Peacock and Smith for D Morgan Plc Cheslyn Hay SHSID.Pdf

Home , A449 road, Cannock, Cannock railway station, Chase Line, Cheslyn Hay, Landywood

December 2019

NPPF 98 adding links.

Blue infrastructure connecting with green infrastructure connecting into the site NPPF 2019 (ref para 138) 2018 SHELAA site refs: 116 & 131 where it has been concluded

that it is necessary to release Green Belt land, plans should

give first consideration to land which has been

previously‐developed and/or is well served

by public transport

Landywood Station Communal wellbeing this community hub, Academy, Primary School, Leisure Centre, South Staffordshire District Council Local Plan is 600m from the housing site Spatial Housing Strategy and Infrastructure the community centre and library Delivery Consultation Response are 900m from the site 7 October ‐ 12 December 2019

Proposed Extension of Cheslyn Hay Host Settlement for Residential Development

NPPF 96 Sport. Health and well‐being of communities.

1 of only 4 Leisure Centres in South Staffordshire

Front Cover – Tier 1 Settlement Cheslyn Hay

Contents

Page: 3 - Settlement Hierarchy Tier 1-5, Rural Services and Facilities Audit 2019 4 – Public Transport Access to Hospitals, Rural Services and Facilities Audit 2019 5 – Cannock Bus Network Map 6 – Cannock Town Centre Catchment Area 7 - Train Access from Landywood Station to the Chase Line ‘a vitally important route into Birmingham’ 8 - Strategic Transport Connections and Employment Sites 9 - Highways England New Northern Motorway Link Road M6 Toll/M6 to M54 10 - National Planning Policy Framework (NPPF) 2019 11- Inspector’s Decision and Council’s Statement of Common Ground (initial September submission – Appendix 8) 12 - Summary

13- 45– Consultation response to 10 Questions 46- 52 - Following on from meeting with Officers email dated 1/11/19

Appendix 1 - Initial September submission Pages 1 – 82

All 10 questions as part of this consultation process, and the answer to each question are not mutually exclusive and the response needs to be read as a whole and with the entirety of this submission. The entirety is relevant to all 10 questions and the Council’s assessment of the SHELLA submissions. This is our first formal opportunity to counter the Council’s position that part of our submitted site (131) is not disassociated from the host settlement Cheslyn Hay and therefore the promoted site needs to be re-considered as a whole, (including 131). This consultation response is part of a formal procedure to provide the Council with the opportunity to reconsider the inclusion of site 131 as part of our promoted site (131, 116 and adjacent land. Appendix 1 initial September submission) as part of this public consultation.

With regard to the disassociated point, para 5.8 of the SHELLA confirms that some sites which are disassociated from a settlement… will now be subject to more detailed investigation, to assess their capacity to provide deliverable/developable housing and employment sites through the Local Plan review. Footnote 4 on page 14 confirms that on a case by case basis, it may be appropriate to consider a site not directly adjoining a development boundary as a ’potentially suitable extension to a village/urban area where the site is a short distance from the host settlement and a legible pedestrian route and means of access to the host settlement can be demonstrated by the site promoter’. To assist the Council in carrying out a more detailed investigation an initial September submission 2019 was presented to the Council followed by an exchange of emails which are now presented between pages 46 – 52 of this consultation response. Further emails with the Council on this point are within Appendix 9 of the initial September submission.

For More Information - Points of Contact

Brock Ltd (a landowner) is within the D Morgan group of companies together with D Morgan PLC the site Promoter. Both companies are controlled by Denis Morgan and employ more than 225 people.

D Morgan PLC www.dmorgan.co.uk New Hey, Chester Road, Great Sutton, South Wirral, CH66 2LS For further information contact Victoria Morgan [email protected]

Peacock and Smith Chartered Town Planning and Development Consultants, 53 King Street, Manchester, M2 4LQ Gareth Glennon [email protected]

Rural Services and Facilities Audit 2019 (Page11)

Para 4.9 States Perton, Wombourne, Brewood and Kinver were Main Service Villages in the previous 2012 Core Strategy. However, they performed less well in the revised settlement hierarchy than other settlements previously classified as Main Service Villages (e.g. Codsall/Bilbrook, Cheslyn Hay/Great Wyrley, Penkridge). As such, these four villages have been reclassified as Tier 2 settlements. This primarily reflects the lower level of access to employment opportunities available in Perton, Wombourne, Brewood and Kinver when compared to other Tier 1 villages, which is in part due to these villages’ lack of rail access. Tier 1 Settlements have the greatest access to employment, services and facilities and Tier 1 have the only access to a train Station to travel around the District and into the surrounding towns and cities. Access to a train Station, gives the best connectivity with sustainable travel.

Cheslyn Hay/Great Wryley uniquely in South Staffordshire is the only location with access to the Chase Line (Landywood Station) which uniquely is the closest station to the West Midlands conurbation. From Landywood, Bloxwich is 7 minutes by train and to Walsall 13 minutes by train. Within the GBHMA Bloxwich/Walsall has a housing shortage.all to make it glook good yes, that’s it. Bloxwich/Walsall has exceptional public transport connectivity to Cheslyn Hay by train and by bus. Para E18 of the Sustainability Appraisal to the Local Plan makes it clear that Tier 1 Settlements have access to railway stations and Tier 2 settlements do not. Development proposals in Tier 1 Settlements would be excepted to locate new residents in an area with excellent access to rail services to travel around the District and into the surrounding towns and cities. The Greater Birmingham Housing Market Area – Strategic Growth Study, para 1.69 states, “for strategic development, the accessibility to public transport and particularly to the rail network, is a particularly important consideration within the wider sustainability of different development options”.

Cannock Chase Hospital

New Cross Manor Hospital Hospital

Bridgnorth Community Sandwell Hospital Hospital Russell Hall Hospital Corbett Hospital

Plan taken from Page 19 – Rural Services and Facilities Audit 2019 Tier 1 settlements – Public Transport Access to Hospitals.

Cheslyn Hay has the shortest journey time by bus and rail to a Hospital, taking 21-30 minutes compared to Codsall/Bilbrook taking 41-60 minutes and Penkridge taking 51-60 minutes. These other Tier 1 settlements are in a less accessible and less sustainable location, with significantly longer journey times to a Hospital (double), refer to Council’s colour coded key above.

By Train on the Chase Line Landywood Railway Station is located on the Chase Line, and is just 1 mile from the promoted site. It takes 3 minutes to reach Cannock Railway Station from Landywood; Cannock Chase Hospital is 0.7 miles from Cannock train Station.Manor Hospital at Walsall is 0.6m from Walsall train Station and can be accessed via Landywood in just 13 minutes. Also using the Chase Line to Birmingham New Street a journey which takes 35 minutes, Birmingham Children’s Hospital the UK’s leading specialist paediatric centre is 0.6m from the train Station.

By Bus Cannock Chase Hospital is close to Cannock Bus Station and Railway Station (3 minutes by train from Landywood). From the promoted site through Cheslyn Hay, the Cannock Bus Station can be accessed via the half-hourly 70 bus service which runs via the Hospital, and terminates at the other end of this bus journey at Wolverhampton. The NHS additionally run a free 15-minute mini-bus service between Cannock Chase Hospital and New Cross Hospital, Wolverhampton. Manor Hospital, Walsall is accessible by bus; the 2-bus service terminates at Walsall Bus Station, 0.6 miles from the Hospital. Birmingham Children’s Hospital the UK’s leading specialist paediatric centre can also be reached from Cheslyn Hay via the X51 bus service.

Cannock Bus Network Map. Cheslyn Hay is on 2 core routes to Wolverhampton City and to Walsall Town Centre & Walsall Manor Hospital - from Cannock Town Centre. The proposed housing site is within the Cannock Town Centre Catchment Area

70, 71 to 1,2, 2E, X51 to Bloxwich and City of Wolverhampton Walsall Town Centres Metro Tram & Walsall Manor Hospital & Birmingham Children’s Hospital X51

Cannock Town Centre offering a choice of employment opportunities has the greatest range of facilities and services; Cheslyn Hay is in the catchment of the Town Centre, served by a regular bus service on two core bus routes, as shown above.

The Town Centre is highly accessible from Cheslyn Hay with frequent bus services, demonstrating Cheslyn Hay’s sustainable credentials. Connections by bus are also available from Cheslyn Hay to Bloxwich, Walsall, Birmingham, Wolverhampton and Metro Tram services.

The Infrastructure Delivery Plan states that in rural areas, public transport is generally poor. Cheslyn Hay is not a rural area and is exceptionally well served by public transport and onward connections.

The Cannock Town Centre catchment area does not include, Codsall/ Bilbrook or Penkridge. Compared to Cheslyn Hay, these other Tier 1 settlements are significantly less accessible by bus and have fewer employment opportunities, facilities and services accessible to residents. These other Tier 1 settlements are not comparable to the excellent connectivity to the Cannock Town Centre catchment area which Cheslyn Hay benefits from. They are therefore not as well connected and not as sustainable.

This excellent bus network provides exceptional connectivity with sustainable travel, available from the promoted site to all members of society of all age groups both able bodied people and those that are less mobile many of whom may not have access to a car. .

Cheslyn Hay with exceptional connectivity is in the most sustainable location with the shortest journey time to employment opportunities and range of facilities and services in Cannock Town Centre and with access to Bloxwich, Walsall, Birmingham and to Wolverhampton for a multiple choice shopping experience and for retail employment.

By Road, from the M6 Junction 11, the A460 north east links with the M6 Toll (T8) and links with the Churchbridge Triangle (Interchange) where there are Four Retail Parks. The A460 also links with the A4601 crossing the A5 to Cannock Town Centre and the McArthur Glenn Designer Outlet (see image below). Cannock Town Centre is approximately 5.4km (3.3 miles) from the promoted site.xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

THE SITE IS WITHIN THE CANNOCK TOWN CENTRE CATCHMENT AREA CONNECTED BY ROAD (ALSO BY BUS – 2 CORE BUS ROUTES) AND BY THE CHASE LINE (BY TRAIN)

It’s 3 minutes by train from Landywood to Cannock Station for the Sub-Regional Shopping Centre and McArthur Glenn Designer Outlet, both are within 1.6km walking distance from Cannock Railway Station

Town Centre

By car, it is a short 10 minute journey of 5.4km (3.3 miles) along the A4601 in order to access Cannock Town Centre (and Cannock Chase Hospital), McArthur Glenn Designer Outlet, and retail parks, shown above offering an exceptionally wide choice for shopping and retail employment.

There is a genuine choice from Cheslyn Hay and the promoted site to access Cannock Town Centre and other destinations by non-car modes of travel with exceptional public transport facilities by bus and by train.

Whilst car use in South Staffordshire is above the national average due to its rural nature, other modes of travel are available in this promoted location for the short journey into Cannock Town Centre by bus and by train. The rail and bus network provides sustainable travel which is available to all members of society of all age groups both able bodied people and those that are less mobile many of whom may not have access to a car.

BY. TRAIN TO 2 SUB-REGIONAL SHOPPING CENTRES AND 1 REGIONAL SHOPPING CENTRE FROM STATIONS ON THE CHASE LINE CANNOCK – BLOXWICH - WALSALL - BIRMINGHAM  It’s 3 minutes by train from Landywood to Cannock Station to the Sub-Regional Shopping Centre.  It’s 7 minutes by train to Bloxwich Town Centre.

 It’s 13 minutes by train to Walsall Sub-Regional Shopping Centre ‘Saddlers’, incorporating the Railway Station built into the Shopping Centre. S  It’s 35 minutes by train to Birmingham City Centre – a Regional Shopping Centre

Staffordshire County Council’s draft Rail Strategy (2016) notes that the Chase Line’s electrification will result in station upgrades and longer platforms including in reduced journey times, giving rise to considerable economic benefits for the West Midlands area; increased frequencies of service (and additional flexibility in regard to stopping patterns); and, increased reliability of services, particularly where constraints or bottlenecks on the network are removed.

From Landywood Station, the Chase Line provides access to 4 nearby Shopping Centres & 3 Hospitals.

Access to 3 Hospitals (Cannock Chase, Walsall Manor and Birmingham Children’s Hospital – the UK’s leading Paediatric centre) and for Shopping Centres accessing retail facilities, services and other employment on this Commuter Line. The ‘Chase Line’ accesses Stations between Landywood and Birmingham New Street giving rise to considerable economic benefits (Staffordshire County Council Draft Rail Strategy 2016). There is a Strategic Growth Study published by the GBHMA. Para 1.69 applies: “The rail network is a particularly important consideration”

The GBHMA is highly accessible from the Chase Line, a Strategic Rail Corridor accessing the Greater Birmingham Housing Market Area (GBHMA) – by train giving rise to considerable economic benefits for the West Midlands Area

The Greater Birmingham Housing Market Area – Strategic Growth Study, para 1.69 states, “for strategic development, the accessibility to public transport and particularly to the rail network, is a particularly important consideration within the wider sustainability of different development options”.

