approach to spatial distribution in South Staffordshire will need to be re-assessed. Given the huge housing requirements of the Black Country and the shared housing market between South Staffordshire and the Black Country, it is considered that suitable urban extension sites located within South Staffordshire District would be the logical and sensible locations to meet any remaining unmet housing need. In terms of the relevance of this point to the Black Country Review, it will be important for the Black Country authorities to collaborate with South Staffordshire on cross-boundary issues, and to identify suitable extension sites to the Black Country built area which fall within the planning jurisdiction of South Staffordshire District. It is welcomed that this approach is planned to be undertaken, by virtue of the forthcoming Green Belt Review which will be a joint exercise between the Black Country Authorities and South Staffordshire District.
Question 10: In continuing to promote growth within the Growth Network, is there a need to amend the boundaries of any of the Regeneration Corridors in the existing Core Strategy? Yes/No; If so, which boundaries and why?
Question 11a: Do you support Strategic Option 1A? Yes/No; If yes, please explain why. If no, do you support Option 1B? Yes/No; If yes, please explain why. If you support the release of further employment land for housing, what should the characteristics of these employment areas be?
Question 11b: Are there any current employment areas that might be considered suitable for redevelopment to housing? Yes/No; Please submit specific sites through the 'call for sites' form.
5.7 As highlighted previously, the key to understanding where the most appropriate employment/ housing locations are within the Growth Network and Corridors will be determined through a qualitative assessment of allocated employment sites. It is understood an updated assessment has been undertaken and such work, complete with responses to the Call for Sites consultation, will provide the Black Country authorities with evidence to determine the urban capacity for housing, which may include transferring some employment land to housing as well as housing land to employment. This work will then outline the number of dwellings to be accommodated beyond the existing Growth Network within the Green Belt.
5.8 It is welcomed that the Issues and Options Draft recognises the need to release Green Belt in all scenarios proposed.
Question 12a: Do you support Spatial Option H1? Yes/No; What criteria should be used to select suitable sites? e.g. ability to create a defensible new green belt boundary, size, access to existing residential services.
Question 12b: Do you think there are any potential locations that should be considered? Yes/No; If yes, please provide details (please submit specific sites through the 'call for sites' form).
Question 13a: Do you support Spatial Option H2? Yes/No; What should the characteristics of Sustainable Urban Areas (SUEs) be? e.g. minimum/ maximum size, mix of uses, mix of housing types, accessibility to other areas. What criteria should be used to select suitable sites? e.g. proximity to a rail station, availability of existing infrastructure, easy access to jobs, potential to support existing settlements / services, proximity to the existing growth network, potential to support urban regeneration.
5.9 Given the scale of the housing need, there is concern that the development requirements could not be met with just one of the suggested options presented and, therefore, a combination of both options will be necessary.
5.10 To be in the best possible position to significantly boost the amount of housing and meet the development requirements in the Black Country, in accordance with the NPPF, it is advised that opportunities to both round off edges of the Green Belt and Sustainable Urban Extensions are proposed in the Preferred Options Draft Core Strategy. As highlighted within the Issues and Options Draft, there are challenges and opportunities that come with both types of development, for example from a delivery perspective, smaller sites will come forward more quickly due to the nature of these being straight forward proposals (with limited infrastructure necessary and one or few land owners) and larger sites will ultimately take longer as they are more complex (with multiple land uses, infrastructure and land owners). This fact has been evidenced by Nathaniel Lichfield and Partners (now known as Lichfields) within their report 'Start to Finish' who concluded that the average planning approval period of schemes of 2,000+ dwellings is 6.1 years and the annual average build out rate is 161 dwellings per annum. These figures demonstrate the need to have a number of sites of different sizes and in different locations removed from the Green Belt. The report also identifies, with regard to housing delivery, that 50% more homes per annum are delivered on average on large greenfield sites than large brownfield sites. This is a significant benefit of including greenfield sites within the Preferred Option and will assist to secure its delivery.
5.11 In terms of the locations for removing land from the Green Belt, this should be informed by the Strategic Growth Study and a Black Country Review of the Green Belt. The more detailed study will provide an assessment of land parcels against the purposes of the Green Belt and is likely to recommend that those that compromise the purposes the least will be shortlisted for further consideration to be removed from the Green Belt. It is advised that the next stage should be a consideration of the shortlisted sites based on their suitability (i.e. are the neighbouring uses compatible, would any previous land uses prevent the development of the site), sustainability (i.e. proximity to/ ability to provide local services/ public transport/ employment opportunities) and deliverability (i.e. whether the site is available, being promoted for development, has no barriers to coming forward etc.) credentials. Clearly each site will fair differently against such criteria and the Call for Sites submission will assist the Council to come to a decision on the preferred sites. It is advised that the Black Country authorities should be mindful of the opportunities, through infrastructure and design, that development can bring that will enhance the diversity and character of a particular location.
5.12 In terms of the characteristics of a Sustainable Urban Extension, this is likely to vary depending on the location of each site. For example, some may be more urban and others suburban in their character and would, therefore, provide a different land use offer. It is important that each are considered on a site by site basis to ensure that any subsequent allocation delivers a successful development. It is important that the developer responsible for promoting the site helps to influence what is ultimately delivered. Often what is proposed on site has been informed by housing market intelligence undertaken by sales experts at development companies and, therefore, should be taken into account. Particularly given recent experience in the down turn in the apartment market, it is important that sites are allocated for the right type and mix of housing to ensure that it will be delivered, occupied and successful.
5.13 In the more suburban locations, it is suggested that Sustainable Urban Extensions should look to provide a different offer to potentially what exists in the Strategic Centres and Regeneration Corridors, such as a mix of larger and lower density homes, which will attract those households that in the past have migrated elsewhere. Given the emphasis on delivering more high density homes in the Strategic Centres, it is important that this housing mix is offset by more larger homes in appropriate locations. Otherwise, there is a concern that the Black Country will have a disproportional amount of small homes, which will further encourage more families to migrate elsewhere and not meet the aspiration to diversify the wider HMA.
Question 13b: What infrastructure do you think would be needed for different sizes of SUEs?
5.14 The type of infrastructure needed will vary depending on the different location and size of each site and must be compliant with paragraph 122 of the CIL Regulations that requires planning obligations (which applies to most infrastructure) to be necessary to make the development acceptable in planning terms; directly related to the development; and fairly and reasonably related in scale and kind to the development.
5.15 With the above in mind, however, provision for open space (both formal and informal), local centre and potentially a primary school should be considered for sites in excess of 1,000 homes.
Question 13c: Are there any potential locations that should be considered for SUEs (please submit through the 'call for sites' form) and what infrastructure would be required to support these?
5.16 Land at Home Farm, Sandhills is a location on the edge of Brownhills in Walsall Borough that could accommodate in excess of 1,200 homes, complete with open space, al local centre and potentially a primary school if required. A Call for Sites form is included at Appendix B, which demonstrates the sites suitability, achievability and deliverability. In addition, a Technical Compendium is included at Appendix C, which includes evidence in relation to landscape and visual matters, cultural heritage and archaeology, transportation, agricultural circumstances, ecology, flood risk and drainage and ground conditions. All of which serves to demonstrate there are no constraints to the delivery of the site and that residential development of circa 1,200 homes can be successfully achieved.
Question 13d: Do you think that the Core Strategy should set out detailed guidance for the development of SUEs (e.g. type and tenure of housing, specific infrastructure required), rather than details being determined at a local level in light of local policies? Yes/No; Any further comments?
5.17 For the reasons outlined above, relating to considering existing local circumstances and CIL Regulation requirements in respect of any charging schedule and planning obligation requirements, it is advised that detailed guidance for the development of SUEs should not be specified within the Black Country Core Strategy as each site will vary and deserves a more detailed consideration, alongside the developer, at the local level.
Question 14: Do you think there are any other deliverable and sustainable Housing Spatial Options? Yes/No; If yes, please provide details
5.18 There are no other sustainable and deliverable options that we are aware of within the Black Country administrative boundary that are capable of delivering the housing spatial options.
Question 15a: If all housing need cannot be met within the Black Country, do you support the 'export' of housing growth to neighbouring authorities within the HMA? Yes/No; What factors should be taken into account in an assessment of the opportunities in neighbouring authorities e.g. proximity to the edge of the urban area, proximity to a rail station, availability of existing infrastructure, easy access to jobs?
5.19 If, once all realistically deliverable options have been considered, there remains an unmet need for housing it is agreed that the Black Country authorities should consider the possibility of exporting growth to neighbouring authorities within the HMA. In particular, there are options to expand existing settlements that are close to the administrative boundary (for example, in both the Black Country and South Staffordshire) across authorities and, therefore, once all options within the HMA have been explored, these could help deliver growth in a sustainable and deliverable manner. These opportunities should be explored first prior to exporting further growth to other authorities within the HMA where there is less of a spatial connection.
Question 15c: Do you think there are ways to ensure that exporting housing will meet the needs of people who would otherwise live in the Black Country? (e.g. transport improvements, provision of affordable housing, creation of employment opportunities) Yes/No; If yes, please provide details.
5.21 It is important to consider a number of factors, including migration and travel to work patterns, which have been used to identify the extent of the HMA, to determine where households relocate to when leaving the Black Country in order to understand where and why those moves are taking place. Whilst planning can attempt to influence where people relocate to, there is no mechanism to guide or restrict people moving to or from certain locations. Once knowledge of movers can be understood can the planning system can attempt to recreate those attractive characteristics (homes that are more affordable, good public transport links, employment opportunities etc.) in locations where there is capacity for the homes to be delivered. It is advised that an additional analysis of the data, where necessary, is undertaken to provide the Black Country authorities with the relevant intelligence to deliver a successful strategy for growth outside the administrative area.
Question 16: Do you support Spatial Option E1? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 17: Do you support Spatial Option E2? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites e.g. quick motorway access, good sustainable transport links? If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 18: Do you support Spatial Option E3? Yes/No; What type of sites are needed to meet the needs of industry and what criteria should be used to select sites? (e.g. quick motorway access) If you think that are any potential locations that should be considered please provide details (please submit specific sites through the 'call for sites' form).
Question 19a: Do you support Spatial Option E4? Yes/No; Any further comments?
Question 19b: Should any factors be taken into account in an assessment of the opportunities? Yes/No; If yes, what should they be? (e.g. quick motorway access, strong transport links with the Black Country, good sustainable transport links with the Black Country) If you think there are any potential locations that should be considered, please provide details.
Question 20: Do you think there are any other deliverable and sustainable Employment Land Spatial Options? Yes/No; If yes, please provide details.
5.22 As previously outlined, there is concern that some of the employment sites currently identified are potentially not fit for purpose and others that are identified to be transferred to housing remain in employment occupation. In light of this mismatch, it is welcomed that an updated qualitative assessment has been undertaken and has informed how much employment land is has be found outside the urban area.
5.23 In terms of where the employment land should be located outside the urban area, as with housing, decisions should be based on the results of the Green Belt Review and the suitability, sustainability and deliverability of sites. For employment land sites, the suitability of a site may well include good transportation links for goods and people. The Call for Sites consultation will assist in putting forward suggestions for sites.
5.24 In terms of exporting employment land, it is considered that a proportionate amount of employment land to housing land exported should be made in an attempt to create more sustainable communities, that is unless there is good reason not to do so (i.e. due to improved public transport links between exported housing and employment sites). As evidenced in work supporting the Issues and Options Draft, whilst the Black Country is a sufficiently self-contained labour market there are strong linkages with Birmingham and South Staffordshire. This would therefore suggest that these locations should be first explored for transporting any employment land growth, however, given the land capacity issues in Birmingham it is more likely that South Staffordshire would be able to assist.
6. DELIVERING GROWTH - INFRASTRUCTURE & VIABILITY
Question 21: Do you think that changes are required to Policy DEL1 to ensure it covers both development within the existing urban area and any within the Green Belt? Yes/No; If yes, please provide details.
6.1 Policy DEL1 is considered to be sound on the basis that it is sufficiently flexible to deal with different circumstances on different sites across the Black Country, including sites that are to be removed from the Green Belt.
Question 22: Do you have evidence of a requirement for new social infrastructure to serve existing needs? Yes/No; If yes, please provide details of the type of facility and where it should be located.
6.2 We are in consultation with the relevant authorities to explore any requirements for social infrastructure to serve any need relating to the development proposals proposed at Home Farm, Sandhills.
Question 23: Do you have evidence of social infrastructure that is no longer needed and where the site could be reallocated for alternative uses? Yes/No; If yes, please provide details.
6.3 No comment.
Question 28: Do you think physical infrastructure is necessary to serve large new housing developments? Yes/No; If yes, what type and scale of physical infrastructure is necessary?
6.8 As set out above, the need for infrastructure will vary for each site. Given such different circumstances, it would be inappropriate and potentially unlawful (as it would conflict with paragraph 122 of the CIL Regulations) to incorporate a blanket policy requiring specific infrastructure on every large housing site.
Question 29: Do you think there are any other tools or interventions that could be used to ensure enough infrastructure is provided by developments? Yes/No; If yes, please provide details.
6.9 It is considered that the existing national framework (which includes the NPPF and CIL Regulations) provides a sufficient tool to ensure the relevant infrastructure is delivered. In addition, the CIL Charging Schedule allows authorities to raise funds for named infrastructure projects, which should be updated in line with the Core Strategy. Therefore, it is considered that there are existing provisions to deliver infrastructure and no additional interventions in the Black Country Core Strategy Review are needed.
Question 30: Do you have any suggestions around how the strategy can be developed in order to maintain the urban regeneration focus of the Black Country while at the same time bringing forward sites in the green belt? Yes/No; If yes, please provide details.
6.10 There is no a need for any specific interventions, such as phasing, to protect the delivery of urban regeneration in the Black Country. Indeed, it is considered that development of green field and Green Belt sites can very much compliment urban regeneration through the provision of a more varied form of development that will help diversify the housing stock and profile of residents in the wider area, which will assist to sustain and improve the vitality of existing communities. Further, as highlighted above, given the priority to significantly boost the delivery of housing green field and Green Belt sites should come forward for development as soon as practically possible. In light of the lead in and build out rates of larger sites, the land should be encouraged to be developed as soon as possible so to ensure the homes are delivered in the plan period and the needs are met.
Question 31: Do you think that the right scale and form of funding is available to support the delivery of the Core Strategy review? Yes/No; If no, what alternative sources of funding or delivery mechanisms should be investigated?
6.11 When delivering green field/ Green Belt sites, there is an opportunity to deliver infrastructure to meet the needs arising from the proposal, which may have wider benefits for the local community. In addition, it is likely that the communities created by the Sustainable Urban Extensions will potentially be more affluent and share their wealth using local shops and services within the wider Black Country, which will contribute to more successful and prosperous community.
7. REVIEW OF EXISTING CORE STRATEGY POLICIES & PROPOSALS
Housing
Question 35: Do you support the proposed approach to housing land supply? Yes/No; If no, please explain why
7.1 As identified above, it is important that a range of sites in different locations are identified to be in the best possible position of delivering the development requirements. In terms of presenting these sites in the Core Strategy, whilst it is useful to identify a housing trajectory, it is important that there is not a phasing policy as such that would prevent the delivery of housing, given the current housing crisis. As stated above, the delivery of housing on greenfield and Green Belt land will not compromise the delivery of urban regeneration as the development on the urban edge will complement and rejuvenate the environment in a different way.
7.2 In terms of the proposed level of discounting, it is considered that if the LPA adopt an approach to identify a further 20% of sites in accordance with the LPEG recommendations identified above, there would not necessarily be a need for the application of discounting in determining the overall level of supply. It is interesting to note that the level of discounting proposed by LPEG is suggested for all LPAs, not necessarily those which have experienced difficulty in delivery. It could therefore be argued that an increased buffer of 25% could be applied in order to take a cautious approach.
Question 36: Do you think that the current accessibility and density standards set out in Policy HOU2 and Table 8 should be changed? Yes/No; If yes, what standards should be applied instead, for example should the minimum net density of 35 dwellings per hectare be increased to maximise brownfield housing delivery?
7.3 It is clear that the current accessibility and density standards outlined in the adopted Core Strategy were formulated in the context of the vast majority of development taking place on brownfield sites within the defined urban area. As reiterated throughout these representations, there is now a clear need for Green Belt release as part of the Local Plan Review to meet emerging, objectively assessed housing needs. We outline in further detail below why the adopted accessibility and densities would not be applicable to Green Belt sites, however would suggest that the current standards do not allow sufficient flexibility on brownfield sites. A blanket application of prescriptive accessibility and density standards across the Black Country, be it brownfield or greenfield, does not allow sufficient flexibility which take into account site specific characteristics. The Council should allow for greater flexibility when assessing accessibility and density standards, with a more pragmatic approach which allows appropriate assessment for site-specific characteristics and also an assessment of market demand which may vary significantly across the large Black Country area.
7.4 Paragraph 47 of the NPPF outlines how local authorities should set out their own approach towards density. It is suggested that the currently adopted approach does not allow for sufficient assessment of local characteristics. It is clear that the chosen approach must be reflective of local circumstances, including the matters outlined above as well as infrastructure and services available in the locality. It is advocated that a more flexible approach to density and accessibility standards is taken as part of the emerging Local Plan Review.
Question 37a: Do you think that the existing Policy HOU2 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why
7.5 In line with the comments above, it is suggested that the Council should assess each site on a case by case basis in terms of accessibility and density standards. This approach would suggest that the numerical baseline trigger of 15 homes or more will not always be appropriate or applicable, and as advocated throughout these representations it suggested that there should be a complete re-assessment on accessibility and density standards as part of the emerging Local Plan Review.
Question 38: Do you think that the current accessibility and density standards are appropriate for green belt release locations? Yes/No; If no, what standards should be applied in these locations and why?
7.6 No, it is not considered that the current standards would be applicable to Green Belt release locations. The adopted standards are overly prescriptive, and as previously discussed were written in the context of brownfield land. Green Belt release sites have a completely different type of character, therefore consideration of accessibility and density standards in relation to these sites should be reflective of local character and site characteristics. The more suburban settings of Green Belt release land lends itself to lower densities which are more appropriate to the Green Belt setting, which typically deliver more family homes. The Council must provide robust evidence to test any forthcoming accessibility and density standards in relation to Green Belt release locations, which allows for a flexible and pragmatic approach.
Question 39: Do you think separate accessibility standards are needed for particular types of housing e.g. housing for the elderly or affordable housing (as occupiers may be less mobile and more dependent on public transport)? Yes/No; If yes, please provide details.
7.7 It is clear that separate accessibility standards will apply to particular types of housing such as affordable and for the elderly population, however in line with the sentiment expressed above, any forthcoming standards should be based on robust evidence and allow for sufficient flexibility to avoid any unnecessary constraints to development coming forward.
Question 40: Do you agree that the 2017 SHMA findings should be used to set general house type targets for the Plan period? Yes/No; If no, please explain why.
7.8 A general and blanket application for house types across the Black Country should not be advanced as part of the Local Plan Review. Paragraph 50 is clear that local planning authorities should plan for a mix of housing based on current and future demographic trends and market trends. It is therefore notable that the NPPF specifically highlights 'market trends' in this context, which acknowledges that the market must inform such decisions.
7.9 Whilst the 2017 SHMA does provide an assessment of demographic and market trends, it is notable that it looks at a wider area assessment and is focused at a higher level. This assessment therefore does not draw out sub-market trends, and cover smaller areas within the vast Black Country area. Again, a blanket policy of house type targets across the Black Country area would not allow for sufficient flexibility to assess each site on a site by site basis, taking into consideration local market trends and demand. The NPPF does not state that specific policies should be set to enforce that local demand is met. As such, it is considered that this should be left for the market to decide, as opposed to applying rigid and prescriptive house size standards.
7.10 It is suggested that the evidence presented in the SHMA should be put into the Plan as an informative and general guide, but should not feed into a specific policy requirement which outlines housing mix percentages that should be applied across the Black Country. A policy containing general house type targets could present as a significant constraint to the delivery of a site where there is no local market demand for this house type, which in turn would have a negative impact on achieving the necessary housing growth targets to be delivered in the Black Country over the Plan period.
Question 41a: Do you support the introduction of a policy approach towards self and custom build housing in the Core Strategy? Yes/No; If yes, would you support:
7.11 It is not considered that there is a policy need for the Core Strategy to address self and custom build housing in the emerging Review. Paragraph 6.32 indicates that there are only nine records on self and custom build registers in the Black Country. It is evident that that there is very limited demand in the Black Country, which is unsurprising given that self and custom build housing is often more popular in rural areas. Given the limited demand it is therefore not considered necessary to take a policy approach towards self and custom build housing within the Local Plan Review.
Question 41b: A target for each authority? Yes/No; Any further comments
7.12 Given that there is evidence of little market demand, it is not considered necessary for the Core Strategy to set targets for each of the Black Country authorities. If it was considered to be necessary as the Local Plan Review progresses, any targets being set should be formulated on the basis of robust evidence such as monitoring of the registers, to provide an indication of how many self-build homes will be needed.
Question 41c: A requirement for large housing sites to provide serviced plots? Yes/No; Any further comments?
7.13 There should not be a requirement for large housing sites to provide serviced plots. This can pose an unnecessary market constraint for large housebuilders when there may be limited or no market demand for self-build plots. Self and custom build plots are often unusual and unique in character, therefore would not be best suited to be located within a large housing development with more uniform house types. If deemed necessary, self and custom build housing should be allocated specific site allocations, as discussed below.
Question 41d: Another approach altogether? Yes/No; If yes, please specify.
7.14 If it is considered necessary for the Review to address self and custom build housing, this should be addressed by the Council's identifying and allocating specific plots for these uses. Identifying site-specific plots would ensure that the most appropriate and suitable locations for self and custom-build will be allocated, via the assessment of appropriate evidence and market demand. In addition, this might be more likely to be achieved on surplus publicly owned land.
Question 42: Do you agree that the annual affordable homes target should be increased to reflect the 2017 Black Country Strategic Housing Market Assessment? Yes/No; If no, please explain why.
7.15 As a general principle, the notion of applying different affordable housing ratios to different parts of the Black Country, based on an understanding of needs and viability, is acceptable. Given that the Black Country represents a vast area, there will not be a uniform housing market, and there will be sub-market trends within this wider area. As such, a more flexible approach which assesses local housing market evidence on a case by case basis could be justified. That said, there is an inherent simplicity and attraction to a single rate figure, which is easy for the development industry to understand.
7.16 In terms of the annual affordable housing target, it is unclear how the Issues and Options document has calculated the figure of 832 homes per year. At paragraph 7.42 of the June 2017 SHMA Part Two- affordable housing document, it is stated that the total annual affordable housing need is 677 dwellings, which represents 19.8% of the annual projected household growth. This differs to paragraph 6.36 of the Issues and Options document, which states that the affordable housing target is 23.4% of total housing need or 832 homes per year. From paragraph 7.47 of the SHMA, it appears that this figure may have been calculated by adding the overall requirement of 16.6% of housing to be affordable rented and 6.7% shared ownership. Clarity is sought on how this figure has been calculated, and we reserve the right to comment further on this matter.
Question 43a: Do you think that the existing Policy HOU3 site size threshold should be kept at 15 homes or more? Yes/No; If no, please explain why.
7.17 We have not undertaken detailed analysis of the findings and assumptions of the SHMA and affordable housing delivery matters, therefore would like to reserve the right to comment on this matter further. However, on face value, it appears to be a reasonable threshold and is not dissimilar to other locations.
Question 44a: Do you think that the affordable housing requirement for eligible sites in Question 43 should be kept at 25% of the total number of homes on the site? Yes /No; Any further comments?
7.18 Based on the current evidence, a blanket rate of 25% affordable housing would appear to be sound.
7.19 However, irrespective of the final rate, any amendments to the currently adopted affordable housing policy must continue to have a clause in it which stipulates that this requirement is subject to viability tests. Any revised affordable housing requirements will also need to carefully consider the implications of adopted Community Infrastructure Levy (CIL) regimes. Both Sandwell and Dudley Councils have adopted CIL Charging Schedules. These will have implications on viability, therefore if revised affordable housing targets are to progressed then these CIL tariffs will need to re-assessed and re-visited.
Question 44b: If no, should the percentage be increased to allow for the provision of affordable home ownership? Yes/No; If yes, what should the percentage be and why?
7.20 At paragraph 6.39 of the Issues and Options Paper, it is stated that options need to be explored to increase affordable housing delivery of private sites. One option would be to increase the overall affordable housing proportion, which would require developers to provide affordable home ownership products plus an appropriate proportion of other affordable tenures. This paragraph follows on from commentary relating to the Housing White Paper.
7.21 The Housing White Paper discusses Starter Homes at Chapter 4, and explains how the government intend to amend the NPPF to introduce a clear policy expectation that housing sites deliver a minimum of 10% affordable home ownership units. It is later stated that it will be for local areas to work with developers to agree an appropriate level of delivery of starter homes, alongside other affordable home ownership and rented tenures.
7.22 The policy position on Starter Homes is not yet fully clear, and has yet to be formally established through a formal amendment and update to the NPPF. Until the national policy position on Starter Homes has been made clear, it would be premature for the Core Strategy Review to suggest an uplift in the affordable housing requirement to include affordable home ownership such as Starter Homes. Any suggestion to uplift the affordable housing requirement to include Starter
Homes should be reflective of the national policy position, as well as founded upon a robust evident base which dictates exactly what percentage this element should be of the overall affordable housing requirement.
Question 45: Should an increased affordable housing requirement be set for green belt release sites, to reflect the likely financial viability of these sites? Yes/No; If yes, what should this be.
7.23 The likely financial viability of Green Belt sites will vary across different areas of the Black Country, therefore any affordable housing requirements for Green Belt sites will need to be reflective of these circumstances. Any affordable housing targets for Green Belt sites should be based on robust evidence, and acknowledge that many sites may need to support and deliver other infrastructure requirements.
7.24 Ultimately, any affordable housing strategy will need to address the affordable housing need as well as the need for market housing. Bearing in mind that the SHMA confirms over 70% of homes required are for homes to be sold on the open market, any affordable housing policy must not dilute the delivery of these needs/requirements. A higher figure on Green Belt sites over and above a standard blanket figure would potentially do this.
Employment
Question 49a: Is there still a need for existing Policy DEL2 in order to manage the release of poorer quality employment land for housing? Yes/No; If no, please explain why.
7.25 The Black Country is to be the subject of large levels of both employment and housing growth over the Plan Period. These uses are very much inter-linked with one another, and will drive each other's need for growth. The Local Plan Review, in order to meet emerging employment and housing needs, must identify a significant number of specific sites for employment and housing uses. By planning proactively and identifying suitable sites for both employment land and housing land, this should reduce the pressures to manage the release of poorer quality employment land, which may not always be suitable for release. The Local Plan Review should also seek to undertake a further review of poorer quality employment land to make it available for other suitable uses, if it proves to no longer be viable for employment land use. This is in line with policy provisions of the NPPF, which at Paragraph 22 outlines that planning policies should avoid the long-term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.
Question 50: Do you think that the Core Strategy should continue to set a target for the total employment land stock in Policy EMP1? Yes/No; Please explain why.
7.26 The continuation of setting a target for employment land stock would be supported. Policy EMP1 should make it clear that these are not maximum figures, to encourage further flexibility for additional growth.
Retail
Question 61: In addition to para 4.33 of the current Core Strategy should the revised Core Strategy include criteria for the creation of new centres that might be needed as a result of any additional housing identified through the plan? Yes/No; Any further comments?
7.28 Criteria would be a useful policy tool to help assess the designation of new centres, and should be in line with previous methodologies used which set out clear thresholds.
Question 71: Should the Core Strategy set housing targets for the Town Centres?
7.29 Housing within Town Centres should be supported, in line with paragraph 23 of the NPPF which discusses the important role that residential development can play in ensuring the vitality of Town Centres. Any housing targets should be based on what sites are known to be readily available, suitable and viable for residential development. Market demand for housing in these areas will also need to be fully assessed. It is notable from the outcome of the 2017 SHMA that there is most demand for three bedroom properties (40%). The highest demand is therefore for family housing, and not for flats which are often the most popular within Town Centre locations. Any housing targets set for the Town Centre would therefore need to consider the findings of the SHMA, and be reflective of the fact that family housing is often more suitable for delivery on larger sites, including on sites which are currently located within the Green Belt.
Environment
Question 99a: Do you think that national standards for housing development on water consumption should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.30 When referring to water consumption paragraph 6.1.52 of the Issues and Options document states that the Black Country does not currently lie in an area of serious water stress, therefore clear need may be difficult to demonstrate. This evidence suggests that there is limited or no need to introduce such a policy, therefore it is not considered that the Core Strategy Review should seek to introduce water consumption standards for housing development.
Question 99b: Do you think that national access standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.31 The introduction of any national access standards, with the Issues and Options document referring specifically to Lifetime Homes, again must be based on a robust evidence base which can demonstrate market demand. It is noted that Paragraph 50 of the NPPF states that planning authorities must plan for a mix of housing to meet a range of needs. In the same paragraph, it is later stated that these must be based on current and future market trends. If Lifetime Home standards are to be introduced these will therefore need to be based on robust evidence, to ensure that the standards are not overly onerous and prevent the delivery of other types of housing which have higher levels of market demand.
Question 99c: Do you think that national space standards for housing development should be introduced in the Black Country? Yes/No; If yes, please specify what level and percentage would be appropriate and why.
7.32 As reiterated throughout these representations, it is not considered that a blanket approach of prescriptive standards across the Black Country allows sufficient flexibility to assess local market and site considerations in an appropriate manner. Whilst it is recognised that space standards can be an important tool to ensure that high quality of homes are delivered, we agree with the sentiment expressed in the recent Housing White Paper. The Paper explains that the government are concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households. The White Paper also states that the Government will be undertaking a review of the Nationally Described Space Standards. It is suggested that the Core Strategy Review should await the outcome of this national review of national space standards, to ensure compliance with national policy and to ensure that the most appropriate approach to space standards, if required, is taken.
Question 99d: Do you think that the standards should be different for brownfield and greenfield sites? Yes/No; If yes, please explain how and why.
7.33 As discussed above, prescriptive standards do not always allow sufficient flexibility for local market needs, so we would not advocate a blanket approach of different standards to brownfield and greenfield sites.
Open Space, Sport and Recreation
Question 102a: Do you support the proposed changes relating to open space, sport and recreation? Yes/No; If no, please explain
7.34 Paragraph 6.1.60 of the Issues and Options paper outlines how adopted Policy ENV6 creates the framework for open space policies at the local level. The Issues and Options paper outlines how this is in line with national guidance, and that it is proposed to retain this policy and update some references in the supporting text to reflect changing circumstances. It is agreed that the local level remains the appropriate place to set open space policies, and that Policy ENV6 should continue to endorse this approach.