Within the Birmingham Housing Market Area 38% of all a.m. peak journeys into Birmingham City Centre are now made by rail, this is predicted to grow by 49% from 2013 to 2033 and 114% by 2043. Network Rail West Midlands and Chiltern railway route study 2016.

From Landywood Station, it takes:

 3 minutes by train to get to Cannock, with its Town Centre and range of facilities, along with new McArthur Glenn retail outlet currently being constructed.  Bloxwich, 7 minutes from Landywood on the train, also has a Town Centre comprising a mix of national and independent retailers, focused around the High Street area.  Walsall is 13 minutes from Landywood station, with the Town Centre hosting a shopping centre (Saddlers incorporating the Railway Station), several large format supermarkets, as well as traditional retail units.  Birmingham New Street, accessing a Regional Shopping Centre & in the heart of Birmingham City Centre (Britain’s Second City), is just 35 minutes from Landywood station. The rail network provides sustainable travel which is available to all members of society of all age groups both able bodied people and those that are less mobile many of whom may not have access to a car.

Strategic Transport Connections and Employment Sites

South Staffordshire Council’s Site Allocations DPD (2018) para 9.23 states:

“The West Midlands Strategic Employment Study 2015 commissioned in 2014 by Local Authority Chief Executives across the West Midlands also supported this broad location as a Regionally Significant and attractive location for National and International Investment.” (Fig 5.1 below) x Fig 5.1,shows the M54 corridor, M54/M6 Northern Motorway Link Road, M6/M6 Toll & Cheslyn Hay

Cheslyn Hay is a designated employment area set out at para 3.13.1 of the Sustainability Appraisal benefitting from Active Travel, Walking and Cycling to access employment.

South Staffordshire District Integrated Transport Strategy, October 2017, para 5.2 states:

“Delivery of transport infrastructure and reducing traffic delays on the wider strategic network and local authority networks within settlements is fundamental to creating the right conditions for growth in jobs and new homes”. The promoted site and Cheslyn Hay is at the heart of the Strategic Road Network in South Staffordshire in ‘ this broad location’ as a Regionally Significant and attractive location for National and International Investment.pissing about with formatting again to make it look ok I hipe anuwayplease The promoted site will access M6 J11 and the New Northern Motorway Link Road within just 750m connecting with the M54 J1 within 3.9km (2.5m) a short journey of 5 minutes or less along the new link road

No other Tier 1 Settlement is as conveniently located (just 750m) to this Strategic Road Network where 3 motorways connect. Where the motorways connect is to be improved by the New Northern Motorway Link Road.

Highways England New Northern Motorway Link Road between M54 Junction 1 and M6 Junction 11 & proposed Housing site location which is within 0.75km (0.47miles) of M6 Junction 11

Hilton Cross Strategic Employment Site accessed from M54 junction 1 and the future Strategic Employment Site at ROF Featherstone together with the i54 Strategic Employment Site will benefit from this new Northern Motorway Link Road providing the highest benefit to the local economy, providing the best journey time of the options.

Infrastructure Delivery Plan 2019 para 5.19 capacity at the A460 was a known issue that would be addressed through the M54-M6 Link Road. Appendix 1 – baseline infrastructure projects gives an estimated completion date at the end of 2024.

The promoted housing site within a designated employment area benefits from exceptionally close proximity to Strategic Transport Connections including new Northern Motorway Link Road accessing Strategic Employment Sites creating some 20,000 job opportunities in this broad location as a Regionally Significant and attractive location for National and International Investment (Source West Midlands Strategic Employment Study 2015)

Some 20,000 job opportunities will be available within 5km (3.1miles) of the proposed Housing site creating highly skilled employment, supported by South Staffordshire District Council’s Core Policy 7 to sustain and develop the local economy. The West Midlands Strategic Employment Study (2015) is similar to that previously carried out some years ago which resulted in the identification of 2 Regional sites- i54 South Staffordshire within 5km (3.1miles) from the proposed Housing site accessible from the M54 motorway Junction 2 and Hilton Cross within 3.9km (2.5miles) accessible from the M54 Junction 1. Both Strategic Employment Sites are accessible within a short 5-10 minute journey from the promoted site.

As the local economy is developed (Core Policy 7) creating highly skilled employment in this Regionally Significant location, the availability of high quality housing must keep pace. The proposed Housing site providing new homes for the growth in jobs (approx. 800 units – subject to dialogue with the Council) will provide a choice of house types in an attractive, highly accessible and exceptionally sustainable location for National and International Investment (Strategic Employment Study 2015).

National Planning Policy Framework (NPPF) 2019

Sustainable travel modes that limit future car use: Previously developed/land well served by public transport

NPPF 2019 para 122 (c) states:

“Planning Policies and decisions should support development that makes the most efficient use of land, taking into account: c) the availability and capacity of infrastructure – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use.”

NPPF 2019 para 138 states:

“…Where it is has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously- developed and/or is well served by public transport…”

We conclude that of all the sites promoted in the Green Belt, our client’s site is the most suitable in South Staffordshire, ‘to promote sustainable travel modes that limit future car use’ owing to the existing public transport infrastructure connections that are easily accessible from it – by rail and by bus. The cumulative sustainable travel modes and benefits available to all members of society of all age groups both able bodied and those that are less mobile many of whom may not have access to a car, make it an exceptionally attractive site that is exceptionally well served by public transport (NPPF paras 122 (c) & 138).

The settlement of Cheslyn Hay and the promoted site have previously been assessed by the Council through the SHELAA and in evidence based documents, however the situation has changed following the completion of the electrification of the Chase Line in 2018 at a cost to the public sector of £110m with new electric trains operational May 2019. This change in the £110m having now been invested in sustainable transport by the public sector (that limits future car use) available to all members of society of all age groups, must be captured in an up to date Infrastructure Delivery Plan, which is dealt with below in our consultation response.

The Council’s 2019 Infrastructure Delivery Plan (IDP) reinforces NPPF paras 122 (C) and 138.

Para 1.3 States:

“… This seeks to locate growth in locations that maximise existing infrastructure provision as well as provide new infrastructure where known deficits have been identified in this IDP.”

Para 5.2 States:

“This Infrastructure led strategy reflects the Council’s desire to see growth that does not put a strain on existing infrastructure, and where possible delivers new infrastructure benefits, whilst also reflecting national policy requirements by ensuring growth is located in locations with good access to sustainable public transport, or where brownfield opportunities exist…..”

Para 5.3 states:

“… Regard has also been had to the relative levels of existing services and facilities in villages – informed by the Rural Services and Facilities Audit 2019 – and opportunities for development to make the most of existing infrastructure provision when setting levels of housing growth.”

The IDP is out of date and fails to capture the recent electrification of the Chase Line 2018 with new electric trains commenced May 2019 at a cost to the public sector of £110m. The use of this existing rail infrastructure benefitting from this public sector investment should now be maximised and the out of date IDP misinforms the SHSID, which is unsound.

(SHELAA Site 116) Campians Wood Appeal APP/C3430/A/06/2019854

Para 9.2 “… Numerous bus routes pass close to the site with stops within convenient walking distance and it is proposed to provide the infrastructure to allow a bus service to pass through the site when development is substantially complete. Local linkages to other public transport intersections and to local services, employment and education are sufficiently convenient to encourage future residents to consider journeys by modes other than the private car. The proposal meets the sustainable development objectives set out in PPG 13.” Statement of

Common Ground agreed with South Staffordshire District Council

Para 9.29 “…it is agreed that Cheslyn Hay is highly accessible by public bus services, including those along Wolverhampton Road.”

Para 26.45: “…With appropriate ‘refreshments’ the Local Planning Authority expects to use its suite of studies for its Deposit Draft Plan to inform its Core Strategy and other DPDS. In terms of peak hour public transport accessibility Cheslyn Hay is in equal top place with Great Wyrley and Bilbrook and day time services are also good.”

Para 26.46: “…On the basis of its ‘sustainability credentials’, the appeal site was considered suitable for inclusion in the list of 7 sites identified in Policy H1 of the abandoned deposit draft Local Plan intended to make good the shortfall in the Structure Plan housing requirement to 2011. That Local Plan is abandoned but if there is to be new housing in South Staffordshire then Cheslyn Hay/Great Wyrley would appear to be at or very near the top of locations on sustainability grounds. “

Refer to initial September 2019 submission – Appendix 8.

In summary:

Cheslyn Hay. In this consultation response, we have evidenced that Cheslyn Hay and our promoted site (SHELLA site ref 116, 131 and adjacent blue land (Appendix 1 initial September submission) is the most sustainable location in South Staffordshire and is at the top of all locations.

 Cheslyn Hay/Great Wryley is the only Tier 1 settlement within a Town Centre Catchment Area (Cannock) accessing a comprehensive range of shops, leisure, restaurants, food superstores, other services and facilities in the commercial and retail sectors with significant retail employment opportunities including the new McArthur Glenn retail designer outlet;  Tier 1 settlements have the greatest access to employment and services and facilities and have the only access to a train Station;  Tier 2 settlements reflect the lack of rail access (no train Station) and lesser levels of employment access;  Cheslyn Hay has the shortest journey time by bus and rail to a Hospital;  Cheslyn Hay is in the most sustainable location with the shortest journey time to access the range of facilities and services in Cannock Town Centre and with direct access to employment opportunities by rail or bus to Cannock, Bloxwich, Walsall, Birmingham and Wolverhampton;  Due to its rural location, car use in South Staffordshire is above the national average. Cheslyn Hay is not in a rural area and other modes of sustainable travel are available using the bus network and the Chase Line commuter railway in this promoted location for the short journey into Cannock Town Centre using sustainable public transport and for the short journey into Birmingham, the UK’s second city connecting with the national rail network;  The rail network provides sustainable travel which is available to all members of society of all age groups both able bodied people and those that are less mobile many of whom may not have access to a car connecting with the NEC, Airport and UK cities;  Peak journeys into Birmingham City Centre made by rail are predicted to grow by 49% to 2033 and a 114% by 2043;  Delivery of transport infrastructure is fundamental to creating the right conditions for growth in new jobs and homes. Cheslyn Hay is a designated employment area;  The new Northern Motorway Link Road will provide ‘the highest benefit to the local economy’ (Source Highways England) it is just 750m, 0.75km from the promoted site (M6 J11);  The ‘vitally important route into Birmingham’ the recently electrified Chase commuter line 2018 with new electric train services May 2019 will give rise to considerable economic benefits for the West Midlands area.(Source Staffordshire County Council’s draft Rail Strategy 2016);  Cheslyn Hay and the promoted site located within a designated employment area (para 13.3.1 Sustainability Appraisal) are also located ‘in a Regionally Significant and attractive location for National and International Investment’; (Source West Midlands Strategic Employment Study 2015);  The accessibility to public transport and particularly to the rail network ‘is a particularly important consideration’ within the wider sustainability of different development options (Source GBHMA Strategic Growth Study);  NPPF paras 122 (c) & 138 require development to promote sustainable travel modes and to give first consideration to land that is brownfield and/or well served by public transport. Cheslyn Hay and the promoted site is exceptionally well served by public transport with excellent transport services, with headroom capacity for growth that must be maximised;  The Planning Inspector’s Decision and Statement of Common Ground in 2006 confirms that Cheslyn Hay is at or very nearly at the top of sustainable locations in South Staffordshire. Initial September submission Appendix 8;  The evidence provided to the Council in this consultation response is that Cheslyn Hay is the most sustainable location in South Staffordshire and the IDP must be updated so it does not misinform the other documents relied on by the Council. Currently the Plan is unsound;  Cheslyn Hay and the promoted site has access to shopping facilities, educational facilities and employment opportunities all accessible by Active Travel (Walking and Cycling) and by Sustainable Travel as explained in detail within the initial September 2019 submission;  Allocating the promoted site to achieve housing growth is supportive of the sustainability objectives to maximise of use existing public transport infrastructure and services where it exists. The Chase commuter line recently electrified, has the head room capacity for growth, along with the bus network within the Cannock Town Centre catchment area.

RESPONSE TO QUESTIONS POSED BY LOCAL PLAN SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION (2019)

Introduction

A meeting was held at South Staffordshire District Council’s offices on Monday 28 October 2019 with Kelly Harris, Ed Fox and Patrick Walker (all SSDC) to discuss D Morgan PLC’s promoted site in Cheslyn Hay (site 131, 116 and adjacent land – Appendix 1 of the September 2019 initial submission) provided to officers in advance of the Spatial Housing Strategy and Infrastructure Delivery (SHSID) Consultation period 17 October 2019 – 12 December 2019.

Officers advised to re-submit the initial September submission as part of this consultation process and it is appended to this consultation response.

D Morgan PLC wishes to work with the Council to bring forward its promoted site in an exceptionally sustainable location for development and invites officers to continue the ongoing dialogue so that the Company may provide any additional information that officer’s may require.

In attendance at the meeting on behalf of D Morgan PLC were: Ian Bryne (D Morgan PLC), Gareth Glennon and Sarah Lowe (Peacock + Smith).