r!

r 1

r 1







( )








I I
ll
l I
l I
l I



2. Landscape and Visual Context


2.1 Introduction


2.1.1 Pegasus Design has undertaken a preliminary appraisalof the landscape and visual constraints and opportunities for the land at Home Farm, Sandhills Site. A summary of this landscape and visual work is provided below.

2.2 Site Context and Description


2.2.1 The site is located on the eastern edge of Brownhills. Open countryside extends to the north and east, which is also designated Green Belt. It is generally characterised by large arable field enclosures , but also populated by a number of elements of built form, and in particular major highways infrastructure including the M6 Toll and the A5. Chasetown lies further to the north. To the south lies further development , typically residential, extending down towards A ldridge. To the east is the urban area of Brownhills, including the Wyrley and Essington Canal.

2.2.2 The site itself also lies within Green Belt land and forms part of land covered by the Forest of Mercia community forest. Within the wider landscape there is an area of open access land to the south at Shire Oak Hill and to the north at Brownhills Common. Public rights of way are limited in the local landscape, although there is a tow path along the eastern edge of the canal.


2.3 Site Description


2.3.1 The site is irregular in plan form and comprises approximately 12 no. field enclosures of different sizes. It is defined to the north-west by the canal, including a mature hedgerow with the occasional tree; and to the south-west by the rear garden curtilages of residential properties on the eastern side of the A452 Chester Road. It is defined to the south-east by the A461 Lichfield Road (A461), which includes a number of private properties fronting on to it. This boundary is also characterised by some mature vegetation infrastructure along its length, including a small woodland copse. It is defined to the north-east by a number of elements including farm tracks, a water course and topographical change. The district boundary between Walsall Council and Lichfield District Council, which is coincidental with this boundary, follows a track that extends across the north-eastern section of the site.

2.3.2 There are two building groupings on site, both in close proximity to the A461 Lichfield Road. To the north is Sandhills Farm, including a number of small brick buildings and some large agriculturalsheds. Access to it is from Lichfield Road. Slightly further south is Home Farm, including the red brick Farmhouse itself, with other associated farm buildings behind. Access to it is from the Lichfield Road,


and the access track extends past Home Farm to a series of other buildings, in private residential use. A farm track links these two groups of buildings. No elements of the built form are listed.

2.3.3 In terms of topography, the site is located on an area of gently sloping agricultural land between approximately +170m AOD at the junction of the Chester Road and Lichfield Road, to approximately
+140m AOD beyond the district boundary of Walsall. Beyond this, the landform rises to approximately
+150m AOD to the north.