The initial submission was made to the Council in September 2019 and officers confirmed at the meeting that the initial submission had been received and reviewed.

The subsequent meeting and discussion focused around our client’s promoted site (131, 116 and adjacent land) in Cheslyn Hay, which has been identified as a sustainable Tier 1 settlement in the SHSID. It was discussed that this is consistent with an Inspector’s Decision and the Council’s Statement of Common Ground relating to an appeal decision in 2006 (Appendix 8 of the initial submission) on part of our client’s site.

However, Officers pointed out that, ‘the Council has reviewed Local Plan representations received to date and the emerging evidence to arrive at an infrastructure led strategy. This seeks to locate growth in locations that can maximise existing infrastructure provision as well as provide new infrastructure where known deficits have been identified’ . In terms of the SHSID consultation we have evidenced in this consultation response the existing infrastructure on pages, 2 3,4,5,6,7,8, 9, 10, 11 and 12 and in the initial September 2019 submission (which forms part of this consultation response) which also evidences that the promoted site is not disassociated from the host settlement Cheslyn Hay.

Cheslyn Hay and D Morgan PLC’s promoted site (Appendix 1 of the 2019 initial September submission) benefits from exceptional public transport infrastructure with excellent services including the Chase Line, ‘a vitally important route into Birmingham’ which evidences that it is exceptionally well served by public transport and is the most sustainable Tier 1 settlement in South Staffordshire. . Landywood train Station uniquely is the only Station in South Staffordshire. This consultation response provides the evidence base.

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NPPF para 138 confirms that where it has been concluded it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously- developed and/or which is well-served by public transport.

Following the 28 October meeting an email dated 01 November 2019 appended to this consultation response was sent to officers identifying the significant deficiency and flaw in the current IDP document, which makes it unsound, because it does not identify/recognize the recent public sector investment of £110m to complete the electrification of the Chase Line Rail corridor completed 2018 and the sustainability benefits of zero emission travel with faster more frequent train services which commenced in May 2019. The IDP states that the electrification is still to take place. For this reason, the IDP is out of date.

This consultation response is a consequence of our meeting and discussion with officers. The consultation response includes our review of the Local Plan documents that are available for consultation. All evidenced base documents have been reviewed and quoted where relevant to assist in answering the 10 questions posed by the Council.

The Infrastructure Delivery Plan (IDP) is a key document that informs the Local Plan. It is a ‘live document’ that will be updated regularly as new information is provided by infrastructure providers and developers, as options for growth are refined through the Local Plan (para 2.1). Our consultation response is part of the SHSID consultation process and will assist the Council to update the IDP which in its present iteration is deficient, flawed and unsound and which misinforms the SHSID.

Consultation on the IDP with infrastructure and service providers, developers, residents and other stakeholders will take place alongside consultation on the various iterations of the Local Plan to ensure the IDP reflects the most up to date situation from the infrastructure providers’ perspective (para 2.5).

D Morgan PLC reiterates that it wishes to maintain the ongoing dialogue with officers including consultation on the ‘live’ IDP alongside consultation of the Local Plan. It is requested that officers communicate the details of any further consultation processes including any new iterations on the IDP to Peacock + Smith.

Para 2.1 of the IDP states that working with providers is essential to understand the cost, source of funding, timescales and responsibilities for delivery of required infrastructure. By working with providers the Council will be able to establish inter alia the locations where existing infrastructure has head room capacity to accommodate additional growth and the level of growth that would represent a tipping point.

This is why the IDP is deficient and flawed because Cheslyn Hay and Great Wyrley which benefit from the significant £110m public sector investment in the electrification of the Chase Line, which has been completed and which is operational with head room capacity to accommodate additional growth has been overlooked by virtue of the housing distribution in the SHSID.

This consultation response evidences that this recently completed electrification of the Chase Line with existing head room capacity for growth serving Cheslyn Hay and D Morgan PLC’s

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promoted site from Landywood Station, is well served by public transport and is ideally situated to accommodate housing growth. The Council is actively promoting Walking and Cycling. These modes of Active Travel are available from our client’s promoted site to Landywood railway Station (refer to Appendix 4 of the initial September submission) as an alternative to the private car particularly for short journeys. The promoted site is within 1.6km of Landywood Station, well within the 2km distance used by the Council to walk to railway Stations and for this reason is highly sustainable by virtue of new reisdents being able to benefit from Active Travel, from the promoted site to Landywood Station all of which creates zero emissions.

Para 2.8 confirms that Appendix B sets out infrastructure concerns and that whilst not in infrastructure providers current plans – have been raised by local Members or residents, and therefore are being investigated further with the relevant provider and the outcomes of the discussions are reflected in the table.

As such infrastructure is not in current providers plans and is being investigated further, there is no evidence available to scrutinise or challenge whether or not any such infrastructure is capable of being viable and delivered or will ever be included in any future plans by the infrastructure providers. It is untenable to proceed with housing growth in areas where infrastructure is not planned and may never happen, whereas in stark contrast the public sector has already invested £110m in the electrification of the Chase Line ‘a vitally important route into Birmingham’ which has been completed. It is now operational with new electric train services with additional headroom capacity for growth.

Para 2.18 of the IDP (which is deficient and flawed for the reason explained in this response) confirms that once preferred sites are identified, it is likely that more specific infrastructure requirements will emerge. Often emphasis will be placed on the site promoter to demonstrate that the required infrastructure can be achieved and that their site is deliverable.

The site promoter, D Morgan PLC has demonstrated through its exceptionally detailed initial September submission and in this consultation response that the necessary infrastructure already exists and can be used and has the headroom capacity to accommodate the additional growth and that its promoted site is deliverable and is well served by public transport.

At para 3.1 this is further explained with the IDP commenting that delivering infrastructure can be very challenging due to competing pressures and the often high cost associated with projects. With public sector resources being limited, there is a need for private sector input to deliver infrastructure.

It must follow that where public sector funding is made available to deliver sustainable public transport (electrification of the Chase Line with new electric trains at a cost to the public purse of £110m) that such public transport must then be used and maximized including benefitting from more environmentally friendly journeys with zero emissions travel.

The NPPF is clear at para 138 that sites which are brownfield and/or well served by public transport must be given first consideration when looking at Green Belt releases. Sites which are not brownfield and not well-served by public transport are not the first consideration.

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Para 5.2 explains the Council’s strategy is the desire to see growth that does not put a strain on existing infrastructure and where possible delivers new infrastructure benefits. Such new infrastructure benefits costing £110m have recently been delivered on the Chase Line and should now be maximized.

The Council’s Strategy can be achieved via our client’s site in Cheslyn Hay. Significant new public transport infrastructure with head room capacity for growth has been delivered by the public sector in South Staffordshire in 2018 with £110m investment in completion of the electrification of the Chase railway Line that will provide the growth that does not put a strain on existing infrastructure, which the Council’s strategy seeks to deliver.

The Council’s Strategy not to put a strain on existing infrastructure can be achieved with significantly increased headroom capacity with new electric more frequent train services introduced May 2019. This public sector investment to achieve growth on this ‘vitally important route into Birmingham’ with resources being limited has created significant headroom capacity for growth. This will not put any strain on the existing recently completed Chase Line infrastructure because it has had £110m of public funds invested in it to provide for the increased capacity and growth which the Council seeks.

QUESTION 1: Do you agree that the evidence base used to inform Spatial Housing Options is robust and proportionate? If not, what else should we consider?

D Morgan PLC are strongly of the view that the current evidence base used to inform the Spatial Housing options is not robust as at least two of the evidence-based documents are deficient and fundamentally flawed, they are silent on the completion of the public sector £110m investment in electrification of the Chase Line significantly increasing head room capacity for the growth which the Council seeks, which electrification was completed during 2018 and which commenced new zero emission electric train services May 2019 which are faster and more frequent (and with longer trains) to facilitate the growth which the public sector investment and the Council seeks to achieve.

 The Infrastrastructure Delivery Plan is one such document.

The Infrastructure Delivery Plan (2019) was published as part of the October 2019 consultation, however it is deficient and fundamentally flawed as it does not reflect the completed public sector investment and completion of the Chase Line infrastructure service provision as an important commuter line within the West Midlands area.

The IDP should consider and recognise Staffordshire County Council’s Draft Rail Strategy (2016) which notes that the electrification of the Chase railway line will give rise to significant economic benefits for the West Midlands area. The updated IDP must inform the SHSID to maximise these economic benefits.

We do however acknowledge that the Council consider the IDP to be ‘a live document’ that will be updated regularly as new information is provided.

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As the Council acknowledges at para 2.1, the IDP (2019) is a ‘live document’ that will be updated regularly as new information is provided by infrastructure providers and developers and as options for growth are refined. D Morgan PLC wishes to fully engage with the Council in this respect and it has provided this fully detailed and comprehensive consultation response to inform the evidence base, to make sure it is up to date.

It is hoped that this response as part of the Council’s consultation will inform the IDP so that it can be updated to reflect the reality of the £110m investment of public money in the public transport system which completed the electrication of the Chase Line in 2018 to provide faster, more frequent electric train services May 2019 to facilitate the growth that the Council seeks, in maximizing the use of existing infrastructure.

The IDP 2019 is deficient because it does not capture the significant investment costing £110M and improvements to facilitate growth that have been delivered to the Chase railway line. Appendix A - Baseline infrastructure projects only shows ‘electrification of the Walsall to Rugeley line’ (the Chase Line) as being “programmed with funding available”. This funding has been spent and invested and the programme completed but the IDP does not capture this.

The Rural Services and Facilities Audit 2019 at para 2.3 states that the NPPF emphasises the following matters:  Maximising the opportunities to use existing and proposed transport infrastructure,  Limiting the need to travel, offering a genuine choice of transport modes and maximising sustainable transport solutions

The IDP in its current iteration fails to maximise the sustainable transport solution delivered by public sector investment with electrification of the Chase Line with new electric trains and fails to maximise the significant economic benefits, because it is silent on the electrification of the Chase Line completed in 2018 with new faster, more frequent electric train services, May 2019. This silence is inconceivable.

The operationally completed electrification of the line has not been identified by the Council as being operationally completed and the reality is that the £110m public sector investment in electrification (providing zero emissions sustainable train travel with significant head room capacity for growth) is operational but development and electrification of the Chase Line infrastructure and services have not informed the existing IDP in its current iteration and consequently the IDP has not accurately informed the Council’s Spatial Housing Strategy and Infrastructure Delivery Strategy (2019) which has failed to have regard to ‘where existing infrastructure has head room capacity to accommodate additional growth’ (Para 2.1 of the IDP). This is highly relevant to the Local Plan Spatial Housing Strategy and Infrastructure Delivery consultation in terms of where development must be located to meet the Governments policy to ensure planning achieves sustainable development.

This is also highly relevant to Green Belt release and para 138 of the NPPF which requires first consideration to be given to brownfield sites and or those well served by public transport.

For the IDP to remain silent on the exceptional rail infrastructure that now exists because of £110m public sector investment in the electrification of the Chase Line (completed 2018) and to remain silent on the excellent public transport service with faster zero emissions sustainable

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train travel (improving air quality) which commenced May 2019 potentially will misinform the release of Green Belt land to which first consideration must be locations which are brownfield/ and or well served by public transport.

The Greater Birmingham Housing Market Area – Strategic Growth Study states:

(1.69) For strategic development, the accessibility to public transport and particularly to the rail network, is a particularly important consideration within the wider sustainability of different development options.

Landywood Railway Station is unique because it is the only Station in South Staffordshire situated on the Chase Line, ‘a vitally important route into Birmingham’. The £110m public sector investment has resulted in longer platforms at Landywood Station to accommodate longer trains, therefore significantly increasing passenger capacity to accommodate growth. New longer electric trains, commenced services in May 2019, with improved journey times and increased service frequencies and this combination has significantly increased Passenger Capacity for future growth. This passenger capacity is now available and should be maximised.

The significant public sector investment in the Chase Line has significantly improved the railway links from Cheslyn Hay to Cannock and Rugeley to the north, and towards Bloxwich/Walsall and Birmingham New Street to the south. Para 10.13.1 of the Sustainability Appraisal stresses that the majority of residents living within South Staffordshire commute out of the District with 38% of all peak am journeys into Birmingham City Centre Area now made by rail with this figure predicted to grow by 49% from 2013 to 2033 (to around 60%).

As Cheslyn Hay uniquely in South Staffordshire is the only railway Station on the Chase Line, this provides South Staffordshire residents with exceptional access into the Birmingham City Centre area and accessing out-of-district employment opportunities. The associated benefits of having a recently electrified line with significantly increased passenger capacity which is now available, must be identified in the evidence base, and consideration given to focusing growth at/near such a public transport system and location in order to reduce private car use and lead to wider sustainability benefits such as lower CO2 emissions, quieter trains more frequent trains, and attract new jobs to improve the economic performance of the area.

 The Sustainability Appraisal is the second document

This sustainability appraisal is considered to be deficient and fundamentally flawed. Again, this has no mention of the recently electrified Chase Line Rail Corridor, with its new electric train services which commenced May 2019.

Lepos state in the ‘about this report & notes for our readers’ that:

“This Spatial Housing Strategy and Infrastructure Delivery SA Report is based on the best available information, including that provided to Lepus by the Council and information that is publicly available. No attempt to verify these secondary sources has been made and they have been assumed to be accurate as published.”

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This untested and ambigious approach is reflected in para 2.18 of the IDP which relies on more specific infrastructure requirements (and the omission of existing infrastructure, i.e the Chase railway line completion of electrification) to emerge as part of this consultation process.

As this Sustainability Appraisal document is a key piece of the Local Plan’s soundness, to have such a material consideration (Chase Line electrification with zero emission sustainable faster, frequent electric train services with head room capacity for growth) absent from the Sustainability Appraisal is wholly unacceptable and has far reaching consequences for the soundness of the current Local Plan which uses information that has not been verified and which is assumed to be accurate but which we have evidenced is out of date.

To continue to remain silent on the public sector investment in the electrification of the Chase Line with its exceptional infrastructure with excellent new train services would put the Council in conflict with the Inspectorate Local Examination Reports (in particular those concerning Leeds (A Thickett) and Cambridgeshire and South Cambridgeshire (L Graham) as outlined at para 2.23 of the South Staffordshire Green Belt Study 2019.

In conclusion, for the reasons set out above the evidence base used is out of date, it is deficient and fundamentally flawed and cannot therefore be considered to be robust. This subsequently results in the SHSID document not being sound.

The Council need to have regard to Staffordshire County Council’s Rail Strategy (2016) and the considerable economic benefits that the electrification of the Chase Line would bring. As this electrification has been completed, the economic benefits and head room capacity for growth must now be maximized and addressed through the Local Plan.

In addition, the Council must re-consider sites which it previousy considered to be disassociated from a settlement in light of additional evidence provided by a site promoter. With regard to the disassociated point, para 5.8 of the SHELLA confirms that some sites which are disassociated from a settlement… will now be subject to more detailed investigation, to assess their capacity to provide deliverable/developable housing and employment sites through the Local Plan review. Footnote 4 on page 14 confirms that on a case by case basis, it may be appropriate to consider a site not directly adjoining a development boundary as a ’potentially suitable extension to a village/urban area where the site is a short distance from the host settlement and a legible pedestrian route and means of access to the host settlement can be demonstrated by the site promoter’.

QUESTION 2: Do you agree that taking account of housing land supply from the start of the new plan period (1 April 2018) is the correct approach?

D Morgan PLC does not agree with this approach.

It is considered that a more robust approach to dealing with the housing land supply would be to take the most up to date position available and review this on an ongoing basis having regard to permissions and completions and the most up to date evidence which would demonstrate if a site continues to be available and deliverable and if it is in the most sustainable location given the emergence of other sustainable sites during the current consultation and review of the Local Plan including updating the out of date IDP.

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Using 1 April 2018 as the starting point could potentially result in the Council being unable to correctly identify the most up to date housing land position as some permissions that were extant on 1 April 2018 may now have lapsed, or not built out in accordance with the approved permission or will be in less sustainable locations compared to other newly promoted sites.

Using 1 April 2018 as the starting point would also prejudice the updating of the current deficient and flawed IDP and evidence base.

QUESTION 3: Do you agree that all Safeguarded Land identified in the SAD should be released as a priority and should be delivered at an average density of 35 dwelling per hectare?

No, D Morgan PLC disagrees with this priority approach.

As a result of the Local Plan Review including updating the out of date IDP, Safeguarded Land identified as part of the Site Allocations Document needs to be reconsidered alongside newly promoted sites to ensure that the principles of sustainable development are reviewed across all sites using an up to date IDP and evidence base.

Since the Site Allocations Document was adopted (11 September 2018), the Council have commissioned new evidence. This evidence is the most up-to-date evidence available, with the exception of the IDP, which is yet to be updated for the reasons explained above.

The Framework is clear that the purpose of the planning system is to contribute to the achievement of sustainable development. To simply release all Safeguarded Land infers that these are the most suitable and sustainable housing sites available. However, since the adoption of the SAD, a number of sites which were not previously available and or considered suitable (or considered to be available due to the lack of landowner participation or for any other reason ) may now be available and suitable by reason of additional evidence provided to the Council and may now be the most sustainable locations.

Furthermore, factors such as the public sector investment in the electrification of the Chase railway Line (completed during 2018 with new faster and more frequent electric train services introduced May 2019) need to be taken into account in accordance with para 138 of the NPPF to give first consideration to sites well served by public transport which are currently designated as Green Belt and this must be factored into identifying the sustainable potential of all housing sites as to whether or not they are well served by public transport.

This significant public transport investment of £110m and all the associated public transport benefits arising from it including significant head room capacity to provide for the growth that the Council seeks will have a strong bearing on where houses must be located to meet the Government’s policy requirement to contribute to the achievement of sustainable development including achieving reduced Co2 emissions.

Electric train travel produces zero emissions, improving air quality and significant weight must be given to this in carrying out the review of all land including Safeguarded land and the convenience of accessing such sustainable and exceptional transport infrastructure with excellent service provision.

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QUESTION 4: Are there any other options we should consider?

Yes, Cheslyn Hay and site 131, 116 and adjacent land promoted by D Morgan PLC as detailed in the initial September 2019 submission, which is in a regionally significant and attractive location for national and international investment well served by public transport including bus and rail is an option that must be considered first in respect of Green Belt release as stipulated by paragraph 138 of the NPPF. Not to do so would be contrary to Government Policy concerning Green Belt release.

Not to do so would also be contrary to the evidence contained in the Rural Services and Facilities Audit contained at para 2.3, which relates to the emphasis of the NPPF to:

 Maximising the opportunities to use existing and proposed transport infrastructure,  Limiting the need to travel, offering a genuine choice of transport modes and maximising sustainable transport solutions

Not to do so would also be contrary to para 2.1 of the IDP which states that the Council will work with providers to establish locations where existing infrastructure has head room capacity to accommodate additional growth.

D Morgan PLC reiterates that it wishes to work with the Council and maintain the ongoing dialogue with officers including consultation on the ‘live’ IDP alongside consultation of the Local Plan. It is requested that officers communicate the details of any further consultation processes including communicating the detail of any new iterations on the IDP to Peacock + Smith as part of a working relationship.

The current Spatial Housing options are based on an unsound, deficient and fundamentally flawed IDP. In its current form the IDP is out of date. It has no regard whatsoever to the significant public transport benefits arising from the recently completed Chase Line electrification project 2018, with new faster more frequent electric train services May 2019.

Faster more frequent electric train services, which are also much longer (because platform lengths have been extended) with significantly increased headroom for growth in passenger travel, were very recently introduced in May 2019 providing sustainable public transport with zero emissions as a result of the £110m investment from the public purse in the Chase railway Line. This available clean and green zero emission travel – improving air quality using electrified public transport infrastructure providing zero emissions travel, is highly sustainable, but is not recognised in the out of date IDP. This potentially misinforms the Council as to the distribution of housing well served by public transport and we propose that this should be rectified in the interactive IDP which is a ‘live document’ to accurately inform the SHSID including taking account of the pedestrian access providing zero emissions Walking and Cycling by Active Travel from the promoted site to Landywood Station which is a unique opportunity. There are no other railway Stations on the Chase Line in South Staffordshire.

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Staffordshire County Council’s draft Rail Strategy (2016) notes that the Chase Line’s electrification will result in Station upgrades and longer platforms including in reduced journey times, giving rise to considerable economic benefits for the West Midlands area; increased frequencies of service (and additional flexibility in regard to stopping patterns); and, increased reliability of services, particularly where constraints or bottlenecks on the network are removed.

The significant benefits of electrification of the Chase Line are also set out in Network’s Rail’s Railway Upgrade Plan which explains: “This scheme, along with targeted line speed improvements will allow an all-day two trains per hour service to operate between Walsall and Rugeley improving capacity and overall journey times from stations on the route to Birmingham”.

This vitally important route into Birmingham has now been delivered at a cost to the public purse of £110m and is available for use with head room capacity for growth.

The proposed electrification of the line which is referred to in the out of date IDP (now completed with electric train services introduced May 2019) had also been subject to a number of parliamentary debates, which served to reinforce the vital importance of the Chase Line Electrification Scheme including for commuters into Birmingham.

Hansard (14 June 2012) Thousands of constituents use the line daily to commute to and from work, and at weekends it is a vitally important route into Birmingham and the surrounding areas for leisure trips. It was acknowledged that the electrification improvements will not only assist users of the line in reaching their destinations quicker, but it is also important in supporting efforts to bring new business to the area.

Within the Birmingham HMA 38% of all peak am journeys into Birmingham City Centre Area are now made by rail, this is predicted to grow by 49% from 2013 to 2033 (to around 60%) (Network Rail West Midlands and Chiltern Railway Study 2016)

This future growth will also benefit from zero emissions travel further improving air quality to achieve the Governments legally binding fifth carbon budget which says emissions must be reduced by 57% by 2032 compared to emission levels in 1990, and 100% reduction by 2050.

From our promoted housing site, Landywood Train Station is accessible by foot within a 1 mile (1.6 km) and journeys to Birmingham New Street via zero emissions trains are just 35 minutes. This is highly relevant given that 38% of South Staffordshire residents currently commute to Birmingham daily with this figure predicted to grow by 49% to 2033 (to around 60%).

The rail network provides sustainable travel which is available to all members of society of all age groups both able bodied people and those that are less mobile many of whom may not have access to a car. Landywood Station and its platform together with other Stations and platforms on the Chase Line have been improved and platforms lengthened not only to improve headroom capacity using longer faster electric trains but also to facilitate access via the use of ramps for use by wheel chairs and or prams and other appropriate measures to enable access to all members of society of all age groups, including those that are mobile or less mobile.

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The Council’s evidence base to support the SHSID contains a number of documents and notes:

The South Staffordshire Green Belt Study 2019

Paragraph 2.10 reproduces paragraph 138 of the NPPF which deals with Green Belt release and states:

“when drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy- making authorities should consider the consequences for sustainable development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and / or is well served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”

Paragraph 2.23 identifies a number of important Planning Inspectorate Local Plan Examination Reports which have informed Green Belt planning. These include:

 The Inspector’s report (A Thickett) to Leeds City Council (September 2014) emphasizes that Green Belt studies should be ‘fair, comprehensive, and consistent with the Core Strategy’s aim of directing development to the most sustainable locations’, i.e. Green Belt reviews should be ‘comprehensive’ rather than ‘selective’.  The Inspector’s letter (L Graham) to Cambridge City and South Cambridgeshire Councils (May 2015) emphasized that Green Belt studies should make clear ‘how the assessment of importance to Green Belt’ has been derived’ from assessments against the individual purposes of the Green Belt and highlighted the importance of revisions to Green Belt boundaries to ‘take account of the need to promote sustainable patterns of development, as required by paragraph 85 of the NPPF (even if) such an exercise would be carried out through the SEA/SA process’

Paragraphs 2.27 and 2.28 confirm that 80% of the South Staffordshire District is Green Belt and the District is at risk from ‘leapfrogging’ to sites immediately beyond the Green Belt boundary. This can result in unsustainable patterns of housing, public services or employment land. Parts of the settlements of Penkridge and Wheaton Aston lie just outside the northern boundary of the Green Belt, which makes them vulnerable to development pressures. i.e housing development in Penkridge and Wheaton Aston to satisfy the Greater Birmingham Housing Market Need would be as far away as it would be possible to be from the West Midlands Conurbation, by ‘leap frogging’ the Green Belt.

It would also be as far away as possible to be from the significant employment areas (West Midlands Strategic Growth Study 2015) accessed from the M54 motorway junctions 1 & 2 and would require an increased use of the private motor vehicle, increased travel by car increasing

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emissions resulting in unsustainable patterns of housing in Penkridge and Wheaton Aston and in any area north of the Green Belt.

Paragraph 3.37 outlines that the South Staffordshire Historic Environment Character Assessment identifies the settlements of Penkridge, Kinver and Brewood as historic towns which were established as market towns during the medieval period, but the Green Belt Study does not identify any historic towns within South Staffordshire for the Purpose 4 assessment.

This is fundamentally wrong. This approach is deficient and flawed as the Green Belt study fails to assess the impacts of new development on the setting and special character of these identified historic towns, which includes Penkridge, Kinver and Brewood.

Paragraph 5.17 provides commentary on the assessment of contribution to Green Belt Purpose 2 and confirms that only 1.5km separate Bloxwich from Landywood, at the southern end of Great Wyrley. This gap between towns is therefore considered fragile and no land is sufficiently urbanized to make less than a strong contribution to Purpose 2.

Paragraph 7.10 confirms that consideration of the harm to the Green Belt that could result from the release of land for development is an essential part of establishing the exceptional circumstances for making alterations to Green Belt boundaries. However, there are other important factors that need to be considered, most notably sustainability and viability issues.