2.3.4 Land on site is currently in arable production, with the exception of two small field enclosures at the eastern end off Barracks Lane that remain in pasture. The field enclosures vary in size and shape. On the southern, eastern and northern parts, the enclosures are generally small to medium sized and rectangular; in the central part of the site and extending west of the canal, there is a much larger, irregularly shaped enclosure that occupies the lowest lying land.

2.3.5 Vegetation is generally confined to the southern and eastern parts of the site. This includes a triangular shaped woodland copse just west of the private buildings behind Home Farm; a treed hedgerow just south of Home Farm; and a mature woodland copse j ust south of Home Farm on the Lichfield Road frontage . Both the access tracks to Home Farm and Sandhills Farm are tree lined, and the track that links the two buildings groupings is also tree lined. There is also some vegetation associated with the back gardens of properties fronting Chester Road on the south-western site boundary.

2.3.6 The site is currently included as part of the West Midlands Green Belt. There are no landscape specific designations which cover the site or the immediate area. A site location and planning designations plan is contained at the end of this Chapter, which provides further details.

2.4 Landscape Character


2.4.1 In terms of national landscape character, the site is located within National Character Area Profile 67: Cannock Chase and Cank Wood, as published by Natural England (2012). At a more local level, Walsall Council does not have a published landscape/townscape character assessment. The site is located at the boundary of Walsall and Lichfield District and displays many similarities to the Sandstone Estatelands: Farmland Landscape Character Type/Subtype of the Staffordshire Landscape Character Assessment, 'Planning for Landscape Change' Supplementary Planning Guidance (2001).

2.5 Views and Visual Receptors

2.5.1 Several representative viewpoint photographs from local visual receptors have been taken from the surrounding landscape. The location of these is shown on Figure 2.1 on the following page. The photographs taken from these viewpoints are contained at the end of this Chapter.




Figure 2.1- Viewpoint Photographs








'*
'
Spr111eh 1ff ,;)' * ' *

\ -lo
























2.5 .2 The following section describes the visual relationship between the site and the surrounding landscape in relation to the inter-visibility of the area and the nature and extent of potential views. In visual terms the site and its context are relatively well contained with views towards it generally being of short distance. Whilst inter-visibility across the site is possible, it is well contained by the surrounding built form and topography .

2.5.3 From the north, the visual envelope of the site is limited by local undulations in landform combined with adjacent built form along the B4155, Lichfield Road and Barracks Lane. From areas to the east, the visual envelope is contained by Barracks Lane and the localised ridgeline that lies between Whitacre Lane and Cartersfield Lane. From the south rising landform and existing properties along the A461 (Lichfield Road) and along Chester Road (which line the south-western site boundary) limit views across the site. From the west, the existing settlement area of Brownhills lies immediately adjacent to the Wyrley and Essington Canal which follows the north-western site boundary and serves to limit views of the site from beyond those available immediately adjacent to it.

2.5.4 From the north, there are views available from Barracks Lane however these are limited by boundary vegetation and topography. Views from the east are both public and private and look across the site from the A461 Lichfield Road, from where the Home Farm and Sandhills Farm buildings are visible, together with their tree lined access tracks. In these views, the combination of farm buildings and mature trees is characteristic,with more extensive views looking northwards beyond the site across


open countryside. Views from the southern end of Barracks Lane are more limited as the agricultural sheds within the Sandhills Farm complex serve to screen views in combination with rising topography. However, there are views from the central parts of Barracks Lane, with the urban edge of Brownhills in the background.

2.5.5 From the north-east, the site is not visible from where the A5 and M6 toll roads cross over at the Boat Lane junction. This is mainly due to the rising topography and existing vegetation in the direction of Brownhills to the south. Views from the Muckley Corner area are similarly limited.

2.5.6 From the south, there are both public and private views from Lichfield Road looking into the southern part of the site, and further across it to the north with more elevated countryside in the distance including the south-east fringes of Cannock Chase. There will also be private views from the residencies backing on to the site from Chester Road. From the west, there are views looking across the site from the path alongside the Canal, notably where the localised elevation of this path rises and where the hedgerow is absent. In these views, the central parts of the site can be seen, with the urban edge of Brownhills on rising land beyond, characterised in part by mature vegetation.

2.5.7 Overall, views towards the site are limited to a number of localised visual receptors that include residential receptors at the existing settlement edge of Brownhills, users of the canal tow path, and users of the local road network.


2.6 Landscape and Visual Analysis


2.6.1 The contextual landscape and visual analysis can be summarised as follows:

* The context comprises a functional landscape , generally consistent with local landscape character studies, however heavily influenced by urban areas and elements of built form, notably major highways infrastructure;

* The local landscape character is also degraded in part, primarily showing the effects of the removal of hedgerows following intensification of arable farming practices;

* It well visually contained to the north and west by built form. The only exception to this are the views form the towpath along the canal which runs along the western site boundary; and

* In contrast, the site is more visually open to the south and east although many of these views are limited to short and mid distance views, typically influenced by the urban edge;

2.6.2 The site landscape and visual analysis can be summarised as follows :

* The site topography is such that it forms a localised 'topographical bowl' in its central and northern parts, formed by rising topography both to the north and south;



* This 'bowl' is more visually contained in the wider landscape;

* The southern part of the site adjacent to Brownhills gives the perception of being more enclosed, notwithstanding its higher elevation, primarily due to the vegetation structure on and adjacent to it;

* The central and northern parts of the site contrast with this, and retain a distinct lack of vegetation infrastructure;

* The triangular copse, in combination with the Home Farm buildings complex serve to define a 'threshold' between the differing characters of the south and central/northern parts of the site;

* The Farm buildings complexes, in combination with mature tree planting, generate a pleasant visual composition when viewed from the A461 Lichfield Road corridor; and

* The Wyrley and Essington Canal corridor retains pleasant amenity value and good visual connectivity with the site where the adjacent hedgerow is absent and does not channel views along the corridor.

2.6.3 A contextual Landscape and Visual Analysis drawing is contained at the end of this Chapter.


2.7 Impact on the Green Belt

2.7.1 The site is located in part of the Green Belt that extends between Lichfield to the north-east, with Burntwood, Brownhills and Aldridge to the south-west forming a more or less continuous ribbon of development extending south towards Walsall. It is also bisected by the M6 Toll; the A5; the A5190 and the A461 ; and includes the Villages of Shenstone, Wall and Hammerwich together with numerous elements of 'ribbon' development along highways routes.
2.7.2 Extending across and around these elements, the majority of the landscape is in arable production and is very gently undulating. The land is not covered by any other form of amenity planning designation. Openness therefore in this instance comprises combinations of this agricultural landscape populated quite consistently with development in terms of both highways infrastructure and built form to a greater or lesser degree. Various combinations of these elements will vary in views across the Green Belt.
2.7.3 In accordance with the NPPF, Green Belt boundaries should be defined clearly, using physical features that are readily recognised and likely to be permanent. It is considered that the north-eastern and south-eastern boundaries of the site, in combination with the existing triangular woodland and proposed woodland belts this could form a clearly defined Green Belt boundary by the nature of them being defined by mature vegetation . The landscape and green infrastructure strategy for the site also proposes new planting throughout the site area.._--af!G-particularly along the south-eastern boundary where there is an interface with the existing ribbon development along the A461 Lichfield Road. These



mitigation measure will help to establish and enhance a robust landscaped edge to the proposed development and provide a definitive new Green Belt boundary.

2.7.4 Table 2 on the following page sets out a summary of the likely impacts on Green Belt purpose, in landscape and visual terms, using the five purposes set out by the NPPF.



Table 2: Summary of LikelyImpacts on Green Belt Purpose - Green Belt Review Criteria



NPPF Purposes of the Green Belt Summary






To check the unrestricted sprawl of large built-up areas.
The site is located on the eastern edge of the settlement of 8rownhills. An area of which extends as ribbon development a long the A461 Lichfield Road, running in parallel with the majority of the south-eastern boundary. There are a number of built elements already existing within the site and these combine with an area of triangular woodla nd copse to contribute to the definition of the boundary of 8rownhills, and serve to contain it both physically and visua lly. Development of the site will not lead to unrestricted sprawl of the built-up area as it will be contained within this framewo rk. The extent of development will not project built form further into the countryside as it sits directly adjacent to the existing settlement edge and includes new landscape infrastructure planting along its boundaries. The proposals outline the intention to provide strong green infrastructure along the eastern boundaries of the development envelope that will provide a
closed edge to the development that extends no further east than the existing settlement along the A461 (Lichfield Road) to the south-east and along the 85011 and the 84155 to the north and north-east. The development will also serve to rationa lise in part the existing ribbon development along the A416, Lichfield Road, to better incorporate it into the settlement pattern of 8rownhills.



To prevent neighbouring towns merging into one another.
The closest settlement to the eastern edge of 8rownhills is the small v illage of Stonna ll, located ca. 1.2km to the south-east of the site. The ribbon development along the A461 Lichfield Road,
lies closer to the village of Stonnall that the proposed development . The next closest settlement is the village of Shenstone that lies ca. 4.45km to the east. Development of the site will represent a relatively small scale extension on the eastern edge of 8rownhills which will not extend further east than the existing settlement pattern. Overall, development of the site will not lead to coalescence ('merging') of neighbouring settlements.




To assist in safeguarding the countryside from encroachment .
Development of the site will result in a small loss of open land in the context of the edge of 8rownhills. However, the majority of the existing vegetation will be retained, and together with a robust green infrastructure strategy, development can be located within a comprehensive
la ndscape setting which wou ld be located along, and consistent with, the ex isting settlement edge. Furthermore, development of the site will not extend the existing settlement edge further east than the alignment of the settlement pattern created by the A461 (Lichfield Road) to the south-east and along the 85011 and the 84155 to the north and north-east. The site has already been encroached upon by built development, including large scale agricultural buildings and




individual residential properties. There is no public access on site, nor is there any evidence to suggest informal use of the site for recreation.



To preserve the setting and special character of historic towns.
There are no conservatio n areas w ithin the study area and the closest scheduled monument is the fort located in Shire Oak Park Nature Reserve, ca . .4km to the south. The park and fort form a loca l hill characterised by wood la nd that prevents any visual relationship between it and the site.
As such, the appropriate design of development on the site is unlikely to cause undue effect to any historic features within or surrounding the town.



To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
The site is influenced by a number of urbanising features such as the settlement edge of
Brownhills; a number of major transport routes and their associated infrastructure, including the M6 Toll road,A461Lichfield Road and the AS; and existing built form on site.
It is considered that all areas of Green Belt by their nature and designation should contribute to the recycling of derelict and urban land as Green Belt is generally a prohibitive designation where development is rarely acceptable, thus development is focused into urban areas.



























2.8 Landscape and Visually Led Development Process


2.8.1 With respect to development proposals on site, a landscape and visually led process has been adopted in order to identify the initial parameters for development. This includes the formulation of a comprehensive Green Infrastructure (GI) strategy and the identificat ion of a Development Envelope, the details of which are outlined below.

Development Envelope

2.8.2 The initial landscape and visual analysis has identified areas which retain good capacity for development. It essentially comprises two overall parts. The highways analysis has identified two points of access: a primary one from the A461 ; linking to a secondary access off the Chester Road. These will serve the first part of the development envelope which extends across the south-western part of the site. Although the land is slightly elevated in this location, it remains quite well enclosed and relates well to the existing urban edge. This part of the envelope is again broken down into two parcels, with a significant area of open space between them, which may function in part as primary school/community use, and will offer long distance views northwards.

Green Infrastruc ture (GI) strategy

2.8.3 The development envelope has been identified integrally with a comprehensive GI strategy. Creation of a robust green infrastructure (GI) network across the site is a key component of the proposed development and will not only provide landscape and visual mitigation, but will also enhance the landscape resource and add value to it.

2.8.4 The analysis identified the general lack of GI across the site and it is considered important to build on the existing elements of vegetation and consider more opportunities in terms of access and permeability, as well as the recreational and biodiversity benefits that extend form this.

2.8.5 The green infrastructure strategy will be robust, including links to existing and proposed vegetation belts, and will include the following:

* Creation of a comprehensive open space hierarchy, including a linear park along the canal, and a series of three large linked linear open spaces between the development parcels;

* Retention of all the vegetation across the site, in particular that along the A461 Lichfield Road frontage, with supplementary planting where necessary;

* Creation of a series of new, linked woodland belts which are consistent in character with the existing ones on site and in the local area. These include:

- The A461 frontage, south of Home Farm, to reinforce the visualenclosure in this area;



- Supplementary planting adjacent to the retained triangular copes to extend a green link down towards the secondary site access on Chester Road;

- Along the eastern edge of the northern section of the development envelope, behind Home Farm, for both visual containment and to enhance the setting and amen ity of the Farm;

- Along the north-eastern edge of the southern section of the development envelope, again for visual containments and setting and amenity value; and

- To the north of the northern edge of the northern section of the development envelope, up to circa, 10 metres in width, that will provide a robust and well defined edge to the Green Belt.

* Safe and easy public access through the series of newly created spaces;

* Provision of open spaces with drainage features in appropriate locations, including the north­ eastern corner of the site; and

* Creation of a natural parkland landscape design in the open space that will be created along the canalfrontage.

2.8.6 The introduction of woodland belts along the eastern edge of the development envelope, combined with the remaining agricultural parcels around existing built form and localised undulation in topography will serve to continue views of open space when approaching Sandhills along the A461 Lichfield Road and filter views of the proposed development.

2.8.7 The proposed, indicative Green Infrastructure Strategy is shown on a Plan contained at the end of this Chapter.

KEY
[Z] Site boundary
EJ LPA boundary*
Urban Open Space (LC1)*

D Green belt**
SSSI..


Ancient Woodland**

[]Scheduled Monuments**
D CROW land **
Country parks **


Forest of Mercia ***



Sources:
* Walsall Council UDP (2005)
** www. magic.gov.uk
*** www.forestry.gov .uk

















Home Farm, Sandhills, Walsall
Fig. 1 Site Location and Planning Designations







PLANNING IDESIGN IENVIRONMENT IECONOMICS
Copyright Pegas.us Planning Group Ltd. Crown copyright,Al oghts reserved. 2015. Ordnance Survey Copyright Lpnce number 100042093. Promap LIC8nce number 100020449 and X.XXXXXXX.X .
Pegasus accepts noilablity for any use of this document other thanfor its originalpurpose, or by the original client,or following Pegasus'ex.press agreement to such use. T 01285641717 www.pegasuspg..co.u









lkm

Drawing Ref: BIR.4327 06 Client : Gallagher Estates
Date : 09/03/2017
Drawn by : LG Pegasus
Checked by : KM Design .
Scale : 1:25000 @ A3 ....-'

------------------------------------------------------------------------------------------------------------------------------------------------A-p--p-r-o-x--im--a--te---e-x-t-e-n--t-o-f- s-i-te------------------------------------- --------------------------------------------------------------------------------------------...

North-east boundary North-west boundary Sandhills Farm Propert ies on
Lichfield Road

Home Farm




Nor th-west boundary H F Property on Barracks ome arm
Lane


North-west boundary Properties on
Chester Road






















Viewpoint 2 View f rom north-western boundary looking east Camera type Nikon D3300 with 50mm lens Iequivalent focal length)
Date 9th March 2017
Approx grid ref SK 05405 04975
Approx elevation + 146m AOD Distance to site c.2m
PLANNING I IENVIRONMENT IECONOMICS
Copyrtght Pequu5> Aarming Group ltd. CtoNnCoVftighl. All rights reserved. 2015.Ontnoc* SurvtY Copynght l.Jcence nu 100042093. Promap Licence number 100020449 Peguosaccepts not111b111ty for ny u ot this document other thanfor its ori91nalpurpose. or by the ongmalchen1, or f0Uow1n9 Pegasus* ex.press aqrutnenlto such use. T 0128564 1717 www.pegasuspg.co.uk

Home Farm, Sandhills, Brownhills
Fig. 3: Viewpoint Photographs
Drawing Ref: BIR.4327 07A Client: Gallagher Estates
Date : 24/08/ 17 Pegasus
Drawn by : LWE/LG/CW Env1ronmert .
Checked by : KM


----------------------------------------------------------------------------------------------------------------------------------------A--p-p-r-o-x--i-m-a--te---e-x-t-e-n--t -o-f--s-i-t-e------------------------------------------------------ ----------------------.------------------------- -----------------------------------.
Properties on Paterson Place Lichfield Road





















Viewpoint 3 View f rom Lichfield Road. looking west
Camera type Nikon D3300 with 50mm lens !equivalent focal length) Date 91h March 2017
Approx grid ref SK 05686 04350
Approx elevation +161m AOD
Distance to site c. 21m
--------------------------------------------------------.---------------------------------------------- ---------------------------------A--p-p-r-o-x--im---a-t-e--e-x-te-n--t-o-f--s-i-t-e -----------------------------------------------------------------------------.----------------------------------------------------------*
- .
Properties on Home Farm Properties on Sandhills Farm Lichfield Road Property on Barracks Chester Road Catshill Road La ne








)














Viewpoint 4 View from Lichfield Road. looking wesl


Home Fa rm, Sand hi lls,

Camera type
Date

Nikon D3300 wilh 50mm lens !equivalent f ocal length!
91h March 2017

Brown h ills
Fig. 3: Viewpo i nt Photog ra phs

Approx grid ref SK 06347 04846
Approx elevation +130m AOD
Distance to site c. 20m

Drawing Ref : BI R.4327 07A Client: Gallagh er Estates
Date : 24/08/ 17 Pegasus

PLANNING I

IENVIRONMENT IECONOMICS

Drawn by : LW E/LG/CW Environm enl .
Checked by : KM --'

Copyn9ht Ptguus Planning Group Ltd. CroNn copy right. All ri9hts reseNed, 201S. Ordnance Survty Copyright l.Jc ttice number 100042093. Promap licence number 100020449 Peg asus acceptsno b1t11y lo.- any use of thisdocumtnl other then for rts ong1nal purpose, or trf the Ofl9H'I M dtent. or tollowmg Pegasus*express agreement to such us.. T 01285641717 www.ptgasuspg.to.uk

*--_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ * _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ £1?!?.i_f!!_'! i:_i: !_n_ ?!_ li:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ *_ _ _ _ _ _ _ _ _ _ _ _ _ *_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _


Sandhills Farm Home Farm Properties on Chester Road

Tower block on Lindon Drive

Properties on Catshill Barracks Lane
Road and Sadler Road


















\









Residential area off Castle Road and Catshill Road
1._ _ _ _ _ _ _ _ _ .P-l?!?_ i_r:i_'!i:.i:!.!!sit li:-_ _ _ _ _
..
.
'

"'"_1,*r-- "'Jil1i
















Viewpoint 6 View from Greenwood Road, looking north
Camera type Nikon 03300 with 50mm lens Iequivalent local length I


Home Farm, Sandhills, Brownhills

Dale

9th March 2017

Fig. 3: Viewpo int Photographs

Approx grid ref SK 05818 02761
Approx elevation +170m AOD

Drawing Ref : BIR.4327 07A C lient: Gallagher Estates

Distance to site
PLANNING I

c. 1.Skm
IENVIRONMENT IECONOMICS

Date : 24/08/17 Pegasus
Drawn by : LWE/ LG/CW Environment .
Checked by : KM _--'

Copynghl Pegasus P\anning Group Ltd. CroHO c:opyrhl. All rights reserved. 2015. Ordnance SYrte, Copynght licence number- HX:Xl420V3. Promap Ucence number 10002040 Pega!.Vs <tct!'pls no l1ab1l11y lor*ny use ol th1s document other than for rtsong1 nal purpose. or by tht onginal cl..nt. ortottow.ng re98sus* upr1!$S tgrHmtnt 10 !tuch use.. 1012856& 1711 www. isuspg.co.u

Approximate extent of site









\.






















PLANNIN G I IENVIRONMENT IECONOMICS
Copyright Pasus PlannmQ Group ltd, Crt1ovn toptnght, Alt rights reserved.2015.Ordnance Sur'1eyCopynght Licence number 100042093. Prorn;ap Licence number 100020449 Pegas atupts no liab1l11y tor any use ol t his document other than for its tmgrnalpurpose. or bythe onq1nal client, or t0Uow1 Pegasus' expre-ss agreemeni 10 such us.. T 01285641117 www.pegsuspg..co.uk

Home Farm, Sandhills, Brownhills
Fig. 3: Viewpoint Photographs
Drawing Ref : BIR.4327 07A Client: Gallagher Estates
Date : 24/0B/17 Pegasus
Drawn by : LWE/LG/CW Environment .
Checked by : KM




AOO

Section AA Seal* 1:2000@!'0












32 *..

-*



140m
!.<:'On
/\00
Section BB Salle *:2!JOOGAO

155m 150m





\..






3 '::: Li:iicG:ih>ifiie&i1.d..;i ieij::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::=
'"°' hern-stttdy-&ree-bounda





Section Locations Scale 1:100CJ@AO

won
'

rni"tn '"

, ,"Q" and ton


;, ""!
, ....... --1 -1- 11- t-;- -lr--t ;- ;--
,.,,,;:::::::=t::::tt:::::::::::::::::::::::::::::i::::::::::::::::::::::::::::::'.:J=::t==t===================================================== :::::':::: ::::::::=t=::+::

ILCm--
12Cn\
A:xl

I *A A* A*A A-& & A*A*- < A.A .


Section CC Salle 1 2000@AO


Notes
* Proposed andexisting bui ding heights shownat 9m to r dge.
* Proposed plantingshown at 8 to 10 m.
.Existing planting shown at 10 to 20m. Home Farm,Sandhills, Walsall
Fig. 6 Site ocation and
Planning Designations





t t UH"'gt.'"". ....,Jl(tJdl C'
*./ ....................* .l










Copp ce La
f r


KEY





Site boundary


Existing settlement area

----* -*
.i



...




i--a




'l>Crw ch Place Farm


Br :lg







M
B Existing vegetation
providing containment Public rights of way

Visually exposed edge of Brownhills


Localised Ridgeline


Sloping landform




*..
Crancbrook *****
Fa m *-..


07
:::

***

Existing farm buildings on-site
1. Home Farm
2. Sandhills Farm
Wyrley and Essington Canal


Local/short distance views across site





Sewa
W s









>elsail

34
\* Far-n /*** -*

**::::1: *
..*!'..::**

*
...
*,*.
*

. ..,
::
. r, Crea1:*
** .

\ N w B ns
'\*..
***








PLANNING I DESIGN IENVIRONMENT IECONOM ICS
Copynght Pegasus ptanning Group Ltd, Crown copyright,All rights reserved.2015. Ordnance Survey Copyright Licence number 100042093.Ptomap Licence number 100020449 andXX.XXXXXX.X .
Pegasus acceptS no iabrlityfor any use of this document other than for its ortginal purpose, or by the originalcllent.or fol1ow ng Pegasus'express agreement to such use. T 01285641717 www.pegasuspg.co.uk





Sand
P t



Co
Copp ce

\..**.,

Fig. 4 Contextua l Landscape and Visual Analysis

Drawing Ref: BIR.4327 06 Client : Gallagher Estates
Date : 15/03/2017
Drawn by : JT Pegasus Checked by : KM Design . Scale : 1:20000 @ A3 --'






AVE
w : \

_ _,,, ,..
_,.. Nursery * -

KEY
[ZJ



Site boundary

''!; >
0
15

ti *
!! !!I
-.....P;.v ,_;;;. O
. {]
Holland




Sports
* Ground

B c:.-tA.sE R.J::
' :Ii-
u

i!
Wks

* Park
\

Sch 151m
""'.p

2.Sandhills Farm


1. \



, , -* J
/ 'tG.RE:.A r Ckli.R L[$ STRJC. n-


153m







SPorts
Ground













Scrap Yd

D Proposed development cells
Retained and enhanced woodland with additional proposed
infrastructure planting

I c:rc::=::;z_ GREA T CHAHlf:.S s1A[n

School ' GYd


141m



The .o
Springhill .

l**I

Proposed green infrastructure
corridor network

p _,ef' Farm ..Springhill _ ....-**

Proposed key open spaces




---!
W;p>!'-"*v.c,
... . l .


; ..Sinks.
\
Whitacre
Farm




Issues








Rose
Cotlage

Potential location for play areas


Proposed main access




, 140m 120,,,

0 Potential secondary access

Existing Wyrley and Essington Canal towpath





129m Cartersfield Lane

BExisting contours

Farm















111


Proposed new green belt boundary


1*,,.I LPA boundary
[]Retained agricultural land


Track




Maybrook Industrial Estate



_,,.**

150m


Cac


Mauray Lodge

.park School *
(J


Home Farm, Sandhills, Walsall

,. *'

170m

*.
Fig 5. Green Infrastructure Strategy








PLANNING IDESIGN IENVIRONMENT IECONOMICS
Copynght Pegasus Planning Group Ltd. Crowncopyrighl,All rights rese!"od._ 2_015.Ordnance Susvey Cpyrigh Licence nun:ibef 100042093.Promap Licence number 100020449 andXXX.X.XX.XX.X .
Pegasus accepts no liability for any use of this document other than for its ongmalpurposo.or by the onglnat chent.or followlt'lg Pegasus' exp<es.s agfeement to such use. T 01285641717 www.pegasuspg.co uk.


Drawing Ref: BIR.4327 09 Client :Gallagher Estates
Date : 23/03/2017
Drawn by :JT Pegasus Checked by : KM Design. Scale : 1:10000 @ A3
N.B- Some of the visuals are missing from the main text so please refer to attachment.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

3. Indicative Development Framework


3.1 Masterplan Components


3.1.1 The Indicative Development Framework Plan, included as the end of this Chapter, works within the parameters identified as part of the landscape and visually led process, and begins to progress some of the design principles. In summary, the process has generated the following statistics in terms of the components and mix of uses within the development framework:

* Up to 1,280 residential dwellings (36.50ha @ approx. 35dph) ;

* Mixed use localcentre (0.5ha);

* One form entry primary school (0.7ha) plus primary school playing fields/commu nity open space (0.55ha);

* Public open space including landscape buffers and attenuation features (16 ha); and

* Land retained as existing use (53 ha).

3.1.2 The proposed development will create housing choice, community facilities and new amenity spaces for the existing and new community whilst improving public access across the site.

3.2 Development Parcels

3.2.1 Four distinct areas of development that are separated by areas of public open space have been
:,
defined within the Development Framework Plan. Each of these areas will have their own character, but will share common design principles and elements in order to provide a cohesive design response to the scheme. These four areas are as follows:

Parcel 1: Woodland Setting

3.2.2 Located to the south of the development proposals and adjacent to existing woodland planting and tree belts, this area of development provides the entrance feature to the design proposals. It is proposed to extend the existing woodland planting along Lichfield Road and to provide the primary site access through this point. Dwellings will be set behind these t ree belts. This area will be of lower density, consisting of predominately detached and semi-detached properties. The proposed dwellings will provide a strong frontage along the route of the main access street.

Parcel 2: Commun i ty Focal Point

3.2.3 The development area contains a mix of uses including residential, mixed-use local centre and potential primary school. The play areas to serve the school could be integrated with the proposed woodland park and provide community areas. The central location of this area will provide a





T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

community focal point, which would also provide benefit for the existing community. It is intended that this area will contain medium density areas that include a mix of short terraces , semi-detached and smaller units. It is proposed that the Local Centre will be located to the north of the Primary School, and will be approximately 0.5ha.

Parcel 3: Canal Si de Development

3.2.4 The canal side development is contained within the lower lying levels within the site adjacent to the canal the corridor. A linear park has been created between the proposed development envelope and the canal in order to maintain the open aspect of the towpath. Dwellings will front onto the canal side park and incorporate a more landscape dominated environment in order to provide the appropriate transition between the built environment and the area of open space. The house types proposed in this location will be short terraces , semi-detached and detached units within the medium low density area.

Parcel 4 : Urban - Rural Transition

3.2.5 The most northern parcel of development creates the transitional area between the built form edge and the adjacent countryside. A new Green Belt boundary is created through the provision of a substantial woodland belt and a potential linear swale park. This parcel will be a lower density area so as to provide an appropr iate landscape dominated environment.

3.2.6 The development proposals achieve an average density of approximately 35 dwellings per hectare, which accords with Government guidance on ensuring the efficient use of land, yet is reflective of the scale of the local area.A variety of house types,tenures and sizes of dwellings are to be provided within the development in order to assist in creating a balanced community as a variety of households can be accommodated.

Site Access

3.2.7 Two access points are proposed to serves the development. The primary access point being located via Lichfield Road to the south of the proposed development. The secondary access is located off Chester Road and has the potential to be a bus/emergency access point only. A bus loop is also proposed to serve the development.




i
1.
*o
c

"0'

,;;
§
I
1
c. .
::;


.l!

I0
i:
8.

ll
::;

KEY

STUDY AREA

LAND RETAINED WITHIN EXISTING LAND USE

INDICATIVE RESIDENTIAL DEVELOPMENT

MIXED USE LOCAL CENTRE


POTENTIAL PRIMARY SCHOOL

POTENTIAL PRIMARY SCHOOL PLAYING FIELDS/COMMUNITY OPEN SPACE


POTENTIAL PRIMARY ACCESS POINT

POTENTIAL SECONDARY ACCESS/EMERGENCY ONLY ACCESS


11
;;-
<(

mil


INDICATIVE MAIN ACCESS ROUTE POTENTIAL BUS LOOP
BUS ONLY/EMERGENCY ACCESS ONLY
ROUTE


EXISTING VEGETATION TO BE RETAINED [SUBJECT TO DETAILED SURVEY]


INDICATIVE PLANTING


PUBLIC OPEN SPACE

POTENTIAL LOCATION FOR ATTENUATI ON FEATURE

POTENTIAL LOCATION FOR CHILDRENS PLAY SPACE








HOME FAR M, SA NDHILLS, WALSALL - INDICATIVE DEVELOPMENT FRAMEWORK PLAN
I T 01285 641717 I F 01285 642348 I www.p egasuspg.co.uk I Team MCC/AMW I Date: 16 DECEMBER 2013 I Scale: 1:2500 ra AO I drwg: BIR.4327_03C I Client: GALLAGHER ESTATES I



Pegasus
Urban °?

N.B-Some visuals have not been scanned so please refer to the Attachement.

4. Transportation


4.1 Introduction


4.1.1 Mode Transport Planning have been appointed by Gallagher Estates to prepare constructive representations setting out the highways and transportation package to support the delivery of circa 1,500 dwellings at Home Farm, Sandhills, north of Walsall.

4.1.2 The site is situated in Brownhills and is bordered to the north by the Wyrley and Essington Canal, to the south by the A461 Lichfield Road, to the east by farmland and to the west by existing residential properties which front onto the A452 Chester Road.

4.2 Planning Policy and Guidance


4.2.1 The delivery of residential development in this location has been considered in relation to relevant transportat ion policies of the Black Country Core Strategy (BCCS), adopted 2011, and the relevant long-term themes of the West Midlands Local Transport Plan 3 (LTP3), covering the period of 2011 to 2026 .

4.2.2 The key policies from the BCCS, specifically relating to the delivery of new development , are as follows:
* CSP5 - Transport Strategy;

* HOU2 - Housing Density, Type and Accessibility;

* TRAN1- Priorities for the Development of the Transport Network; *

* TRAN2 - Managing Transport Impacts of New Development;

* TRAN4 - Creating Coherent Networks for Cycling and Walking; and

* TRANS - Influencing the Demand for Traveland Travel Choices.


4.2.3 The key themes from the West Midlands LTP3, specifica lly relating to the delivery of new development are as follows:
* Long Term Theme 1: Regeneration, thriving centres, corridors and gateways;

* Long Term Theme 3: Modal Transfer and the Creation of Sustainable Travel Patterns; and
* Long Term Theme 6: Improved LocalAccessibility and Connectivity.


4.2.4 The long-term themes of the West Midlands LTP3 aim to reduce reliance on the private car in favour of more sustainable modes of transport for many journey purposes.



4.2.5 Any transportation submissions to support a forthcoming planning application would be prepared in line with the Department for Transports (Offs) Guidance on Transport Assessment (GTA) with reference to DfT circular 02/2013 (The Strategic Road Network and the Delivery of Sustainable Development) where traffic impacts are envisaged on the strategic highway network.

4.3 Local Highway Network and Access Options


4.3.1 1 The site is bordered by the A452 Chester Road to the west and the A461 Lichfield Road to the south. The A452 Chester Road and the A461 Lichfield Road form a traffic signal controlled junction at the southern corner of the site.

4.3.2 The A461 Lichfield Road provides a linkage to Walsall to the south-west of the site and to the A5 Watling Street to the north-east of the site. The A5 Watling Street links to the M6 toll via junctions T5, T6 and T7, to the M6 at junction 12 and to the M42 at junction 10.

4.3.3 The A452 Chester Road provides a linkage into Brownhills and the A5 Watling Street to the north of the site and to Sutton Coldfield, Erdington to the south. The A452 Chester Road also provides linkages to Great Barr and West Bromwich via the A4041 Queslett Road. The A452 Chester Road also links to the M6 at junction 5 and also atjunction 6, via the A38 Aston Expressway.The A38 Aston Expressway provides a direct route into the centre of Birmingham.

4.3.4 In line with policy TRAN2 of the SCCS the traffic impacts of the development proposals will be considered in relation to existing conditions on the surrounding highway network and where necessary appropriate mitigation measures will be provided to counter any forecast adverse impacts directly attributable to the development proposals.