Paragraph 8.3 states A common interpretation of the policy position is that, where necessitated by development requirements, plans should identify the most sustainable locations for growth. This policy position should be maintained unless outweighed by adverse effects on the overall integrity of the Green Belt. The relatively poor performance of the land against Green Belt purposes is not, of itself, an exceptional circumstance that would justify release of the land from the Green Belt. Conversely, higher performing Green Belt may be appropriate for release where exceptional circumstances are demonstrated.

Refer to para 2.10 above plans should give first consideration to land which has been previously developed and / or is well served by public transport.

Commentary on Green Belt Study 2019

We fundamentally object to the Green Belt study in respect of the settlements of Penkridge, Kinver and Brewood which have not been assessed against Purpose 4 of the Green Belt (to safeguard the setting and special character of historic towns) as they are not identified in the Core Strategy as towns, but instead as villages. It is for this reason alone that they have not been assessed against Purpose 4.

Looking at paragraph 3.23 of the study, it is clear that Penkridge, Kinver and Brewood have been assessed against Purpose 2 (to prevent neighbouring towns from merging into one another) as ‘full account is therefore taken of the role that smaller settlements play in preventing the merging of ‘towns’.

As such, an inconsistent approach and assessment has been adopted in the study. Given that Penkridge, Kinver and Brewood are identified as ‘towns’ in the Historic Environment Character

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Assessment and that this document refers to the Historic Environment and the Purpose of Option 4 is ‘to preserve the setting and special character of historic towns’, it is inconceivable and wrong that they have not been assessed against Purpose 4.

This approach and assessment puts the Council in conflict with National Policy, legislation and Case Law, which seeks to protect Heritage Assets and Core Strategy Policy 2 which seeks to protect and enhance the natural and historic environment.

The Sustainability Appraisal of the South Staffordshire Local Plan Review

(E18) There are four railway stations located within South Staffordshire including Landywood Railway Station. As a result, development proposals located in inter alia Cheslyn Hay/ Great Wyrley would be expected to locate new residents in an area with excellent access to rail services to travel around the District and into the surrounding towns and cities.

Many new residents located towards Tier 1 and 2 settlements (Tier 2 settlements do not have railway stations) would also be expected to have good access to the local bus network.

Tier 2 Settlements do not enjoy a good bus network or service and do not have railway stations and for these reasons Tier 2 settlements are less sustainable than Tier 1 Settlements.

As a result, Spatial Options D, E, F and G would be expected to have a minor positive impact on transport and accessibility whereas Spatial Options A, B and C could potentially have a minor negative impact on transport and accessibility due to their more rural location. Only the Tier 1 settlements have railway stations. The Greater Birmingham Housing Market Area Study at para 1.69 makes it clear that for Strategic Development:

For this reason any development identified in urban extensions which do not contain railway Stations are clearly not in the most sustainable locations.

(E19) There are a good range of Primary and Secondary Schools located within South Staffordshire. Secondary schools are primarily located within the Tier 1 settlements, including at Cheslyn Hay/ Great Wyrley. As all options would direct some new residents to these locations, a positive impact in regard to access to education would be expected.

(E20) It is noted that the majority of residents living within South Staffordshire commute out of the District to employment opportunities within Wolverhampton, Dudley, Stafford and Birmingham. The towns of inter alia Cheslyn Hay/ Great Wryley have a railway Station which would be expected to provide residents with good access to out-of-District employment opportunities.

(10.11.1) There are four railway stations located within South Staffordshire; Penkridge, Bilbrook, Codsall and Landywood Railway Stations. As a result, development proposals located in Penkridge, Bilbrook/ Codsall and Cheslyn Hay/ Great Wyrley would be expected to

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locate new residents in an area with excellent access to rail services to travel around the District and into the surrounding towns and cities. Many new residents located towards Tier 1 and 2 settlements would also be expected to have good access to the local bus network.

This expectation for Tier 2 settlements in reality does not exist as the Rural Services and Facilities Audit 2019 (table under para 4.7) simply states that there is a degree of access to facilities outside the settlement via public transport. Tier 2 settlements compare poorly to Tier 1 settlements. That is why the former Tier 1 settlements Perton, Wombourne, Briewood and Kniver which do not have railway Stations have been reclassified and downgraded to Tier 2 settlements as they do not have access to railway Stations and have lesser levels of access to employment facilities. It is acknowledged by the Council that the District is generally poorly served by public transport.

(10.13.1) It is noted that the majority of residents living within South Staffordshire commute to out of the District to employment opportunities within Wolverhampton, Dudley, Stafford and Birmingham... Cheslyn Hay/ Great Wryley have [a] railway station which would be expected to provide residents with good access to out-of-District employment opportunities.

(10.14.2) notes that it is difficult to differentiate between the sustainability performance of spatial options D, E, F and G as the proposed development under all of these options would be likely to result in the same or similar sustainability impacts…. However, Spatial Option G has been idenfitied as the best-performing Option, as the proposed developmet would be likely to result in the greatest positive impacts in terms of sustainability, in particular in regard to acess to education and employment.

“For Strategic development, the accessibility to public transport and particularly to the rail network is a particularly important consideration within the wider sustainability of different development options” Source the Greater Birmingham Housing Market Study para 1.69.

Commentary on the Sustainability Appraisal

The Sustainability Appraisal is very clear that Cheslyn Hay/Great Wryley is a Tier 1 settlement with access to Primary and Secondary schools and is a designated employment area set out a para 3.13.1 of the Sustainability Appraisal. Also, it is very clear that Cheslyn Hay/Great Wryley uniquely within South Staffordshire on the Chase Line, ‘a vitally important route into Birmingham’ has a railway Station (Landywood) which would provide residents with excellent access to out-of-district employment opportunities as the majority of residents living in South Staffordshire commute out of the District.

Despite this, Spatial Housing Option G does not allocate any new housing growth to Cheslyn Hay/Great Wyrley but instead focuses new allocations in Penkridge (a historic market town), Codsall/Billbrook (Tier 1 settlement), Wombourne (Tier 2 settlement), Brewood (Tier 2 settlement and a historic market town), Kinver (Tier 2 settlement and a historic market town), Perton (Tier 2 settlement).

Option G also proposes an employment-led urban extension around ROF Featherstone (Tier 3 Settlement), which is an existing Tier 3 settlement with 13.5% of the District’s total housing requirement – 1,194 dwellings at the location). This is not deliverable unless significant

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speculative new road infrastructure is built with a choice of routes yet to be determined which is ambigious and uncertain and also has no railway station.

Another proposed urban extension is to an area to the south of Essington which is an existing Tier 3 settlement – essentially the northern area of Walsall and north of Wolverhampton (13.5% of the total housing – 1,194 dwellings). Again with no railway Station.

Another proposed urban extension is to the eastern boundary of South Staffordshire (western edge of black country) (8% of the total housing – 752 houses). Again with no railway Station and in a sensitive part of the Green Belt because it is the western edge of the Black Country which hitherto has restricted the urban sprawl from expanding beyond the Black Country into the rural areas of South Staffordshire. Para 9.7.2 of the Sustainability appraisal confirms that this ‘is likely to be located on greenfield land’.

A smaller urban extension is proposed to the south east of Stafford where 2% of the housing growth would be located (circa 177 houses). This is in area that would essentially result in the sprawl of Stafford and would not relate to any existing settlements in South Staffordshire.

In conclusion on this point, only Codsall/Bilbrook, Cheslyn Hay /Great Wryley and Penkridge are Tier 1 settlements and have railway Stations to which sustainable development should be directed subject to no adverse impact on the setting and special character of the historic market town of Penkridge or the well preserved Conservation Area of Codsall.

Cheslyn Hay/Great Wyrley uniquely are the only settlements within South Staffordshire that have access to the recently electrified Chase Line with zero emissions faster and more frequent trains with newly created head room capacity to assist in meeting the Council’s aspirations for growth in this Regionally Significant and Attractive location for National and International Investment.

Cheslyn Hay/Great Wyrley has the shortest travel journeys to Hospitals and access to the greatest range of facilicies and services and retail employment opportunites within Cannock Town Centre whereas the other Tier 1 settlements do not, they are not within the Cannock Town Centre catchment area.

In respect of the areas of search for urban extensions, with the exception of a limited area around Bloxwich (the next Station on the Chase Line north is Landywood Station) there are no train Stations. Furthermore, there are no guarantees that bus stops and services exist in these areas with only assumptions that stops and services would be provided. As such these locations, especially Green Belt sites cannot demonstrate that they meet the requirements of paragraph 138 of the NPPF and the wider sustainability requirements of the Framework.

For example there are no Tier 1 settlements in any of the urban extension locations proposed.

Given the acknowledged sustainability benefits of Cheslyn Hay and our promoted site (initial September submission Appendix 8 and this consultation response December 2019) it is inconceivable that housing is being focused around less sustainable areas in conflict with the NPPF and in conflict with the evidence base including paras 1.67 and 1.69 of the GBHMA - Stategic Growth Study.

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The Greater Birmingham Housing Market Area – Strategic Growth Study

(1.67) The NPPF sets out that local planning authorities should seek opportunities to achieve sustainable development including net gains across each of the economic, social and environmental dimensions, and avoid significantly adverse impacts wherever possible.

The Infrastructure Delivery Plan (2019)

(1.3) The Council has reviewed Local Plan representations received to date and the emerging evidence to arrive at an Infrastructure led strategy. This seeks to locate growth in locations that can maximise existing infrastructure provision as well as provide new infrastructure where known deficits have been identified.

Public transport  With the exception of some of the larger villages, public transport in South Staffordshire is generally poor, with links between north and south of the district particularly lacking.

Rural Services and Facilities Audit 2019

(2.2) Key extracts from NPPF 2018 and Planning Practice Guidance (PPG) are highlighted:  Para 102 – promoting sustainable transport – transport issues should be considered from the earliest stages of plan-making… so opportunities from infrastructure are realised…  Para 103 - promoting sustainable transport – significant development should be focused on locations which are or can be made sustainable through limiting the need to travel and offering a choice of transport modes…  Para 104 - promoting sustainable transport – planning policies should support a mix of uses across an area, to minimise the length of journeys needed for employment, shopping, leisure, education…

(2.3) The NPPF emphasises the following matters:  Ensuring locations for housing growth are supported by employment uses and community facilities and services  Minimising journey lengths to employment, shopping, leisure, education and other activities  Maximising the opportunities to use existing and proposed transport infrastructure,  Limiting the need to travel, offering a genuine choice of transport modes and maximising sustainable transport solutions  Avoiding isolated rural development, identifying opportunities for villages or groups of villages to grow where this will support local services

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(3.15) Access to Employment – the study has measured public transport accessibility to employment opportunities. The assessment incorporates: the number of destinations that can be accessed within a 60min journey time; the disbenefits of travel in terms of journey time; origin point population; total jobs available at destination. A higher score demonstrates a greater level of access to and choice of employment opportunities.

(4.7) There are five Tier 1 villages Bilbrook, Codsall, Cheslyn Hay, Great Wyrley, Penkridge. These settlements typically have food stores, a wider range of services and facilities than other villages, a range of education establishments, access to a train station and good access to employment and wider facilities outside the village via public transport.

Conclusion.

As outlined in Appendix 8 of our initial September 2019 submission, the Inspector’s decision letter in respect of the planning appeal for housing at Campions Wood Quarry stated at paras 9.2, 9.29 and 26.46:

“(9.2) …. Numerous bus routes pass close the site with stops within convenient walking distance and it is proposed to provide the infrastructure to allow a bus service to pass through the site when development is substantially complete. Local linkages to other public transport intersections and to local services, employment and education are sufficiently convenient to encourage future residents to consider journeys by modes other than the private car. The proposal meets the sustainable development objectives set out in PPG 13. Statement of Common Ground agreed with South Staffordshire District Council.”

“(9.29)… It is agreed that Cheslyn Hay is highly accessible by public bus services, including those along Wolverhampton Road.”

(26.46)…On the basis of its ‘sustainability credentials’, the appeal site was considered suitable for inclusion in the list of 7 sites identified in Policy H1 of the abandoned deposit draft Local Plan intended to make good the shortfall in the Structure Plan housing requirement to 2011. That Local Plan is abandoned but if there is to be new housing in South Staffordshire then Cheslyn Hay/Great Wryley would appear to be at or very near the top of locations on sustainability grounds.”

The evidence base provided in this consultation response acknowledges that Cheslyn Hay/Great Wyrley was then and is now a sustainable Tier 1 settlement. Our promoted site with pedestrian access for able bodied and less mobile people to excellent train services at Landywood train station, excellent access to bus services along Wolverhampton Road and in Cheslyn Hay also benefits from excellent access to a Primary and Secondary school and Leisure Centre all sharing a site which is on the doorstep within 600m of the promoted site. Active Travel, Walking and Cycling which is a priority of the Council can be achieved from the site. Walking is a zero emissions activity as well as being important for health and wellbeing.