4.3.5 The extent of the off-site highways study area will be agreed in consultation with Walsall Council (WC) and the Highways England (HE) as part of any forthcoming planning application. As an absolute minimum, it is envisaged that the highways impact of the development will need to be considered at the A461 Lichfield Road/A452 Chester Road traffic signal controlled junction .

4.3.6 Vehicular access to the site will be provided via two points, the first will be formed with the A452 Chester Road and the second will be formed with the A461 Lichfield Road. Indicative sketch layouts of the site access proposals are shown on drawings P32-3351-PS-001 Rev A and P32- 3351-PS-002 Rev A.
4.3.7 It should be noted that the access drawings (appended) are preliminary in nature and are indicative layouts only; they will ultimately be subject to further assessment and design iterations , subject to consultation with, and approval from, the Local Highway Authority . Further assessmenUdesign of the accesses will be subject to the following:

* Acquisition of highway boundary plans;



* Updated (more recent) traffic survey data; and

* Further consideration of the driveway accesses along Lichfield Road (in vicinity of the proposed signalised junction) .


4.3.8 A high-level appraisal of site access junctio n capacity has been undertaken using average vehicle only trip rates from the TRICS database for houses privately owned situated within the West Midlands region. The calculated trip rates and resultant traffic generated by the development proposals are summarised in Tables 4.1 and 4.2 below.

Table 4.1: TRICS Trip Rates (per dwelling)




Table 4.2: Traffic Generation (1,500 dwellings)



674
950
08:00-09:00 (AM Peak) 276
17:00-18:00 (PM Peak) 656 398 1053

4.3.9 Baseline traffic flows (2009) for the A452 Chester Road and the A46 1 Lichfield Road have been obtained from Mott MacDonald and these have been growthed to 2023 levels (five years post registration of a planning application, assuming a submission during 2018).

4.3.1O The development traffic has been distributed assuming a 60:40 split between access points, with the bias towards the A461 Lichfield Road access, and proportionally in line with the direction of travel on either the A452 Chester Road or the A461 Lichfield Road, obtained from the Mott MacDonald traffic count data. The results of the analysis are summarised in Table 4.3 and Table 4.4.

Table 4.3: Priority Access with A452 Chester Road - 2023 Base + Development Scenario





Table 4.4: Signal Access with A461 Lichfield Road - 2023 Base + Development Scenario






Site Access (Left Turn) 70% 6 77% 4
Site Access (Right Turn) 73% 6 81% 5
A461 Lichfield Road (S) 76% 17 84% 22
A461 Lichfield Road (N) 68% 13 69% 10

4.3.11 The results summarised in Tables 4.3 and 4.4 indicate that both potential site accesses are forecast to work within acceptable capacity parameters.

4.3.12 The access strategy provides a bias towards a main access junct ion formed with the A461 Lichfield Road. It has also been concluded that given the RFC/DoS forecast for the current access designs options, that should any further development be brought forward, that an additional point of access would likely be required in order to accommodate additional traffic demands .

4.3.13 Given the length of available site frontage with the A461 Lichfield Road, it is also considered that a roundabout option may also offer a potential site access solution,subject to further capacity and design checks.


4.4 Sustainable Accessibility

Pedestrian Connectivity


4.4.1 The existing pedestrian and cycle infrastructure network in the area surrounding the site is illustrated on Figure 4.1overleaf .




Figure 4.1:Existing Pedestrian & Cycle Facilities








......


. *"'"y"-' >:-C-on"t..1r-t1 O'"rPdwYw' .ic.:.e.$,u.r,v.c.y............
V: [1:;, o...t_.s...
"Tr.ffk*f tff C)'d.*tOUt*

"Ol\.road cydt toutt
_.T--- ****....Publk r1cJluof w*y









lOtl















.*
...::**=::::.:-:. ..........,......

.................>-\...

***t:.:

..
.....
'\1
',

.........
\... ...............
- ..........
............... =.............***""*......






4.4.2 There are no Public Rights of Way (PROW) which cross or abut the site. The A452 Chester Road and A461 Lichfield Road both benefit from existing footways on both sides of the carriageway. These link with other footways on adjoining roads, thereby providing a network of footways throughout the surrounding area.

4.4.3 SCCS policy TRAN1 describes how all new developments will address the transport network and provide adequate access for all modes, including walking , cycling and public transport. SCCS policy TRAN4 also describes how new developments should have good walking and cycling links to public transport nodes and interchanges. The internal highway layout of the development proposals will provide pedestrian facilities that will link with those on the existing highway network surrounding the site. The main trip attractors for those on foot are generally situated to the north and west of the site and accordingly improvements to pedestrian crossing facilities on the A452 Chester Road may be required to facilitate east-west movements.



Cycling Connectivity

4.4.4 The existing cycle route provision in the area surrounding the site is illustrated on Figure 4.1. The nearest cycle route to the site runs along the towpath on the southern side of the Wyrley and Essington Canal. From this route, it is possible to access National Cycle Route 5 when travelling northbound, and routes through Brownhills and Walsall Wood southbound.

4.4.5 National Cycle Route 5 is a long-distance cycle route, which routes into Birmingham City Centre, and runs to the extents of Bangor and Reading.

4.4.6 SCCS policy TRAN4 describes how new developments should have good walking and cycling links to public transport nodes and interchanges and how all new development should provide cycle parking. The nearest cycle route to the site runs along the towpath on the southern side of the Wyrley and Essington Canal. The canal abuts the northern boundary of the site and presents a key opportunity to provide linkages between the site and the existing cycling network.

4.4.7 Within the site boundary primary roads will include shared foot/cycleway facilities with cyclists expected to share the carriageway with other road users on lower order roads.

4.5 Public Transport


4.5.1 The nearest bus stops to the site are situated on the A452 Chester Road and the A461 Lichfield Road. These stops are shelter type bus stops and benefit from timetable information. The stops on the A452 Chester Road nearest to the proposed site access point serve the 3/3a, 10/1Oa, 24, 936 and the 937/937a services. The stops on the A461 Lichfield Road additionally serve the service number 35.
4.5.2 The service numbers 3/3a, 10/1OA, 24, 35, 936, 937/937a operate within the vicinity of the site; Figure 4.2, overleaf, illustrates the location of bus stops and services that stop within close proximity, ultimately serving the site.




Figure 4.2: Bus Service Accessibility




4.5.3 The frequencies of these bus services are summarised in Table 4.5. Table 4.5: Summary of Bus Service Frequency



4.5.4 The levelof combined bus service frequency in the area immediately surrounding the site is high and it is not considered to be necessary to provide increased service frequencies as a result of the development proposals. Any required improvements would simply serve to increase accessibility to bus services for all dwellings. Opportunity exists to explore the diversion of existing bus services into the site using a diversionary loop in order to deliver this.
4.5.5 There is opportunity to bring forward smaller parcels of development via a single point of access without investment in significant volumes of public transport infrastructure given that bus services already run along both the A461 Lichfield Road and the A452 Chester Road. This would likely involve relocation of existing bus stops in order to maximise accessibility to the development proposals.
4.5.6 The nearest railway stations to the site are Walsall Railway Station and Shenstone Railway Station, which are approximately 4.6 miles southeast and approximately 2.45 miles east of the site, respectively. Many of the bus services operating within the vicinity of the site also stop at St Paul's Bus Station in Walsall, which is a short three to four­ minute walk to Walsall Railway Station; providing an opportunity to change between modes.
4.5.7 From these railway stations, it is possible to access Birmingham New Street directly on a frequency of every 15-minutes from Walsall railway station, and approximately every 20-minutes from Shenstone railway station. From Birmingham New Street, it is possible to travel onwards towards major UK destinations such as London, Glasgow and Cardiff including other destinations en-route.
4.5.8 It is possible also to access Walsall Railway Station via NCN route 5 (an approximate 30-minute cycle), which can be accessed from the site via the Wyrley and Essington Canal Cycle route, enabling travel between the site and the local railway stations possible via a range of modes of transport.
4.5.9 Walsall Railway Station does not have a car park, however does has 10 cycle storage spaces. Shenstone Railway Station has 20 car parking spaces,with 2 accessible spaces available for blue badge holders. It does not currently have any cycle storage spaces available.


4.6 Local Amenities


4.6.1 Policy TRAN2 of the SCCS sets out accessibility standards for new development , highlighting particular amenities and desirable journey tome distances to them via walking/public transport .
4.6.2 For the purposes of this analysis we have assumed that the development will have a density of between 35-45 dwellings per hectare, will provide less than 25% flats and will provide a high amount of housing suited to families. Those amenities of interest



and the indicative journey times to them are summarised in Table 4.6. Table 4.6 Summary of BCCS Access ibility Standards
* i': T'.Tin-m

Employment - Strategic Centre or other Employment Centre 30 mins (walk/public transport)
Health - Doctors Surgery or Walk- in Centre 15 mins (walk/public transport)
Fresh Food - Centre or Food Store 15 mins (walk/public transport)
Education- Primary School 1O mins (walk only)
Education - Secondary School 20 mins (walk/public transport)


4.6.3 Figure 4.3, overleaf, illustrates key local amenities and employment areas plotted in relation to concentric isochrones representing 400m, 800m, 1,200m and 1600m journey distances radiating from the site. These isochrones represent approximate jo urney times from the site for those on foot where 400m represents a five-minute journey on foot, 800m represents a ten-minute journey on foot and 1,200m represents a 15-minute journey on foot and 1,600m represents a 20-minute journey on foot. The 1,200m isochrones also represents an approximate 5-minute journey by bicycle.


4.6.4 The isochrones show that many local amenities are accessible within reasonable walking and cycling distances from the site including:
* Schools - Millfield Primary School, St James' Primary School, St Bernadette's Catholic Primary School, Shire Oak Academy;
* Pharmacies/Medical Centres - The Park View Centre;


* High Street - Catshill High Street; and


* Employment - Lichfield Road Industrial Estate, Maybrook IndustrialEstate.



Figure 4.3: Walking lsochrones & Key Amenities


Cont.in$ OrdHllnC-e Swvey dtl
0 Crown copynght *nd d1tAbHe

-r.7:L.<T.:i'.;D.::::; :---- Development Site
[QJ-4-00m lsochrone IQ Isoom lsochrone IQ I12oom lsochronc IQ I1600m lsochrone
GEducatlon
[!I]Retail
[!]Medical

Industry




-*­




4.6.5 Walsall town centre is also located 4.6 miles southwest of the site's vicinity; with the town centre containing a wide array of amenities ranging from supermarkets to public houses.

4.6.6 Walsall Bus Service Map also indicates that a variety of bus services run past, or close to these local amenities, thereby making access to amenities possible by a range of modes of transport.

4.6.7 Figure 4.3 shows that many of the core amenities specified in the BCCS are within acceptable walking distances to/from the site. The level of bus accessibil ity from the site is good and would provide improved journey times to many facilities. Public transport journey time modelling will be undertaken (using VISOGRAPHY or similar) to support the development proposals as part of a planning application and to demonstrate the level of accessibility to key amenities afforded by public transport.



4.7 Travel planning and smarter choices


4.7.1 Policy TRAN5 of the WCCS considers influencing the demand for travel and travel choices. Specifically, in relation to new development the use of maximum parking standards in conjunction with promoting and implementing smarter choices to help to reduce the need to travel are discussed . Policy CSP5 also supports this stance.


4.7.2 Accord ingly, the development proposals will be supported by a robust Travel Plan that will seek to promote alternatives to the use of the private car. The Travel Plan will be prepared in line with the following national best practice policy documents:


* DfT - Making Residential Travel Plans Work (2005); and

* DCLG/DfT - Good Practice Guidance: Delivering Travel Plans through the Planning Process (2009).
4.7.4 The existing modal shift for journeys to work from Aldridge North and Walsall Wood ward as surveyed in the 2011 Census is summar ised in Table 4.7. The development proposals would be expected to attract a similar if not better level of sustainable transport use for journeys to work as part of the Travel Plan proposals.
Table 4.7: Summary of Existing Modal Shift (Aldridge North and Walsall Wood Ward)

.1:-.....1n.r. .... . *J*' 11*1ro1:-F.l"i .

Work Mainly at or from Home 3.96%
Underground, Metro, Light Rail, Tram ' 0.05%
Train 0.93%
Bus, Minibus or Coach 7.33%
Taxi 0.20%
Motorcycle , Scooter or Moped 0.50%
Driving a CarNan 73.93%
Passenger in a CarNan 5.75%
Bicycle 1.22%
On Foot 5.77%
Other Method of Travel to Work 0.37%
Total 100.00%
Source: www.neighbourhoodstatisitics.co.uk







4.8 Summary of Discussions with Walsall MBC

4.8.1 A meeting was held at Walsall Council (WC) offices on 13th December 2013: with Kevin Gannon, David Burrows and Steve Griffiths, in summary:
* WBC welcomed the opportunity to see this initial transportation work undertaken;
* Not aware of other sites at this scale currently been promoted within Walsall ;

* Historically smaller developments have come forward in recent years;

* A larger development was seen favorably at a high level (for its ability to contribute positively to highways mitigation);
* Access was generally deemed acceptable for the level of development; however, expressed that the main site access on A461 may require new traffic signals;
* Main concern was the existing A461 capacity from the site into Walsall;

* Hence, we discussed linking signals (they are currently not linked) to aid platooning vehicle movement and hence fee up capacity; and
* A strategy heavily based upon public transport and sustainable access will be key to delivering this development.


4.8.2 Further to the above, and more recently (August 2017), Walsall Council are currently undertaking an improvement scheme along the A461 Lichfield Road; the overall scheme aims to address the issues of growing congestion and capacity along this strategic route.
4.8.3 The scheme targets two key locations, including the A461 Lichfield Road/84152 Salter's Road junction and the A461 Lichfield Road/A452 Chester Road (Shire Oak); both locations will be widened to increase capacity, they will benefit from new and improved pedestrian facilities and new traffic signals/communications technology will be introduced to improve efficiency and operation.
4.8.4 The proposed site access on Lichfield Road (signals) could potentially be incorporated within the network approach now being carried out by WCC ; this could be achieved through various traffic signal management methods and optimisation techn iques .
4.9 Summary


4.9.1 In summary, it is considered that the site can be delivered in line with the aforementioned improvement scheme and other site-specific infrastructure requirements to enhance accessibility and sustainability. The site-specific improvements are listed below, and are also illustrated on Figure 4.4:



* New site access formed with A452 Chester Road;


* New site access formed with A461 Lichfield Road;


* Linkages to the existing fooUcycleway running alongside the Wyrley and Essington Canal; and
* Diversion of existing bus to serve the site via a loop arrangeme nt; including provision of high specification bus stop infrastructure.


Figure 4.4: Proposed Site Connectivity Plan




4.9.2 A Travel Plan would set out objectives , aims, targets, measures and a monitoring framework would ensure that the site is accessible for all modes of transport and as sustainable as possible.

4.9.3 There may be more off-site highway works required in order to mitigate development impacts at key junction locations/corridors , and these would be explored as part of a planning application.




T r a n s p o r t a t i o n

/ '-.
t

../


Th is d rawing has been prod uced by mod e transport planning
No responsi bility will be accepted for the use of th is drawing i n any other project.



Anchor Bridge



144.5m






- -- - - Post
/
/
/
/ / [J
/
/
/ /
/ /
/ /
/ /
/ /'\
/
/
/
/
/
/
/
/
























drawing title



Priority Juncti on


client


Gallagher Esta tes

/
scale
mode transport planning l:SOO@A3
-- -
drawn .

Access Design -
Chester Road


job title


Home Fa rm,





t 012 794 83'10

mode


check ed

JWm A
bdf

07-09-17

Issued

Sand H i lls, Walsall

e :'lfoCl'odetransport cc- uk
w www.modet,..e1rspc.* .c.o.LJ

tra nsport planning created Sept 17

P32-3351-PS-002




DO N OT SCA OFF THIS DRAWI N G.


I§
1$
'
N






Proposed
Signalised Junction





























/).


<9/t
\S'








d rawing title


Lichf ield Roa d Signalised Junction Access Design






JOb title


Ga llagher Estates

Home Farm,


mode transport planning





t 0121 794 8390


mode




drawn check ed





bdf

Sand Hills, Wa lsall
--- - - --------------.- -- --


e G>modetr3nsport co.uk
w "modetr*r1sport c.:i.uk

tra nsport pla nning created Se- -
17

P32-3351-PS-OOI

P.S- There is a visual that has not been uploaded please refer to the attachment.

5. Ecology


5.1 Background


5.1.1 Aspect Ecology has been appointed to advise Gallagher Estates in respect of ecological matters relating to promotion of land at Home Farm, Sandhills, Walsall through the Issues and Options Review of the Black Country Core Strategy.

5.1.2 An extended Phase 1 Habitat survey of the site was conducted in December 2013, to record main habitat types and species, identify areas of ecological interest, and provide an assessment of the potential use of the site by fauna! species. A desktop study was also undertaken to source known records of protected or notable species and details of local site designat ions. This desktop study has since been updated in October 2015 to ensure background information is up to date.