However, the Council’s proposed housing strategy does not seek to distribute any additional new housing growth to this most sustainable Tier 1 settlement. This is despite Cheslyn

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Hay/Great Wyrley being a Tier 1 settlement, being exceptionally well served by public transport (with £110m public sector investment in the electrification of the Chase Line) and being on the fringe of the urban area and within the Cannock Town Centre catchment area with access to the Town Centre, employment, facilities and services, access to the Cannock Chase Hospital near to the bus station in the Town Centre and access to the McArthur Glen Designer Outlet and near Cannock railway Station also providing access to the GBHMA using the recently electrified Chase Line that is ‘vitally important route into Birmingham’.

Cheslyn Hay within the Cannock Town Centre Catchment Area with all the connectivity benefits that result from this proximity, benefits from at least half hourly bus services to Cannock Town Centre, with journeys taking between 11 minutes and 23 minutes. There are 6 different bus services (refer to Cannock bus network map page 5) that access Cheslyn Hay offering residents a multiple choice, frequent and excellent bus service with head room capacity for growth. Penkridge a historic market town only has an hourly bus service to Cannock Town Centre with this journey taking circa 40 minutes. Codsall/Billbrook has an hourly bus service to Cannock Town Centre with journeys taking circa 2 hours.

Landywood Station (Cheslyn Hay/Great Wryley), provides access to a significant area of employment, Cannock Town Centre and the Cannock Chase Hospital and the soon to be opened McArthur Glenn Designer Outlet (see page 41 of the initial September submission) are a 3 minute train journey, compared to 59 minutes – 1hr 37 minutes from Penkeridge. From Codsall/Billbrook, Cannock Town Centre is circa 1hr 35 mins by train.

As outlined above, Landywood Station is located on the Chase Line and is uniquely placed as the only Station within South Staffordshire on the Chase Line. The line has recently been electrified at a cost to the public purse of some £110m. As a result of the electrification and associated Station improvements (providing new longer platforms with ramps for able and less mobile people to access new longer trains which are now operational), new zero emissions, quieter, more frequent, faster and longer trains (providing additional head room capacity for passengers) commenced service 2019.

With this significant public sector expenditure, invested in order to facilitate sustainable travel and growth and improve air quality, travel times and reliability available to all members of society and age groups, it is perplexing that no additional housing growth is planned in Cheslyn Hay to take advantage of this significant £110m public sector investment in existing upgraded rail infrastructure and services “to promote sustainable travel modes that limit future car use” (NPPF para 122 c).

The Sustainability Appraisal at para 10.9.1 (in respect of Spatial Housing Option G) confirms there are no NHS Hospitals with an A&E department located within South Staffordshire. County Hospital in Stafford, New Cross Hospital in Wolverhampton and Russell’s Hay Hospital in Dudley are listed as the nearest facilities. This is not the whole picture.

No mention is made of Walsall Manor Hospital with an A&E Department (which is 0.6 miles from Walsall train Station), which is just a short 13 minute train journey from Landywood Station. Nor is there any mention of Cannock Chase Hospital with a minor injuries unit on the

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door step (which is 0.7miles from Cannock train station) which is just a short 3 minute train journey from Landywood station. Furthermore, no mention is made of Birmingham Children’s Hospital the UK’s leading paedatric centre which is a 35 minute train journey from Landywood Station to Birmingham New Street which is a 0.6mile walk to the Children’s Hospital. All 3 Hospitals are accessible from the Chase Line by mobile and less mobile people of all ages.

In terms of the Sustainability Appraisal and para 10.9.1 the electrified Chase Line provides sustainable travel which is available to all members of society many of whom may not have access to a car. The Sustainability Appraisal must also take account of these three hospitals and access to them from Landywood Station. Para 10.9.1 goes on to state that a proportion of new residents (Spatial Housing Option G) would also be likely to be situated outside the sustainable travel distance to a GP surgery or Leisure Centre. In contrast, there are 2 GP surgerys and a Leisure Centre in Cheslyn Hay.

With this in mind, Cheslyn Hay (and in particular our client’s promoted site) is exceptionally well located to address these issues. As outlined above, Walsall Manor Hospital with its own A&E Department is just 0.6miles from Walsall train Station which is a 13 minute train journey from Landywood Station accessible by walking from our client’s site. Cheslyn Hay Leisure Centre on the same combined site as an Acadamy and Primary School is accessible by Walking from our client’s site as are the 2 GP surgeries.

In addition within Cheslyn Hay, there are 2 GP surgeries, High Street Surgery and The Nile Practice (High Street also) both are within a short walk of our clients site. Further detailed information including walking distances are included in our initial September submission. The exceptional access to and proximity of Cheslyn Hay/Great Wyrley to Hospitals by bus and rail is described above and evidenced below.

Whilst the Rural Services and Facilities Audit document (page 19 – see below) provides a colour coded pictoral Public Transport Access to Hospitals (Bus and Rail) Wednesday 08.00 to 10.00 hours, it does not provide a clear breakdown of journey times to reach the nearest Hospital by rail/bus. Our table below provides this clear breakdown and clarity based on the Council’s colour coded map of journey times.

Settlement Journey Time (mins) Penkridge 51-60 Codsall/Bilbrook 41-60 Cheslyn Hay/Great Wyrley 21-40 Wombourne 41-60 Perton 41-60

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By any measure, Cheslyn Hay/Great Wryley is clearly the shortest journey time.

The Sustainability Appraisal is deficient and flawed and is misleading by not taking into account the Chase railway Line and Landywood Station, which uniquely is the only Station in South Staffordshire accessing the Chase Line providing sustainable travel by train to three Hospitals not referred to in the Sustainability Appraisal. Cannock Chase Hospital with its minor injuries unit, Walsall Manor Hospital with it’s A&E Department and Birmingham Children’s Hospital the UK’s leading paedtric centre.

The evidence is that no account has been taken of the unique access provided by Landywood Station on the Chase Line to 3 important Hospitals all accessible using sustainable travel and within walking distance of Stations, accessible to all members of society and age groups with no dependency on the motorcar.

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It is also clear from the above produced Council map, that the best journey time by rail/bus to Hospitals referable to the colour coded journey times are only achievable from Cheslyn Hay/Great Wyrley. However, the Council’s preferred option G does not propose any additional growth to Cheslyn Hay. Cheslyn Hay/Great Wryley has excellent bus services as shown on page 5 of this consultation response. It also has excellenet rail services.

It is clear from the above, that Cheslyn Hay/Great Wyrley is in a highly sustainable location with the shortest travel times to Hospitals by bus and rail, which is unsurprising given its proximity to the existing conurbations of Cannock and Walsall.

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The Council’s preferred area of search for urban extensions do not have any railway Stations and are only assumed to provide bus stops and services and cannot therefore be described as being well served by public transport resulting in unsustainable transport patterns, greater reliance on the motor car with higher Co2 emissions and adverse impacts on air quality. Such a speculative approach is contrary to paragraph 138 of the NPPF which requires proposals to be brownfield and/or well served by public transport as the first consideration.

QUESTION 5: Do you agree that the 7 Spatial Housing Options set out above are appropriate options to consider? Are there any alternative options we have not considered?

No , we don’t agree that the seven Spatial Housing Options are appropriate to consider for the reasons given in this consultation response, which must be read in its entirety. In respect of alternative Options, we would refer you to our answer to question 4 and the entirety of this consultation response.

The IDP is out of date. It cannot reliably inform a Spatial Options Strategy whilst it is out of date. There needs to be an Option presented which incorporates an up-to-date and correct IDP, which focuses development on land which has access to Landywood Station using zero emissions electric trains providing increased capacity for growth available to all members of society and age groups with no dependency on the motor car which commenced services on 10 May 2019.

Our Client’s promoted site (SHELAA refs 131, 116 and additional land) is located within Cheslyn Hay/Great Wyrley which is ‘at the top or very near the top of locations on sustainability grounds’ (Appendix 8 paras 9.2, 9.29 and 26.46 initial September submission). In particular our client’s site is within the required 2km walking distance (zero emissions active travel) of Landywood Station and is therefore well served by sustainable public transport (NPPF 138) and it should be identified as a housing site in accordance with government policy relating to Green Belt release owing to the settlement’s proven Tier 1 sustainability, and the significant benefits set out above including being located within the Cannock Town Centre catchment area with its comprehensive services and Hospital. The sustainable transport benefits available to all members of society and age groups include access to Walsall Manor Hospital and Birmingham Children’s Hospital the UK’s leading paedatric facility which have arisen as a result of the recent £110m public sector investment in providing longer platforms with ramped access and in electrification of the Chase Line to provide exceptional public transport infrastructure and excellent services with head room capacity for growth.

In looking at the Spatial Housing Options, no regard has been had to the proximity of all nearby Hospitals and or A&E facilities, which are accessible by short sustainable train journeys using the electrified Chase Line as set out above. Using the recently electrified Chase Line with new electric train services May 2019 does provide sustainable travel as an alternative to the motorcar and our client’s promoted site (SHELLA refs 131, 116 and additional land) within Cheslyn Hay must now be considered as a spatial housing option which is in a highly sustainable location for all of the reasons explained in this consultation submission.

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QUESTION 6: Do you agree that Spatial Housing Option G is a robust approach to meet needs in the district and to make a contribution towards unmet needs in the GBHMA?

No, D Morgan PLC objects to Spatial Housing Option G as it is based on unsound and fundamentally flawed evidence used to inform Spatial Housing Option G, and all seven spatial Options (including Option G) fail to take account of the recently electrified Chase Line providing sustainable travel with Landywood Station available to all members of society and age groups uniquely being the only Station in South Staffordshire with access to the Chase Line.

The Council’s Sustainability Appraisal at paragraph 10.14.2 confirms that it is difficult to differentiate between the sustainability performance of Spatial Options D,E,F and G, as the proposed development under all of these Options would be likely to result in the same or similar sustainability impacts. Nevertheless, Spatial Option G has been selected as the preferred Option as it has ‘been identified as the best-performing option, as the proposed development would be likely to result in the greatest positive impacts in terms of sustainability, in particular in regard to access to education and employment.”

In respect of education and employment, page 44 of the SHSID confirms that this may deliver inter alia infrastructure opportunities in Codsall/Bilbrook (first school), north of Black Country (ROF Featherstone access road and potential rail link). There are no guarentess that such infrastructure opportunities will happen. Indeed the Council’s evidence base (IDP) at paras 2.17 confirm that a viability study is currently underway to test the viability of development proposals including the costs associated with the required infrastructure to deliver sites. The study will in broad terms, determine if the proposed infrastructure is feasible in financial terms and therefore whether the proposals and policies in the plan are deliverable. Para 3.1 of the IDP confirms that ‘Development will not be proposed through the Local Plan unless it has been robustly demonstrated that the development will provide or facilitate the necessary infrastructure.”

As such, given the huge uncertainties around what is actually feasible/viable/may or may not be delivered, the Council is unable to soundly adopt the position that Spatial Option G is the preferred Option and continue with this approach.

In addition, the IDP at para 9.7.2 confirms that the areas of search for urban extensions are likely to be on greenfield land. As these sites are in the Green Belt, they can only be considered for release once consideration has been given to sites which are brownfield and or well served by public transport.

The Council has demonstrated that it has had regard to alternative potential strategies, but we do not agree that they are all appropriate to consider or that it has been robustly demonstrated that any such development will provide or facilitate the necessary infrastructure.

All strategies that will meet the Council’s housing need requirement will require Green Belt release and the overriding priority is to give first consideration to brownfield land and or that which is well served by public transport (para 138 of the NPPF and para 2.10 of South Staffordshire Green Belt study 2019).

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Any spatial housing options which fail to comply with this (including Option G) are not appropriate and should not be considered ahead of any sites that are brownfield and or well served by public transport.

Spatial Option G is entirely speculative in respect of the urban extensions as no Areas of Search contain a railway Station and the availability of bus services (if any) is clearly stated to be an assumption. It cannot be robustly demonstrated that any Green Belt locations proposed to be released by Option G are well served by public transport.

There will be heavy reliance on the use of the motor car with a significant increase in emissions when South Staffordshire’s use of the motor car is already above the national average.

Spatial Housing Option G is stated to “focus growth on strategic sites that will deliver new or improved infrastructure, and in areas near to the source of unmet housing needs in the Black Country”.

Spatial Housing Option G does not however deliver a train Station to urban extensions.

Before any new or improved infrastructure is delivered the release of Green Belt land requires consideration to be given first to brownfield sites and or those well served by public transport. In this important respect use of existing public transport infrastructure that provides sustainable travel available to all members of society and age groups with no dependency on the motor car must be maximized first.

We have made the point elsewhere within this submission that the IDP is out of date and the recently electrified Chase Line rail infrastructure with its significant increase in capacity for growth with new electric zero emissions train travel is not included in the out of date IDP and therefore Option G is based on flawed and deficient information that must be updated and re- evaluated.