5.1.3 This note provides a summary of the survey findings with regard to promotion of the land through the emerging plan making process, providing an overview of ecological issues with a focus on potent ial constraints and opportunities and overall ecological deliverability of the proposed allocation.

5.2 Site Description


5.2.1 The site comprises an 'L' shaped area of land to the north and east of Home Farm, Sandhills, located to the east of Brownhills in Walsall. The site is bordered by residential properties associated with Chester Road (A452) to the west, the Wyrley and Essington Canal to the north, and Lichfield Road (A461) to the south. Home Farm and associated farm buildings, residential properties and surrounding farmland lie to the east, excluded from the site itself but included as part of the wider survey area.

5.2.2 The site itself is dominated by arable farmland with a number of hedgerows and treelines at its margins. A track also runs through the middle of the site from Chester Road to the west to Home Farm, along which a small woodland area is located.

5.3 Ecological Baseline Conditions


Ecological Designations


5.3.1 Desktop study information received from the Multi-Agency Geographic Information for the Countryside (MAGIC) online database, Staffordshire Ecological Record and EcoRecord indicate that the site is not subject to any statutory nature conservation designations.

5.3.2 However, information returned from EcoRecord identifies part of the site as a Potential Site of Importance (PSI), namely Sandhills Arm Canal PSI, which includes the small woodland area and



associated hedgerow along the track which divides the site. PSls are sites that potentially contain areas of important semi-natural habitat but currently fall outside of the Local Site system. The PSI is described as "former canal arm, now infilled, and triangular block of woodland depicted on historic map (1st ed OS map 1880s)".

5.3.3 3 Wyrley and Essington Canal, forming the northern boundary of the site, is also subject to non­ statutory designation as a Site of Local Importance for Nature Conservation (SLINC). The SLINC is designated for its generally good quality water conditions supporting a diverse aquatic flora .

5.3.4 A number of ecological designations are also located within the surrounds of the site, as shown on Plan 3586/BN1 contained at the end of this Chapter.

5.3.5 The nearest statutory designation is Shire Oak Park Local Nature Reserve (LNR) located 200m to the south of the site. This comprises an old sand and gravel quarry support ing lowland heathland, grassland, woodland and pond habitats.

5.3.6 A number of Sites of Special Scientific Interest (SSSls) are located within the wider surrounds of the site, the nearest being Chasewater and the Southern Staffordshire Coalfield Heaths SSSI, located approximately 1250m to the north of the site. The SSSI is designated for its heath, fen and standing open water habitats, supporting two nationally scarce vascular plant species.

5.3.7 A number of European designations are also located within the wider surrounds of the site including Cannock Extension Canal Special Area of Conservation (SAC) 3.3km to the west of the site and Cannock Chase SAC 9.8km to the north of the site.

Habitats


5.3.8 A plan of habitat types and features within the site and wider survey area is provided at Plan 3586/BN2, contained at the end of this Chapter.

5.3.9 The site is dominated by arable farmland under cultivation for a range of crop types at the time of survey. This appears to be relatively intensively farmed with few arable weeds evident, and is largely open in nature with few hedgerows or other boundary features. Aside from a small area sown with a wild bird seed mixture (see below), the farmland also lacked areas of set aside or field margins at the time of survey. As such, the arable farmland is considered to provide limited opportunities for wildlife, and is of low ecological value at a local level.

5.3. 10 Habitats of elevated value are generally limited to the margins of the site, and include:


* Woodland - a small wood land copse is present along the track which bisects the site (forming part of Sandhills Arm Canal PSI). This supports numerous semi-mature to mature trees, likely



planted in origin, with species including frequent Sycamore and occasional Beech, Oak and Pine. A moderate understorey of Holly and young Sycamore is present, although ground flora is very species poor, dominated by Ivy with occasional Common Nettle and Bramble. Based on its poor diversity of species and the lack of an established woodland flora, the woodland is not considered to be of high importance, although provides some value in association with the treelines and hedgerows as an area of wooded habitat within an otherwise open landscape.
* Hedgerows and treelines - several hedgerows and treelines are present at the boundaries of the site. These are species-poor, although are generally intact, offering value in terms of wildlife habitat and connectivity around the margins of the site. Occasional standard trees are present along the hedgerows, and established treelines occur in the southern part of the site, largely dominated by Pine and Sycamore.
* Wild bird seed plot - a small area in the south of the site was sown with a wild bird seed mixture at the time of survey, comprising a grass dominated sward with frequent pea and cabbage species. This area provides some interest as a foraging resource for farmland birds, although given its recently established nature, is not of any particular ecological value.

5.3.11 Further habitats of elevated value occur within the wider survey area, including established treelines with some notable mature trees, additional wood land areas, and an area of grass pasture with scattered mature trees. The offsite canal to the north of the site also provides a valuable wildlife corridor, with areas of emergent vegetation and associated tree and scrub habitats.





5.3.12 The majority of the site is of limited value for faunal species, being dominated by arable farmland with few boundary habitats or areas of ground cover providing shelter or nesting opportunities. Nevertheless, some potential exists for farmland species, whilst boundary habitats provide potential opportunities for a wider range of faunal species. A discussion of potential opportunities for faunal species is given below:

* Bats - roosting opportunities are largely absent from the main part of the site, although a small number of trees within the woodland and along boundary treelines were noted to have developed features such as rot holes and splits which may offer bat roosting potential, whilst offsite farm buildings also offer potential roosting habitat. Boundary features (notably along the offsite canal) are also likely to provide habitat for foraging and commuting bats, including species such as Noctule, Common Pipistrelle, Soprano Pipistrelle and Wh iskered Bat for wh ich records were returned as part of the desktop study. The main part of the site however, being dominated by arable farmland, is unlikely to support any significant bat activity.
* Badger - A record of a Badger sett was returned from EcoRecord as part of the desktop study, located along the offsite canalto the north of the site. However, no evidence of this species was recorded within the site during the field survey.



* Other mammals - No evidence of any other protected or notable mammal species was recorded during the field survey and generally the site is considered to provide few opportunities for such species being dominated by arable farmland with few areas of wooded vegetat ion. Some potential occurs for species favouring open farmland such as the UK BAP species Brown Hare, although no sightings of this species were made during the field survey. The offsite canalprovides potential habitat for riparian species including Water Vole (for which records were returned as part of the desktop study) and Otter.
* Birds - the site is likely to provide some interest for farmland bird species, with species recorded during the field survey including UK BAP and Red listed1 House Sparrow, Linnet and Starling. However, nesting habitats are largely limited to the boundaries of the site (aside from ground nesting species such as Skylark), whilst a lack of associated field margins or extensive areas of set aside mean that the site is unlikely to support any significant bird interest.
* Reptiles - the site is dominated by arable farmland with no substantial areas of rough vegetation, providing unsuitable habitat for reptile species.
* Amphibians - a pond is shown on OS mapping close to Home Farm, approximately 160m from the site boundary. However, this was noted to be dry at the time of survey, and is understood to be a temporary drainage feature (see Plan 3586/BN2). The next nearest waterbody is a large lake within a sand and gravel pit 380m to the south of the site. Given the separation from the site by residential housing and a main road, it is unlikely there would be any significant movement of amphibians between this waterbody and the site, particularly given the low suitability of terrestrial habitat within the site (being dominated by arable farmland). As such, this species group is not considered to form a constraint at the site.
* Invertebrates - the site is generally considered to be of low value for invertebrate species, being dominated by arable farmland. Wooded vegetat ion provides some elevated potential for this species group, although such habitats are generally limited to the site margins.

5.4 Constraints and Opportunities


5.4.1 The survey work undertaken has found the site to be largely unconstrained in respect of ecology. However, a number of minor constraints have been identified, including presence of nearby ecological designations, boundary habitats of elevated value, and potential opportunities for a number of protected and notable faunal species. A discussion of these potential constraints is given below in relation to any future proposed development, together with consideration of any required actions or mitigation. Potential opportunities for ecological enhancement in accordance with national and local policy are also identified.








1 RSPB (2009) 'Thepopulation status of birds in the UK - Birds of Conservation Concern: 2009 '



Ecological Designations


5.4.2 With the exception of Sandhills Arm Canal PSI and Wyrley and Essington Canal SLING, all ecological designations are well separated from the site and are unlikely to be subject to any direct effects as a result of the proposed development. Some potential exists for increases in recreationa l use, although nearby designations such as Shire Oak Park LNR are managed to accommodate recreational use, whilst there is unlikely to be any significant increase in recreational pressure at more distant designations.

5.4.3 In regard to European designations, the Habitats Regulations Assessment (HRA) for the Black Country Joint Core Strategy 2 , identifies some uncertainty in regard to effects on Cannock Chase SAC as a result of air pollution and recreational pressure and disturbance, and Humber Estuary cSAC, SPA and Ramsar and Severn Estuary cSAC, SPA and Ramsar as a result of water quality and water supply. Preliminary work undertaken by Walsall Council as part of the HRA process to inform the emerging Site Allocations Document has narrowed these issues further, to Cannock Chase SAC only, although an agreed approach in regard to this designation is yet to be established. As such, it will be necessary for the approach in regard to Cannock Chase SAC to be confirmed at an appropriate stage, although given the separation between the site and this designation (beyond an 8km zone of influence) and available options for mitigation if required (e.g. provision of open space to offset increases in recreational pressure), it is considered likely that any potential issues can be addressed.

5.4.4 In regard to Sandhills Arm Canal PSI, this can readily be retained under the proposals together with an appropriate buffer of open space. Road access may be required across the hedgerow which forms the western part of the PSI, although subject to sensitive road design and new planting, this could be achieved with minimal loss of connectivity. Furthermore, long-term management of habitats within the PSI and provision of improved wildlife connectivity through new landscape planting and habitat creation would provide benefits under the proposals.

5.4.5 Wyrley and Essington Canal SLING is separated from the site by a tow path and hedgerow, ensuring no direct disturbance or damage to bankside habitat. Under the proposals , there is an opportunity to create an area of open space alongside the canal, forming a buffer to the proposed development, whilst implementation of an appropriate drainage and pollution control strategy would avoid adverse effects as a result of surface water runoff. As such, subject to implementation of appropriate mitigation, it is considered that this designation can be fully safeguarded under the proposals.









2 UE Associates (201O) 'Habitats Regulations Assessment of the Black Country Joint Core Strategy: Appropriate Assessment Report'




Habitats


5.4.6 The site is dominated by arable farmland of low ecologicalvalue, not considered to form a constraint to the proposed development, whilst habitats of elevated value including hedgerows, treelines and woodland are mostly restricted to the site margins, allowing them to be readily retained under the proposals. Some minor losses of hedgerow habitat may be required to accommodate road access, although given the species-poor nature of the hedgerows at the site, this is unlikely to constitute a significant impact.

5.4.7 Under the proposals, there are significant opportunities to deliver ecological benefits through new habitat creation and enhancement of existing habitats. Such enhancements could include the following:

* As discussed above in relation to ecological designations, there is an opportunity to create an area of open space adjacent to the offsite canal. This could incorporate a range of wooded, grassland and wetland habitats (such as wet scrapes and ponds), forming additional habitat for species associated with the canal such as waterfow land bats, and strengthening the function of the canal as a wildlife corridor;
* Native tree and shrub planting within areas of open space and around the perimeters of the built development , providing new wildlife habitat and contributing to the habitat linkage provided by existing woodlands and hedgerows.
* Provision of wildflower grassland margins along hedgerows and woodland edges;
* Specific measures to benefit farmland bird species such as wild bird cover plots and scrub creation;
* Enhancement of existing woodlands/hedgerows through sensitive management in accordance with ecological principles.





5.4.8 The site generally provides few opportunities for wildlife, and is unlikely to be subject to any significant constraints in regard to protected or notable species. However, habitats at the site provide some potential for species including bats, Badger, Brown Hare and farmland birds, and as such these species will require consideration at an appropriate stage. Further detail is given below:

* Bats - boundary features such as hedgerows and the offsite canal provide potential habitat for foraging and commuting bats, and consideration will need to be given to treatment of these boundary habitats to ensure suitable habitat for bats is maintained, particularly in respect of lighting. It is recommended that this is supported by further survey work at the planning application stage. In addition, it is recommended that any trees proposed for removal are subject to survey to provide an assessment in regard to roosting activity. Following implementation of the habitat measures set out above, bats are likely to benefit under the proposals, whilst provision of bat

E c o l o g y





T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

boxes on retained trees and within the fabric of new buildings would provide additional roosting opportunities for this species group.
* Badger - based on current evidence, no Badger setts would be affected under the proposals. However , it is recommended this is confirmed by further survey at the planning application stage.
* Brown Hare - it is recommended that searches for Brown Hare are undertaken as part of other survey work at the site at a planning application stage to determine presence/absence of this species. If present, consideration could be given to enhancements to the wider survey area to ensure suitable habitat is maintained for this species.
* Birds - it is recommended that further survey work is carried out at the planning application stage to provide a full assessment in relation to this species group. However, boundary habitats likely to be of value to bird species can be readily retained under the proposals, whilst new habitat creation can be provided within areas of open space to maintain and increase opportunities for bird species at the site. Measures such as provision of nest boxes on retained trees and within the fabric of new buildings would also provide enhancements for this species group.

5.4.9 The habitat measures set out above would also deliver benefits for other fauna! species such as invert ebrates, whilst increasing the likelihood of species such as reptiles and amphibians colonising the site.

5.5 Feasibility Assessment of the Proposed Development


5.5.1 Based on the results of the work undertaken, the majority of the site is considered to be unconstrained in terms of ecology. A number of minor potential constraints have been identified including Sandhills Arm Canal PSI and the presence of wood lands, hedgerows and treelines, along with the potential for protected and notable species including bats, Badger, Brown Hare and birds. However, these constraints are largely restricted to the margins of the site or established boundary features and as such it is considered that with a sensitively designed masterplan, together with the provision of appropriate avoidance and mitigation measures, the proposed development would be unlikely to result in significant effects in terms of ecology. Indeed, the proposed development provides the opportunity to create areas of new wildlife habitat within areas of open space, providing significant benefits for wildlife. As such, the proposed development is considered to be highly deliverable in ecological terms.















E c o l o g y























*- ,-**.-:_::
GA,::: ..
...- ............C..o.i ...t,,. ,
*{i,,..... ..----\
*.*- l1 II
'



























KEY:
D
































SITE LOCATION






















_...---:
aspect ecology

SITE OF SPEC IAL SCIENTIFIC INTEREST (SSSI) Aspect Ecology limited -Wnt Coun*Hardwick Business Park
Noral Way - Banbury - Orlon:!s.ture - OX16 2AF

D LOCAL NATURE RESERVE (LNR)

0 1295 276066 * i nfo@aspect...ecology . com - www.aspect-eoology . com

Dmm

ANCIENT & SEMI-NATURAL WOOD LAND (ASW) LAND AT HOME FA RM, IPROJECT

SITE OF IMPORTANCE FOR NATURE CONSERVATION (SINC)
SITE OF LOCAL IMPORTANCE FOR NATURE CONSERVAT ION (SLINC)

SANDHILLS, WALSAL L
ECOLOGICAL DESIGNATIONS ITITLE

D POTENTIAL SITE OF IMPORTANCE (PSI)* 3586/BN1 IORA'IJ1'G

Information on non-statutory sites was returned for a 4x4km area around the site. Any such sites beyond this boundary may not beincluded on this plan.
'Full information relating to PSls has only been provided for sites at the centre of the search area,so only PSls


REV.

relevant to the site or immediate surrounds are shown on the plan. OCTOBER 2015 DATE


Based upon I.he Otdna Survey map w:th permissK>n of the Controller of Her Majesty's Stationery Office,Cl Crown Copynghl Aspect Ecology id, West Court. Hardw::ck Business Par11:,No1alV..'<Jy, Banbury,Oxfordshire , OX16 2AF. Licence No. 100045262

N.B- Some visuals have not been uploaded so please refer to the attachment

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

6. Archaeology and Cultural Heritage


6.1 Introduction


6.1.1 Pegasus Group has produced a heritage appraisal on behalf of Gallagher Estates, which provides a high-level assessment of potential heritage issues which could constrain the development at Home Farm, Sandhills.

6.1.2 This appraisal will identify designated heritage assets within and in the vicinity of the proposed site. Where appropriate, non-designated assets will be identified. It will provide an initial assessment of the significance which will also include assessing whether the proposed development site contributes towards the significance of the assets through setting. The appraisal will conclude with a statement of whether the heritage may present a key constraint to development.

Designated Assets


6.1.3 Within a 1km search area from the site boundary there are four Listed Buildings, all at grade II and one Scheduled Monument. These are shown on Figure 6.1 below.