D Morgan PLC is concerned that by pursuing Option G, the most sustainable (“Tier 1”) settlements, such as Cheslyn Hay, which have a swathe of Tier 1 services and facilities with exceptional public transport infrastructure already in place including railway Station, excellent train services ‘on a vitally important route into Birmingham’, excellent bus services and excellent intermodal connections the use of which and the available headroom capacity that must be maximised, are not being allocated a proportionate amount of growth which reflects the exceptional level of sustainability and capacity that exists, providing access to people of all age groups and of all mobilities for short and longer journeys connecting with the National Rail Network. Landywood Station serving Cheslyn Hay is one Station along from Bloxwich North (a short 7 minute train journey) and is ideally located in close proximity to the West Midlands conurbation to satisfy the source of unmet housing need from Bloxwich/Walsall and the GBHMA.

It is understood that the entirely speculative developer contributions that may or may not arise from Option G would be put towards delivering a Primary School in Codsall/Bilbrook, a swimming pool in Penkridge and additional car parking at Brewood. Local Members have additionally been invited to highlight additional infrastructure concerns in their respective

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areas (para 2.8 of the IDP 2019). The Council has confirmed that development will not be proposed through the Local Plan unless it has been robustly demonstrated that the development will provide or facilitate the necessary infrastructure. In addition the Council should demonstrate that the infrastructure can be completed in an appropriate timeframe which supports the delivery of sites to be identified in the Local Plan.

By comparison Cheslyn Hay and the promoted site (SHELLA ref 131, 161 and additional land) has existing exceptional public transport infrastructure and excellent services with capacity that must be maximized and is well served by Schools and Leisure Facilities/Leisure Centre sharing the same complex within 600m Walking distance of the promoted site which are all guaranteed, as all of this exists as do the 2 GP surgeries also within Walking distance.

Additionally, if the Council are seeking developer contributions to fund infrastructure, the proposals must meet with the three Section 106 legal tests. The tests are:

a. necessary to make the development acceptable in planning terms b. directly related to the development; and c. fairly and reasonably related in scale and kind to the development.

Our client wishes to stress that the preparation of the Local Plan must be fully justified and robust. At present the evidence base is deficient and flawed and the Local Plan cannot therefore be robust.

Option G, as set out in Appendix 4 – Indicative Growth Tables, does not direct any further growth towards Cheslyn Hay, other than releasing previously identified Safeguarded Land. This is the only Tier 1 Settlement without any additional growth being allocated to it, on top of existing permissions, allocations and safeguarded land. Penkridge and Bilbrook/Codsall have approximately 500 additional units each proposed (1,000).

The NPPF is clear that sustainable development lies at the heart of plan-making. Tier 1 settlements are the most sustainable locations for further growth.

Landywood Railway Station on the Chase Line which serves the Tier 1 Settlement Cheslyn Hay has recently had £110m of public sector investment to improve capacity, journey times and frequency, however despite it uniquely being the only Station, in South Staffordshire on the Chase Line, there is not a level of growth which reflects the £110m investment in sustainable public transport and the Settlement’s high sustainability credentials and the range of facilities which serve it (refer to Appendix 8 of the initial September 2019 submission).

The Council also seeks to identify an area of search for a new settlement to be delivered beyond the plan period along the A449 road Corridor. However, this long-term approach looking beyond 2037 is considered to be wholly unsound and against the principles of sustainable development because identifying potential housing sites in 2019 looking beyond the next 17 years has no regard to what may happen in the interim plan period and if such a concept will result in a sustainable form of development beyond 2037. It is not a robust approach.

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At this stage, the evidence suggests that it would not be a sustainable form of development as such an approach fails to take account of the clear advice in the sustainability appraisal (E12) that several main roads run through the district including inter alia the A449. In such respects:

“Development proposed in close proximity to these areas would expose new residents to high levels of air and noise pollution having an adverse impact on human health. Development proposals in these areas would also be expected to exacerbate local air pollution, primarily due to the number of additional vehicles new development would be likely to create. This would be likely to have adverse impacts on human health and the local ecosystem.”

The Council has also ignored the fact that Option G would allocate large amounts of growth to Penkridge (Tier 1), with additional growth also proposed at Brewood (Tier 2) and Kinver (Tier 2) all of which are identified as historic settlements recognised by the Historic Character Assessment. As such, the Council are obliged following the judgement of R.(oao James Hall and Company Limited) v City of Bradford Metropolitan District Council and Co-Operative Group Limited [2019] EWHC 2899 (Admin) to assess the impact of such proposals on the character and appearance of the Conservation Area. It doesn’t appear that such an assessment has yet taken place. Tier 2 Settlements have no train Stations and lesser levels of employment access than Tier 1 Settlements.

Tier 2 Settlements Brewood and Kinver were reclassified and downgraded by the District Council in the Tier 1-5 Settlement Hierachy.

Furthermore, with additional growth proposed in Codsall, there is the potential that any new housing delivery could impact on ‘the well-preserved Conservation Area’, against which there is unlikely to be any commensurate public benefits arising, to outweigh the harm to the Heritage Asset.

Furthermore, the Council is seeking to bring forward an urban extension for employment-led growth at ROF Featherstone. However, Featherstone is a Tier 3 settlement and located in an unsustainable location as it does not have a railway Station, it has poor bus services and public transport is extremely limited in this rural area of the District with heavy reliance on the motor car. Any proposal for a new road access to Featherstone will increase this heavy reliance on the motor car. There is a distinct lack of services and amenities in proximity to the site, which means that by virtue of the lack of sustainable public transport infrastructure, the vast majority of trips will be undertaken by private car exposing new residents to high levels of air and noise pollution having an adverse impact on human health, which is wholly against Government Policy.

Spatial Option G outlines that this may facilitate the delivery of previously developed land in the Green Belt in Wombourne (Tier 2). No details of the site in question are provided. It is unknown if the site is in active use and therefore requires the relocation of existing uses and or if the site is currently, or was last in employment use or if the site has been actively marketed to demonstrate that it is no longer suitable as an employment site. It could be that there are other insurmountable issues including inter alia multiple ownerships, varying topographical ground level differences and or significant contamination issues which would

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either preclude the re-development of the site or significantly impact on the availability and viability of the site. The fact that Wombourne (Tier 2) doesn’t have a railway station is a significant issue and a reason for it being reclassified and downgraded to a Tier 2 settlement in the hierarchy because it preformed less well in the Council’s revised settlement hierarchy. It would not be connected to the GBHMA by rail and is therefore contrary to para 1.69 of the Greater Birmingham Housing Market Area – Strategic Growth Study. Should any housing be proposed it should be restricted solely to the local need of the village.

The proposed urban extension to the eastern boundary of South Staffordshire would provide in the region of 752 homes. However, this area of search does not relate to any particular settlement in South Staffordshire (whether Tier 1 or Tier 2 settlements), but instead is wide ranging and speculative. It is likely to result in extensions of settlements that are within the West Midlands Conurbation and which are outside the administrative boundary into South Staffordshire. Such a proposal would be entirely contrary to one of the five purposes of the Green Belt, which is to check the unrestricted sprawl of large built-up areas.

The proposed urban extension to the north of Walsall and Wolverhampton would provide in the region of 1,194 homes in the most ‘fragile’ area of the Green Belt. However, this Area of Search takes no account of the recently completed electrified Chase Line ‘a vitally important route into Birmingham’ and takes no account of Landywood Station unique in South Staffordshire being the next station from Bloxwich North (a 7 minute train journey) which is in the GBHMA West Midlands Conurbation. It takes no account of Landywood Station being accessable by residents of all ages and mobilities in the highly sustainable location of Cheslyn Hay/Great Wryley. The Area of Search does not relate to any particular settlement in South Staffordshire, but instead is likely to result in extensions of settlements outside the Bloxwich/Walsall administrative boundary into South Staffordshire. Such a proposal would be entirely contrary to one of the five purposes of the Green Belt, which is to check the unrestricted sprawl of large built-up areas. Furthermore, the Area of Search is in proximity to the land between Bloxwich and Landywood at the Southern end of Great Wyrley, which is identified as being ‘fragile’ at paragraph 5.17 of the Green Belt Study. (Appendix 8 of the initial September submission also applies).

The other significant proposed urban extension is at ROF Featherstone which would provide in the region of 1,194 homes on a greenfield site without access to a railway Station. Featherstone/Hilton is identified as a Tier 3 settlement in the Rural Services and Facilities Audit 2019, which typically has far fewer educational facilities and less of a range of services and facilities compared to Tier 1 and Tier 2 settlements. A Tier 3 settlement isn’t the most sustainable settlement in the District (Tier 1 settlements are) as such, to propose a significant number of houses in one of the least sustainable locations in the District is entirely contrary to the principles of sustainable development which Government Policy in the NPPF is seeking to achieve. Given that this is a greenfield site in the Green Belt for new housing which is not well served by public transport, with no train Station, it does not satisfy para 138 of the NPFF which requires first consideration to be given to brownfield sites and or those well served by public transport.

ROF Featherstone doesn’t have access to a railway Station and has a very poor bus service with currently only 4 buses a day accessing the settlement.

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As the Site Allocations DPD clearly shows (page 40 – see extract below) the employment allocation at ROF Featherstone will be delivered on brownfield land, any housing (some 1,194 dwellings) will be on greenfield land in the Green Belt and this aspect of the strategy is therefore contrary to para 138 of the NPPF.

Accordingly, for all the reasons given in this consultation response our client considers the Spatial Housing Option G is not robust.

QUESTION 7: Do you agree that we should continue to explore options for a new settlement?

No. D Morgan PLC considers that to attempt to identify a new settlement whether or not as part of Spatial Housing Option G beyond the plan period is contrary to Government policy which seeks to ensure that the planning system contributes towards sustainable development.

The Council’s plan period runs from 1 April 2018 to 31 March 2037; there is therefore no requirement for the Council to consider planning beyond 2037. The commitment to a new settlement pre-empts any future changes to national policy, demographic projections, and any findings arising from future evidence base studies.

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Paragraph 16 of the NPPF states Council’s plans should inter alia:

a) be prepared with the objective of contributing to the achievement of sustainable development; b) be prepared positively, in a way that is aspirational but deliverable; c) be shaped by early, proportionate and effective engagement between plan makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees; d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

The proposal for a new settlement beyond the plan period would conflict with a number of the policy points set out below.

a) be prepared with the objective of contributing to the achievement of sustainable development; To now seek at this early stage to identify a new settlement looking two decades ahead pre-empts any changes to national policy, demographic projections and any future evidence base findings. It is therefore inconceivable that such an option could meet the objective of contributing towards sustainable development. It is not a robust approach.

b) be prepared positively, in a way that is aspirational but deliverable;

The ‘unknown’ infrastructure impact/demand/cost/viability/deliverability, therefore leads to uncertainty with point b) in mind; the proposal cannot be considered feasible and deliverable without the infrastructure required being identified now looking two decades ahead and costed with appropriate funding arranged, and timescales for infrastructure delivery being factored in and crucially such infrastructure actually being included in the plan of the infrastructure providers. There are also significant concerns over whether land in the area being sought in available for development; not all land shown within the ‘Area of Search’ has been submitted and considered as part of the Council’s Strategic Housing Land Availability Assessment

c) be shaped by early, proportionate and effective engagement between plan makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;

To attempt to plan so far in advance, ahead of knowing what national policy may be, what the baseline position is and what the needs of the District are means that proportionate and effective engagement is impossible to take place.

Without transparancy,clarity on points a) b)and point c) cannot be satisfied, as this requires early engagement with infrastructure providers and landowners. Without knowing where development will be located, the infrastructure demands and

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impacts cannot be quantified and understood; nor can the availability of the land be established.

d) contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

The precise location for any new settlement in the Area of Searach is not clear, and it is ambiguous as to why the Council are pursuing this option when it falls outside of the plan period.

The ‘Area of Search’ proposed by Option G is focused away from any existing settlement(s), away from any existing railway Station or public transport hub. Any settlement in this area would be remote from sustainable public transport, and be heavily reliant on the private car as means of transport;

It is therefore not a sustainable option when the Council already acknowledges that the majority of residents commute out of the District to meet their employment needs. Prospective residents would have no option but to drive long distances out of the District to work. Such an outcome is wholly contrary to the government’s requirement for sustainable transport modes to be promoted through Local Plan preparation (para 108a of the NPPF), and in promoting healthy and safe communities (Section 8 of the NPPF).

The Council’s preferred Housing Strategy Option G is an infrastructure-led development with a garden village area of search beyond the plan period with the SHSID document confirming that growth on strategic sites is prioritised in locations where it could help meet local infrastructure needs and opportunities.

Additionally, an Area of Search for a new settlement to be delivered beyond the plan period would also be established along the road A449 road corridor increasing the use of the motor car and emissions.

Growth in the villages is dispersed across villages in Tiers 1-4 under this option. It is unacceptable that there should be any significant dispersed growth outside Tier 1 settlements. A larger proportion of housing growth is focused on Tier 1 and Tier 2 settlements. Other environmental constraints include historic settlements with extensive Conservation Areas or settlements constrained by a designated landscape. Tier 1 settlements where there is existing infrastructure with existing capacity for growth should maximise the capacity and be the preferred location as opposed to aspirational locations for infrastructure in ‘an Area of Search’ still with a heavy dependency on the motor car.