Figure 6.1 Location of listed buildings (scheduled monument located to the south)

N.B- Figure 6.1 has not been uploaded as full text please refer to the attachment.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills

6.1.4 The Listed Buildings are:
* The Wyrley and Essington Canal Anglesey Branch Railway Aqueduct - 1077180 - 0.?km north-northwest of the site boundary;

* Wyrley and Essington Canal Footbridge at Ogley Junction - 1087076 - 0.2km north of the site boundary;

* Sandhills Pumping Station - 1421472 - 0.25km east of site boundary; and

* Fighting Cocks Farmhouse - 1374262 - 0.6km southeast of the site boundary.

6.1.5 The Scheduled Monument is Hillfort known as The Castle Fort at Castlebank Plantation (1017244) located 1km south of the site boundary. The majority of this asset is located beyond the 1km boundary, extending south towards Castlehill Road.

6.1.6 There are no Registered Parks and Gardens, Registered Battlefields, Conservation Areas or Wor ld Heritage Sites within the site, study area or in close proximity.

6.1.7 The Wyrley and Essington Canal Anglesey Branch Railway Aqueduct is located to the north of the proposed site boundary. It is an aqueduct carrying the Anglesey branch of the Wyrley and Essington Canal over the South Staffordshire Railway. The Canal was originally built in 1797 widened and made navigable in 1850,with the railway built in 1849. This aqueduct was constructed in 1856. The aqueduct was constructed by localengineers, Lloyds, Foster and Co from Wednesbury .

6.1.8 The significance of this asset lies primarily in its architectural and historic value. It is evidence of the emergence of the modern transport networks of both canal and railway. It provides evidence of the engineering skill of the area which came to prominence in the 19th-century. It also provides evidence of the growth in prosperity of the area in the industrial period, aided by the construction of
transportation networks.


6.1.9 The setting of this asset is provided by the railway and the canal, both of which provide the reason for the construction of the asset. The setting is also formed by the remainder of the canal, but with diminishing contributions to significance the greater the distance from the asset.

6.1.10 The site does not form part of the setting of the asset. Although located adjacent to a branch of the canal, there were numerous branches of the canal along its length and the site does not contribute to the significance and understanding of this asset. Therefore , development within this area would not result in any harm to the significance of this heritage asset.

6.1.11 The Wyrley and Essington canal Footbridge at Ogley Junction is located to the north of the proposed development. The footbridge carries the towpath of the Anglesey Branch over disused Ogley locks







T e c h n i c a I C o m p e n d i u m IHome Farm, Sandhills

section of the main canal which was closed in 1954. The bridge was constructed in 1829 and is of cast iron with brick abutments. It was constructed by Horsley Iron Works.

6.1.12 The significance of this asset lies in its historic and architectural value. It is constructed from cast iron, like a number of the other structures along the canal, lending it an aesthetic coherence and tying it into the contemporary industrial landscape. The historic value lies in the information it provides for the development of the canal system and the rise in industrial activity in this area in the 19th-century.

6.1.13 The setting of the asset is formed by the canal and the towpath. These provide the reason for the construction of the asset. There is some connection with the rest of the canal network however the contribution this makes to the significance of the asset diminishes the further away from the asset the canal reaches.

6.1.14 The site does not form part of the setting of the asset. Although another branch line of the canal does cut across the site, the site does not contribute towards the significance or understanding of the asset. If the canal arm crossing the site was still extant, the contribution would be greater, but it no longer is. Change within the site would create change within the immediate surrounds of the asset, but would not cause any harm.

6.1.15 The Sandhills Pumping Station is a water pumping station built in 1935 by F. J . Dixon for the South Staffordshire Waterworks Company and was constructed by Thomas Lowe and Sons Ltd. It was constructed in response to the growing population of South Staffordshire and the increased demand for a clean water supply. Sandhills Pumping Station was constructed in a stripped-classical style and pumps water via two boreholes. The original pumping engine has been replaced but the machinery is still in use today.

6.1.16 The significance of this asset lies in its architectural and historic value. It is a good quality design and example of an inter-war pumping station. Although the machinery is lost, the fabric of the building has seen little change and the purpose is still legible. It has historic value in the information it provides for the social history of the area.

6.1.17 The setting of this asset is its location. It was placed to take advantage of the water table and proximity to settlements. There is no connection with the site and the site does not form part of its setting. Change within the site resulting from the development will not cause any harm to the significance of the asset.

6.1. 18 Fighting Cocks Farmhouse is a late 18th-century farmhouse, of typical L-shaped plan. The name of the farmhouse suggests it may have been the site of cock-fighting in the post-medieval periods.

6.1.19 The significance of this asset lies within its historic and architectural value. It is a good example of the local vernacular and provides evidence for the rise of the agrarian economy and sustaining of that economy in an area which was becoming increasingly industrial.

T e c h n i c a I C o m p e n d i u m I Home Farm, Sandhills


6.1.20 The setting of this asset is the agricultural surroundings of the asset. This contributes to the significance of the asset. The site does not form part of the setting of this asset. Any changes within the site will not harm the significance of the asset.

6.1.21 The Scheduled Monument of the hillfort known as The Castle Fort at Castlebank Plantation is located to the south of the proposed development. It consists of the earthwork remains of the univallate hillfort at Castlebank Plantation, on the crown of the hill, northwest of Castle Hill Road. The remains comprise a bank and outer ditch enclosing an oval area orientated southeast to northwest and is 170m long and 140m wide. The northwest corner of the hillfort a clay pit has been excavated which is now filled with water. This clay pit has removed all traces of the bank and ditch and ancillary works associated with the pit has also removed earthworks on the southwestern portion. There are also quarry pits located to the southeast outside the banks. It is likely that the entrance was located to the northeast with a break in the ditch and the slightly more gentle slope on the hillside beyond.

6.1.22 The significance of this asset lies in its archaeological and historic value. It provides evidence of the construction of hillforts and information into the design and evolution of defensive forts. It also has the potential to provide information on the material culture of the occupants. It has historic value as is it a rare example of a late Bronze Age, early Iron Age hillfort. It provides evidence of how the contemporary society utilised the landscape.

6.1.23 The setting of the asset is the landscape within which it sits. As a fort, it is defensive in nature and therefore the views from this asset add to the significance of the asset. The landscape around the fort would have supported the inhabitants of the fort and therefore this also contributes to the setting of the asset.

6.1.24 The site may fall within the setting of the fort, however the contribution it makes to the significance is very low. In addition, although the entrance of the fort may face towards the site, this view is now blocked by woodland and there is no apprec iable visual relationship between the site and the fort. Change within the site is unlikely to cause harm to the significance of the scheduled monument.

Non-designated Assets


6.1.25 A search was undertaken of the Wolverhampton and Walsall Historic Environment Record (HER) via Heritage Gateway. This identified a small number of assets within the site and in close proximity.
The assets are identified with their HER number.


6.1.26 The line of the Sandhills Arm of the Wyrley and Essington canal once bisected the site, crossing form the main canal running northeast towards Sandhills Farm and is identified as a non-designated asset (5893). It can be seen on the 1889 Ordnance Survey map and the line of this arm is shown until the late 20th-century mapping. The appearance of the canal arm on the 1st edition maps indicates that at

T e c h n i c a I C o m p e n d i u m I Horne Farm, Sandhills

this time, Sandhills Farm was a small industrial complex, with the canal constructed to help transport the goods. The 1st edition Ordnance Survey map shows the canal arm terminating at Sandhills with a wharf area and possibly loading bay. This complex of industrial buildings and the canal wharf are also identified as a non-designated asset. The actual date of construction of this arm of the canal is unknown, however it was marked as out of use on the 1902 Ordnance Survey map. But this time, the entire northern portion of the site, north of the canal arm and two fields to the south of Sandhills (labelled here as The Sandhills) is shown as covered in a vast orchard.

6.1.27 Located within the site and visible on the 1st edition Ordnance Survey is Sandhills House. This is a non-designated heritage asset (5892). The present owner maintains that this house was built in the 17th century as a gamekeeper's lodge, however the current fac;ade is 19th-century. A lodge building is identified at the junction of Lichfield road and the entrance drive to Sandhill house. This lodge (5891) was constructed in the late 19th-century, but first appears on the 1902 Ordnance Survey map.

6.1.28 Home Farm (5992) is also a non-designated heritage asset in its own right. It was constructed in the 19th-century with a walled garden and a mature belt of sycamore.

6.1.29 Located to the southeast of Sandhills, adjacent to Lichfield road is the site of Shire Oak House (5993). This is a mid-19th-century villa, set within its own grounds. It has undergone a series of name changes, first known as Bleak House, the Hill House and finally Shire Oak House by 1919. It is now a residential home. Adjacent to this is the site of a gravel pit (10217). It was still being worked in 1938 and was one of a number of small-scale gravel extraction pits located on the periphery of the site.

6.1.30 At the southwestern corner of the site is the Shire Oak Inn (10218). This is shown on the 1st edition Ordnance Survey map but labelled as Anchor Inn. It is also believed to have been the site of a brewery.

6.1.31 The series of historic Ordnance Survey maps shows the change in the landscape which has occurred over the late 19thand early 20th century. Within the site, the major changes have been the introduction of the Sandhills Arm of the Wyrley and Essington Canal which cut across the site and the later use of a large portion of the area as an orchard. The 1st edition Ordnance Survey map shows the site, with Sandhills House, Home Farm. The entrance to Sandhills House is shown leading northwest from Lichfield Road, with what appears to be a formal avenue of trees lining the driveway.

6.1.32 In the surrounding landscape, directly adjacent to the site boundary is the site of Bleak House. This building is shown within its own grounds. On the 1902 Ordnance Survey map, the name of the building has been changed to Hill House, and the 1919 Ordnance Survey map has this as Shire Oaks, with a large gravel pit located immediately west.

6.1.33 The 1st edition Ordnance Survey map shows the settlement of Cutshill to the northwest, separated from the site by the canal. The settlement is very linear, with little other development in the vicinity of the site. There are a number of collieries within the area, but it is likely that during the 19th -century, the site was used for agricultural purposes.







T e c h n ic a I C o m p e n d i u m IHome Farm, Sandhills

6.1.34 The 1902 Ordnance Survey map shows the orchard covering the majority of the site. It also shows the area of Sandhills Farm as enlarged, with a number of gravel pits and possible glasshouses. A lodge building has appeared at the entrance to the drive leading to Sandhills House,a non-designated asset in its own right. It also shows the development of Shire Oak to the southwest of the site with housing appearing along Chester Road.

6.1.35 There is litt le change within the site until the removal of the orchard in the mid-20th- century. The settlements within the surroundings of the site expand during the 20th- century. By the 1950s, the settlement of Shire Oak has expanded with housing added on the northeastern side of Chester Road and linking the settlement of Ogley Hay, forming one continuous strip of development. This expansion continues until the extents seen in the present day. The proposed development site remains unchanged.

Conclusions


6.1.36 This appraisal has shown that there are no major heritage constraints which could preclude the development of this site. There are a small number of designated assets within the vicinity of the site, but it has been demonstrated that the site does not contribute to their significance. Therefore, change within the site would cause no harm.

6.1.37 The appraisal has identified the potential for below ground archaeology to be located within the footprint. This consists primarily of early modern, industrial archaeology. In particular, it is likely that any intrusive works would identify the line of the Sandhills arm of the Wyrley and Essington Canal. In addition, any works in the vicinity of Sandhills House and Home Farm may uncover evidence of wharf and industrial canalstructures.

6.1.38 The northern portion of the site was beneath a large-scale orchard for at least 50 years, with two fields to the south of Home Farm also included. It is possible that given the density of the planting and the age of the orchard, this would have removed archaeological deposits, or at the very least caused fairly substantial truncation. The site is likely to have been used for agricultural purposes throughout is recent history. There is little potential for earlier phases of archaeology within the site.

6.1.39 Therefore,archaeological investigation would be required for areas which have the potential to disturb the Sandhills arm of the canal, in addition to a Heritage Assessment to accompany any planning application for this site.

7. Drainage


7.1 Introduction


7.1.1 1 THDA Limited prepared this statement on the hydrology of the site and proposals for foul and surface water drainage. It is based on its visit to the site guided by the farmer, a study of sewerage records purchased from Severn Trent Water, and reviews of Internet data on the web sites of the Environment Agency and British Geological Survey.

7.1.2 A plan titled "Drainage Principles", appended, shows contours within the site at five metre spacing, the area in which the British Geological Survey shows the presence of diamicton till superficial deposits, the location of the watercourse serving the site, and provisional principal surface water and sewage drainage routes proposed to serve the development.

7.2 Baseline Condition


7.2.1 1 British Geological Survey mapping shows that near surface bedrock beneath the site is a mixture of sandstone or conglomerate. Superficialdeposits of diamicton till are present over a substantial area of the northern part of the site. In the vicinity of the only natural principal watercourse within the site (which is a headwater of the Crane Brook), there are superficial deposits of glaciofluvial sands and gravels.

7.2.2 A number of records for boreholes drilled within or close to the site are publicly available from British Geological Survey . These records show that locally the water table is at considerable depth and that deeper rocks mainly comprise various red sandstones .

7.2.3 Environment Agency mapping confirms that the bedrock beneath the site is a major aquifer, from which there is a public water supply abstraction located to the south east of the site. A small area of land in the south eastern corner of the site is classified as Source Protection Zone 2, and the remainder of the site is classified as Source Protection Zone 3. The type of development proposed is compatible with these Zones, but reasonable care will be needed with development drainage and control of pollution in general.

7.2.4 The farmer advised that the land in the northern part of the site has a sandy top soil and has occasional clay content and has field drains installed that are connected to the principle watercourse on the site to aid drainage. The area of land served by this drainage is similar to the area where diamicton till is indicated as present. The remainder of the land is very free draining, as witnessed during the site visit.

7.2.5 The principalwatercourse is culverted under Lichfield Road with a 300 mm diameter pipe. The invert of the pipe is about 1.2 metres below ground level at the south east of the site.



7.2.6 Contours confirm that there is one valley line within the site to which all parts of the site fall with a minimum general gradient of about 1:68. The lower end of the valley contains the principal watercourse.

7.2.7 Environment Agency mapping also shows that whereas there are historic and authorised landfills beyond the site boundary, none is recorded within the site. The entire site is classified as Flood Zone
1. Reservoir flood routes have been removed from the Environment Agency website, so have not been checked, but are thought to be not relevant to the site.

7.2.8 As the entire site is Flood Zone 1, and it is not an area with special drainage problems, the development is proposed in the best flood risk location and is not subject to a Sequential Test.

7.2.9 No other flood risks to the development became apparent as a result of the site visit and desktop research.

7.2.10 Severn Trent Water serves the urbanised areas to the south, west and north of the site with foul and surface water sewerage. The foul sewers in Chester Road and Lichfield Road are 150mm and 225mm diameter. Based on 1,500 dwellings a foul flow of approximately 70 litres per second would be expected, so it is unlikely that the existing sewers would have spare capacity. Typically a 300mm diameter pipe would be needed to convey a flow of this magnitude.

7.2.11 Dwellings in Lichfield Road to the south of the site are served by a sewage pumping station. There is a 125 mm diameter rising main from this station which is located under the southern edge of the site.

7.3 Proposed Drainage Strategies


7.3.1 The outline proposal for disposing of sewage from the development is to provide a sewerage network discharging to a single purpose built on site pumping station located in the valley line. This will pump sewage through the site along a line similar to that shown on the Principles Plan to a Severn Trent 1050 mm diameter foul sewer in Lindon Road. In due course Severn Trent will need to be approached to agree this or any other point of connection, to ensure their networks have adequate capacity, and to agree the timescales for both development and potential network improvements.

7.3.2 There are many options for disposing of surface water from the development. The site benefits both from permeable strata and has access to a principal watercourse . As such much of the site can be drained directly to ground, or can be taken directly to the watercourse. Good land gradients and large areas of suitable located open space will allow suitably sized ponds to be located - these ponds can either be used to infiltrate of attenuate the flow prior to discharge to the water course.



7.3.3 Details of surface water drainage and disposal will be dependent mainly on the results of site investigation, planning decisions on what water features may be required as amenity , ensuring compliance with current and emerging SuDS guidance, and the advice as yet to be given by the Environment Agency about the balance between using infiltration to sustain the aquifer and discharge to watercourse to sustain riverine ecology.

7.3.4 Where ground conditions allow , typically roofs could be drained direct to soakaways. Typically roads would drain to the watercourse, thereby allowing implementation and maintenance of the longer treatment trains required. Swales and infiltration lagoons would be a viable and economic alternative.

7.4 Conclusion


7.4.1 This preliminary appraisal of water related environmental factors , including flood risk, groundwater/abstraction and drainage, fully supports the draft master plan for the development as drawn.

8. Ground Conditions

8.1 Introduction


8.1.1 This chapter considers the ground conditions of the Home Farm, Sandhills site, and in particular the Mineral Safeguarding Area which the site lies within, and why it is not considered suitable for mineral extraction.

8.2 Ground Conditions and Mineral Safeguarding Area


8.2.1 The site is located within a Mineral Safeguarding Area for Sand and Gravel (Policy MIN1 of the Black Country Joint Core Strategy). The purpose of a Minerals Safeguarding Area is to alert prospective developers to the existence of mineral resources, so that they can be taken into account at the earliest possible stage of the development project.

8.2.2 The policy explains that proposals for non-mineral development within Mineral Safeguarding Areas will not be permitted unless it can be demonstrated that the development will not result in sterilisation of the resources within these areas. All non-mineral development proposals will be encouraged to extract any viable mineral resources present in advance of construct ion where practicable, and where this would not have unacceptable impacts on neighbouring uses. The policy requires supporting information to be submitted to demonstrate that mineral resources will not be sterilised. The supporting information is required to demonstrate that:

* Mineral resources are either not present, are of no economic value or have already been extracted as a result of a previous site reclamation scheme or other development; or
* Extraction of minerals is not feasible, for example due to significant overburden or because mineral extraction would lead to or exacerbate ground instability ; or
* Prior extraction of minerals would result in abnormal costs and/or delays which would jeopardise the viability of the development; or
* There is an overriding need for the development which outweighs the need to safeguard the mineral resources present; or
* Extraction of minerals would have unacceptable impacts on neighbouring uses, the amenity of local communities or other important environmental assets.

8.2.3 Mindful of the above, the site at Home Farm, Sandhills is not considered suitable for mineral extraction. It is a sensitive location given the uses that immediately border the site including, in particular, Millfield Primary School and residential properties along the Chester Road and Lichfield Road. The area surrounding the site is generally residential in nature, particularly to the west and south. In addition, the Wyrley and Essington Canal borders the site western boundary and mineral extraction could have a severe impact on ecology in and around the canal side.



8.2.4 In addition to the sensitive uses that surround the site that render the site unsuitable for mineral extraction, the Environment Agency have confirmed that the bedrock beneath the site is a major aquifer, from which there is a public water supply abstraction located to the south east of the site. A small area of land in the south-eastern corner of the site is classified as Source Protection Zone 2, and the remainder of the site is classified as Source Protection Zone 3. The residential development of this site is compatible with these Zones. Should the site however be used for mineral excavation, the aquifers below the site could be adversely affected by the backfilling operations. This has the potential to cause problems regarding pollution risk. The backfilling of the site following excavation would also lead to the current permeable site becoming impermeable thereby reducing aquifer recharge.Any excavation and subsequent backfilling of the site would have implications on the future use of the site. The current sand and gravel soils provide ideal ground conditions to build on, being both permeable and stable, foundation solutions would become an issue on filled ground which would affect costs and values and potentially lead to issues with the viability of the development of the site in the future.

8.2.5 In essence, this site is not suitable for mineral extraction. Whilst the site overlies substantial sand and gravel reserves, these minerals are not a scarce resource and given the extent of other land potentially available for mineral extraction in the area which does not have such constraints it is the case that the need for minerals from this site does not outweigh what are material planning objections to such a use in this location.

8.3 Summary


8.3.1 In light of the above it is concluded that this site is suitable for residential development in accordance with both local and national planning policy which promotes a presumption in favour of sustainable development. A proposal for an alternat ive use, such as mineral extraction, would not be. Notwithstanding this it is considered that the site is unsuitable for mineral extraction given its location relative to a number of sensitive receptors and the potential for pollution risk with regards the aquifers below the site. Sand and gravel reserves are not in short supply and given that there is the extent of land potentially available locally for mineral extraction without the use of this site, it is therefore the case that the loss of this site as a potential mineral location is not significant and does not outweigh the legitimate material planning benefits arising from the use of the site for residential development as suggested.

8.3.2 In conclusion, having undertaken the above initial work in relation to the site's ground conditions, it is considered that the site is suitable for residential development.

9. Agricultural Land

Agr ic ultural Land Classification

9.1.1 This section presents the initial Agricultural Land Classification assessment which has been undertaken by Kernon Countryside Consultants Limited (KCC) to identify any major constraint to development on the site.

9.1.2 There are two principal agricultural considerations in the selection of development sites. These are:
* The effect on land and its quality ; and
* The effect on farm businesses.


9.1.3 National Policy Guidance governing the non-agricultural development of agricultural land is set out in the National Planning Policy Framework (2012) (NPPF). Paragraph 112 of the NPPF notes that local planning authorities:

"should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poor er quality land in preference to that of a higher quality."

9.1.4 The best and most versatile agricultural land (BMV) is defined in Annex 2 of the NPPF as land of Grades 1, 2 and 3a in the Ministry of Agriculture , Forestry and Fisheries (MAFF) Agricultural Land Classification (ALC).

9.1.5 The Agricultura l Land Classification Survey (ALC) system divides land into five grades according to the extent to which its inherent characteristics can be exploited for agricultural production. Grade 1 is described as being of excellent quality and Grade 5, at the other end of the scale, is described as being of very poor quality. ALC is based upon an assessment of limitingfactors including soils, climate, and other physical limitations and the way in which these factors interact.

9.1.6 The provisional agricultural land classification map (MAFF 1983), as attached overleaf at Figure 9.1, shows undifferentiated Grade 3 land over the site. The map is provisional and was designed to be used for areas larger than about 80 hectares in extent and boundaries on this plan do not necessarily reflect the detailed situation. Since the map was constructed there has been changes to the classification. In particular Grade 3 has been subdivided into sub Grades 3a and 3b and the effects of the interaction between climate and soils are now more clearly stated which puts the land quality more clearly into the local context. The current Ministry of Agriculture Fisheries and Food ALC system was last revised in 1988.







Agricultural Land
r
Grade 1 Grade 2 Grade 3 Grade 4 Grade 5
Non-Agricultural Land
Land predominantly Other land primarily
in urban use in non-agricultural use


NORTH
t FIGURE 9.1
TITLE Extract from the ProvisionalALC Plan (1983)
SITE Home Farm, Sandhill
CLIENT Gallagher Estates
NUMBER KCC2116/0110/15/vmd
DATE October 2015 SCALE NTS
KERNON COUNTRYSIDE CONSULTANTS LIMITED GREENACRES BARN,STOKE COMMON LANE, PURTON STOKE,SWINDON,
WILTSHIRE, SNS 4LL Tel 01793 771333
This planis reproduced from the Ordnance Survey under copyright licence
100015226


9.1.7 A review of www.MAGIC.gov . uk has identified that the site has been the subject of a detailed ALC survey which was carried out in February and March 1994, in accordance with the current MAFF Guidelines (1988). A copy of the survey is attached at Appendix 9.1. It should be noted that the conclusions of the report relate to the wider site area, of which only part of the land is proposed for development. The survey has identified the site to comprise mainly of sub Grade 3a land, with a swathe of sub Grade 3b land running through the middle of the site in an east - west direction. There are also areas of woodland and agricultural buildings within the site.

9.1.8 Table 9.1 below sets out a breakdown of the grading across the site.


Table 9.1: ALC Grading across the Site


Grade Description Area (Ha) Area (%)
3a Good 62.1 74
3b Moderate 15.7 19
Ag Buildings Ag Buildings 2.2 2
Woodland Woodland 1.7 2
Non-Ag Non-Ag 1.9 2
TOTAL 83.6 100
* The table above relates to the grading across the wider site and, as set out on the indicative Masterplan, a smaller proportion of the site is proposed for development,which includes all of the 3b graded land identified.

9.1.9 The wider site area comprises predominately of sub Grade 3a and Grade 3.b land. The developable area proposed, however, includes a smaller proportion of Grade 3a land and all of the Grade 3b land.
\
A review of land quality in and around Brownhills indicates that this site actually comprises some of the lower quality land in the locality. Surveys to both the north and west of the site identify areas of Grade 2 land, i.e. land of a higher quality than that found at Home Farm, as illustrated at Appendix 9.2. Please note that Append ix 9.2 relates to the wider site and not the development area, which is proposed on the Indicative Masterplan.

9.1.10 Although the site comprises of sub Grade 3a land with an area of sub Grade 3b, the presence of "best and most versatile land" around Brownhills is common place. Indeed, much of the surveyed land to the north and east of Brownhills has been identified as being of Grade 2 quality.

9.1.11 The NPPF requires that, where "significant" development of BMV land is demonstrated to be necessary , poorer quality land is used in preference. In this case, the development of sub Grade 3a land will represent the development of poorer quality land in the area with much of the land around Brownhills comprising of Grade 2 land.



Existing Farming Business

9.1.12 Gallagher Estates has engaged with the owner of the existing farming business on site. The owner of the farming business has confirmed that the business would not be severely affected by the development proposals which are being promoted through this Background Document. The owner currently farms around 2,000 acres, and it is notable that the promotional agreement to secure development on this site does not include the farm houses and associated buildings. Therefore, from a practical perspective the farming business will be able to continue to operate as normal after any residential development is secured and implemented . The promotional agreement covers approximately 200 acres, so even if all of this area was withdrawn from the current farming land base, this would only represent a 10% reduction in the farmed area,which would not be a significant change. As such, development proposals will not prejudice the existing farm business.

9.2 Summary


9.2.2 With regards to Agricultural Land Classification, the wider site has been found to comprise land of sub Grade 3a and Grade 3b. The site proposed for development includes a smaller proportion of Grade 3a land and all of the 3b land. Although sub Grade 3a is considered to be "best and most versatile agricultural land", a review of land quality in and around Brownhills indicates that the site actually comprises some of the lower quality land in the locality, with surrounding areas being identified as being of Grade 2 quality . The development of this site would therefore represent use of poorer quality land in accordance with the NPPF, which states where significant development of BMV land is demonstrated to be necessary, poorer quality land is used in preference.

9.2.3 This Chapter has also demonstrated that development proposals will not prejudice the existing farm business, as outlined at paragraph 9.1.12.

9.2.4 In conclusion, having undertaken the above initial work in relation to the site's agricultural land quality, it is considered that the site is suitable for residential development.




APPENDIX 9.1 MAFF ALC SURVEY REPORT



























AGRICULTURAL LAND CLASSIFICATION LAND AT HOME FARM, SANDBILLS
















R D METCALFE
Resource Planning Team ADAS Statutory Group WOLVERHAMPTON

ADAS Ref: 25/RPT/0617 Job No: 8194
MAli'F Ref: EL46/10407












AGRICULTURAL LAND CLASSIFICATION REPORT FOR
LAND AT HOME FARM, SANDBILLS


I. SUMMARY

I .I The Agricultural Land Classification (ALC) Survey for this site shows that the following proportions of ALC grades are present:

Grade/Subgrade

3a ha
64.0 % of site

76
3b 15.7 19
Other land Agricultural buildings
2.0
2
Non-Agricultural 1.9 2

1.2 The main limitation to the agricultural use ofland in Subgrades 3a and 3b is topsoil stone content.

2. INTRODUCTION

2.1 The site was surveyed by the Resource Planning Team in February and March 1994. An Agricultural Land Classification survey was undertaken according to the guidelines laid down in the "Agrirultural Land Classification of England and Wales - Revised Guidelines and Criteria for Grading the Quality of Agricultural Land" (MAFF 1988).

2.2 The 83.6 ha site is situated to the cast of Brownhills and north west of the A46 I road. The land in the north adjoins a canal, and the west boundary adjoins housing, while the nonh eastern boundary adjoins farmland.

2.3 The survey was requested by MAFF in connection with an ad-hoc development proposal for an industrial development.

2.4 At MAFF Land Use Planning Unit's request this was a detailed grid survey at l :I 0000 with a minimum auger boring density of I per hectare. The attached map is only accurate at the base map scale and any enlargemenl would be misleading.

2.5 At the time of the survey the site was mostly under cereals, brassicas with some fallow land.









3. CLIMATE

3.I The following interpolated data are relevant for the site
Average Annual Rainfall (mm) 725
Accumulated Temperature above 0°C January to June (day °C) 1315
3.2 There is no overall climatic limitation on the site.
3.3 Other relevant data for classifying land include:

Field Capacity Days (days) Moisture Deficit Wheat (mm) Moisture Deficit Potatoes (mm)


170
91
77


4. SITE

4.1 Three site factors of gradient, micro relief and flooding are considered when classifying land.

4.2 These factors do not impose any limitations on the agricultural use of the land.

5. GEOLOGY AND SOILS

5.1 The solid geology of the area is shown as Soft Sandstone with Pebble Beds - British Geological Survey Sheet 154 I inch.

5.2 The underlying geology influences the soils which have a sandy loam texture overlying loamy sand and sand. *

6. AGRICULTURAL LAND CLASSIFICATION

6.1 Subgrade 3a - occupies 64.0 ha (76%) of the survey area.

6. I .I The soil has a sandy loam texture over loamy sand and sand to depth and with up to 15% stones greater than 2cm size present.

6. 1.2 The main limitation to the agricultural use of this land is topsoil stone content.

6.2 Subgrade 3b - occupies 15.7 ha (19%) of the survey area and is found in the northern and eastern parts of the site.

6.2.1 The soil typically has a sandy loam texture overlying loamy sand and sand to depth. The topsoil content with stones greater than 6cm in size is up to 10%.

6.2.2 The main limitation to the agricultural use of this land is topsoil stone content.












6.3 OLher land includes agricultural buildings and farm tracks.

6.4 SUMMARY OF AGRICULTURAL LAND CLASSIFICATION
GRADES

Grade/Sub-grade Areas in Hectares % of Survey Area % of Agricu ltural
Land
3a 64.0 76 80
3b 15.7 19 20
Other land
Agricultural buildings 2.0 2
Non-Agricu ltural 1.9 2
Totals 83.6 100.0 100.0







March 1994




















...,









































APPENDIX 9.2 MAFF ALC SURVEY RESULTS FOR LAND AROUND BROWNHILLS






























CJ
*

10. Conclusions


10.1 Conclusion


10.1.1 This Technical Compendium relates to the site known as 'Home Farm, Sandhills, Walsall'. This document has been produced in response to the 'Issues and Options' consultation of the Black Country Core Strategy Review. Previous versions of this document have been prepared in response to other consultations in relation to the emerging Walsall Local Plan, and alterations have been made where applicable in light of any changes in contextual information.

10.1.2 Land at Home Farm, Sandhills is a highly sustainable and deliverable site and it is proposed that it should be allocated for residential development as part of the Black Country Core Strategy Review. The site provides an opportunity to deliver a significant amount of housing (circa 1,280) with associated infrastructure and open space, which will assist to meet the development requirements of Walsall and the wider Black Country and meet the housing needs of local people in a successful manner.

Suitable
10.1.3 The site comprises of Green Belt land on the edge of Brownhills. As demonstrated in Section 2, the site is a suitable candidate for release from the Green Belt from a landscape perspective. Brownhills is identified in the current Development Plan as a 'regeneration corridor' with a wider range of services and facilities in the nearby town centre, therefore the site is well placed to meet the future development needs of the area.

10.1.4 The town is also located in close proximity to the towns of Walsall , Sutton Coldfield and city of Lichfield.

10.1.5 As such, the site is considered to be a sustainable location for residential development and will contribute towards meeting the housing needs of Walsall and the wider Black Country.

Available
10.1.6 The land is under the control of Gallagher Estates, a Master Developer who is committed to putting the land to market as soon as planning permission has been obtained and relevant site wide conditions discharged. This model allows the potential for multiple house builders to deliver the site efficiently and effectively. Gallagher Estates is committed to obtaining planning permission for the land at the earliest opportunity following an appropriate allocation as part of the adopted Local Plan.

10.1.7 There are no legal ownership matters which would prevent the land from being delivered for residential use.


Achievable
10.1.8 The site is greenfield and as demonstrated throughout the technical chapters, there are no constraints to development that would pose the site to be unviable to deliver. Gallagher Estates has reviewed the economic viabi lity of the site and proposals, including considering land values , market attractiveness and demand , sales rates and development costs and can confirm the development is economically viable to deliver.

10.1.9 In terms of the delivery programme, it is possible that if the site were to be allocated, completions could commence on site within 2 to 3 years of adoption - this would be subject to planning permission. It is anticipated that two to three developers would build at a rate that would see the site complete within 10 years or well within the plan period.

10.2 Summary


10.2.1 To summarise, the site will deliver a significant quantity of much needed housing in the medium to long term in a sustainable location. The proposed development is viab le and can be delivered in a timely manner. The site is therefore achievable.

10.2.2 Gallagher Estates are committed to engaging and working with Walsall Council and the local community to design a high quality residential development.

10.2.3 The development will consider site specific constraints and opportun ities, and will ensure that development proposals respect the existing character of the area.

10.2.4 In light of the information prepared, it is considered the site is suitable, available and achievable for development to meet emerging requirements for dwelling provision in both Walsall and indeed the needs of the wider Black Country.