For the reasons explained in this consultation response it is considered that the strategy of exploring options for a new settlement should be abandoned.

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QUESTION 8: What other information (if any) should we consider before concluding that Green Belt release is justified?

D Morgan PLC is satisfied that the Council has demonstrated exceptional circumstances to justify a Green Belt release of land, but is not satisfied that the Council’s methodology gives first consideration to sites that are brownfield and or well served by public transport for all the reasons given in this consultation response.

The Inspector who recently examined the Council’s Site Allocations Document (SAD) 2018, concluded that a Green Belt Review would be required to inform the Local Plan Review, and the approach which the Council has undertaken reflects this recommendation.

Not only does the evidence presented to date support the release of Green Belt land, but the Planning Inspectorate has, as part of the SAD, already indicated that a review is necessary.

The Council has also explored developing non Green Belt locations, but has concluded that using this approach will not deliver the housing needs of the District.

D Morgan PLC would re-iterate the various references in the Council’s evidence base and indeed within the SHSID to paragraph 138 of the NPPF, which requires Councils to give first consideration to Green Belt sites that are either brownfield and or well served by public transport when considering Green Belt release.

As such, D Morgan PLC considers no additional information is required to justify a Green Belt release. However, first consideration must be given to brownfield sites and or those well served by public transport.

QUESTION 9: Have we identified the key criteria for the identification of sites (as set out in Appendix 6)? Are there any other factors we should consider?

The Council’s site selection methodology – Appendix 6 of the SHSID document confirms (para 1.6) that only sites within a potential location for growth under the infrastructure-led strategy (Spatial option G) will be assessed. This strategy rules out any other option at this stage, which is a flawed approach. If land in the Green Belt is to be released, first consideration must be given to brownfield sites and or well-served by public transport.

For the reasons explained in this response, we consider that the methodology in Appendix 6 is the incorrect approach towards the distribution of housing across the District and the wrong strategy. The approach adopted by the Council at paragraph 1.6 is considered to be unsound and flawed.

Furthermore, the Council at paragraph 1.5 confirm that only sites, which have been identified in the 2018 SHELAA as being in category S1, S2, S3, NCD1 and NCD2 will be considered as potential housing sites. Whilst the rationale behind this approach is understood, it does not allow officers to re-consider sites categorized as NS where additional information has been provided by the site promoter to overcome the Council’s concerns raised in the SHELLA.

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It does not allow the provision of additional information to demonstrate how a site (in respect of a portion of our client’s site) is not disassociated from the host settlement. It does not allow the site promoter via the means of a Masterplanning exercise to show how sites can link into adjacent sustainable transport and or green and blue infrastructure networks (para 9.3) and how existing landscaping can be improved or new landscaping provided to provide mitigation in respect of any impact on the landscape.

As such, the Council’s approach is considered to be flawed and very narrowlily focused and does not allow other sites to be brought forward and considered each on their own individual merits having regard to new information that may emerge, provided by the site promoter as part of the public consultation process.

The Council confirm at paragraphs 1.9 – 1.11 inclusive how sites will be assessed for potential allocation. Whilst our client agrees in principle with the preparation of a pro-forma for each site to enable the site to be assessed against a number of key planning considerations, it is our position that this does not go far enough and the Council should be transparent in setting out and communicating the methodology and scoring system as well as providing a template pro- forma for comment.

Our client considers that sustainability and the proximity to zero emissions public transport infrastructure and services including access to train Stations should be the key consideration in site selection as this would then comply with Government policy to ensure that the planning system contributes to the achievement of sustainable development. Use of land should be maximized when it is well served by public transport.

As South Staffordshire has a high car-ownership level and dependency owing to the rural nature of much of the District, which it is accepted generally has poo public transport, and given that many residents of the District commute to neighbouring areas for work including using the ‘vitally important route into Birmingham’ (the Chase Line), the Council should consider the proximity of sites to existing public transport connections (which should be maximized) and green and blue infrastructure in order to eliminate dependency on the motor car and/or reduce the use of the motor car and cut down on emissions.

The Council as part of paragraph 138 of the NPPF is required to “give first consideration to land which has been previously-developed and/or is well-served by public transport”.

Settlements and sites that are already well served by public transport and in particular low emissions transport facilities should be afforded significant weight and considered first.

QUESTION 10: Do you agree that, when selecting sites to deliver the preferred spatial housing strategy, the Council should seek to avoid allocating housing sites that would result in very high Green Belt harm wherever possible?

It is agreed that the Council should seek to avoid allocating housing sites that would result in Very High Green Belt harm wherever possible.

The South Staffordshire Green Belt Study 2019 sets seven clear categories which Green Belt harm is rated:

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 Very high  High  Moderate-High  Moderate  Low-Moderate  Low  Very Low

Sites falling into all other categories from High to Very Low should be considered against the requirements of paragraph 138 of the NPPF with an emphasis given to sites in more sustainable locations with access to a train Station.

Sites which result in Very High Green Belt harm which do not comply with paragraph 138 should not be considered first.

There must be compliance with Paragraph 138 of the NPPF when releasing Green Belt sites:

“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport”.

Cheslyn Hay a Tier 1 Settlement with capacity for growth which must be maximized, is exceptionally well-served by public transport, both in terms of excellent bus services and excellent railway connections with intermodal connectivity accessible by mobile and less mobile people of all ages. Also refer to Appendix 8 of the initial September 2019 submission. It is located within the Cannock Town Centre catchment area with its extensive and excellent range of shops, facilites and services giving rise to significant retail and other employment opportunities and has excellent regular bus services from Cannock Town Centre via Cheslyn Hay to Bloxwich, Walsall, Birmingham and Wolverhampton City Centre (providing inter-modal connectivity with the Metro Tram), within 100m of the site boundary on Wolverhampton Road.

Within Cheslyn Hay/Great Wryley Landywood Railway Station uniquely is South Staffordshire’s only Station on the Chase Line. The Station enables train journeys to be made to Cannock (3 minutes), Bloxwich (7 minutes), Walsall (13 minutes) and Birmingham (35 minutes) ‘ a vitality important route into Birmingham’ giving rise to increased mobility and considerable economic benefits for the West Midlands area.

Based on this evidence, Cheslyn Hay and our client’s promoted site (SHELLA refs 131, 116 and adjacent land) and the requirement to only release Green Belt sites that are brownfield or well served by public transport (paragraph 138 of the Framework) our promoted site must be an area of first consideration to consider Green Belt release, as required by national policy.

To consider any other non compliant Green Belt sites that conflict with the requirement of paragraph 138 of the Framework which requires that sites that are brownfield or well served by public transport, must be given first consideration, is clearly against National Policy.

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Gareth Glennon

From: Gareth Glennon Sent: 01 November 2019 15:24 To: [email protected] Cc: Ian Byrne; [email protected]; [email protected] Subject: Local Plan Consultation Process. Attachments: Appendix 4.pdf; Significant improvements for passengers when electric trains are introduced between Walsall and Rugeley.pdf

Tracking: Recipient Delivery Read [email protected] Ian Byrne [email protected] [email protected] Victoria Morgan Sarah Lowe Delivered: 01/11/2019 15:24 Read: 01/11/2019 16:54

Dear Kelly, Edward and Patrick,

On behalf of our clientD Morgan PLC, myself and my colleague Sarah, followingthe submission of our local Plan representations document in September, we'd like to take this opportunity to thank you for our meeting on Monday 28 October in respect of our client's site in Cheslyn Hay. We note your advice that an electronic copy of the document should be formally submitted during the consultation period between 17 October 2019 and 8 December 2019.

As explained during the meeting, we will of course be providing comments on the local Plan Spatial Housing and Infrastructure DeliveryPlan (October 2019) and other evidence based documents in due course, prior to the consultation period expirydate of 8 December 2019. In the meantime however, we note that the current (2019) version of the separate Infrastructure DeliveryPlan (!DP)as set out at paragraph 2. 1 "is a 'live document' that willbe updated regularly as new informationis provided by infrastructure providers and as options for growth are refined"

In this respect I consider it relevant to bring to your attention the matter of the Chase line Rail Corridor, which has been electrified with zero emissions at the point of travel significantly improving air quality. The current version of the /DP document suggests on page 26 that funding is available (whereas£ 11Om has already been invested) in electrification of the Walsall to Rugeley line, which is now fully operational and the considerable benefits are available for passengers as referred to below. As set out in our September Local Plan submission document and is clear from the attached press release from West Midlands Railway (Dated10 May 2019), the Chase line has already been electrified and is in use. Electric trains commenced zero emissions serviceson 10 May 2019. Accordingly, it is respectfully requested that the /DP is updated to include this new information.

46 In view of the importance of properly describing the status of the Chase Line in the /DP, we are concerned that any further work on the Local Plan will not have regard to this significant material consideration duringany future

revisions.

The May 2019 press release confirms that the Chase Line is a we/I-used and popular route, which will benefit from the significant uplift in capacity and new direct services that the completion of the electrification project will enable.

The Mayor of the West Midlands commented: "People using the Chase Line are now getting faster and quieter trains offeringmore carriages with more seats and more direct services to London and Birmingham Airport. "

Cllr Mark Winnington (Deputy Chair of the West Midlands Rail Executive and cabinet member for Growth with StaffordshireCounty Council)stated: "This is just part of the investment in the region which will transform the rail network and services over the next few

years improving connections and underpinning jobs and growth".

As set out in our September submission document, our site has the benefit of zero emissions travel on the Chase Line

improving air quality and has the benefit of high quality green infrastructure links which are a zero emissions traffic free pedestrian route for Active Travel walking and cycling improving air quality (Appendix 4 of our September submission - attached for your convenience).

Our September submission (page 2) confirmed that within the Birmingham HMA 38% of all peak am journeys into Birmingham City Centre Area are now made by rail, this is predicted to grow by 49% from 2013 to 2033 (to around 60%) and this future growth will also benefit from zero emissions travel further improving airquality. From our site,

Landywood Train Station is accessible by foot within a 1 mile(1.6 km) and journeys to Birmingham New Street are just 35 minutes and to Cannock Station just 3 minutes serving the Town Centre with its comprehensive range of services and McArthur Glenn Designer Retail Outlet. Zero emissions access to Landywood station by walking and zero emissions electric train travel improving air quality is a unique feature of our site. As outlined above, these journeys will take place on electric trains, which are not only faster, quieter and have greater capacity than Diesel trains, but also have significantly lower Co2 emissions than the Diesel trains that will continue in use on other lines in South Staffordshire. Electric train infrastructure is significantly greener than Diesel train infrastructure. Such zero emissions and air quality benefits are significant in the context of the completed£11 Om investment in the Chase Line and the proposed sustainable housing development at our site willsupport this major investment in public transport increasing the Chase Line passenger capacity for future growth in South Staffordshire.

The Co2 emissions are highly relevant in respect of the Government's legally binding fifth carbon budget which says

emissions must be reduced by 57% by 2032 compared to emission levels in 1990, and 100% reductionby 2050 lhttps://www.theccc.org.uk/tackling-climate-change/reducing-carbon-emissions/how-the-uk-is-progressing/)

The Council's /DP (page 11) under the heading Public transport acknowledges that with the exception of some of the

larger villages, public transport in South Staffordshire is generally poor, with links between north and south of the district particularly lacking" South Staffordshire is a rural district with higher than the national average car usage. 47 Thanks again for taking the time to meet with our client, myself and Sarah and we look forward to continuing a good working relationship with you and your co/leagues and wi/1be happy topr ovide further information if required.

With kind regards

Gareth Glennon Director

0113 243 1919 07968 313 868 Suite 9C Josephs Well, Hanover Walk, Leeds, LS3 1AB

Im peacockandsmith.co.uk 1 PEACOCK+ 111I ■I SMITH

This e-mail is for the use of the intended recipient(s) only. If you have received this e-mail in error, please notifythe sender immediately and then delete it. If you are not the intended recipient, you must not use, disclose or distribute this e-mail without the author's prior permission. We have taken precautions to minimise the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. We cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in future then please respond to the sender to this effect.

Registered address: Westwood House, 78 Loughborough Road, Quorn, Leicestershire, LE12 8DX Registration No. 0130 6847

48 APPENDIX 4 Existing Community green Network for walking/cycling from the proposed Housing Site to Landywood Station (SAD 136) Published 21st April 2017, “The Cycling and Walking Investment Strategy sets out the Government’s ambitions to make cycling and walking the natural choice for shorter journeys, or as part of a longer journey”.

1 2

South Staffordshire District Integrated Transport Strategy October 2017, para 5.17 states: “Great Place to Live - the health and Connection with the disused Wyrley branch wellbeing of local communities will benefit from improved walking Canal and thereafter using PRoW 11/18 and cycling facilities that encourage increased physical activity”. linking into the proposed Housing site layout providing a great place to live for walking and cycling.

3 4

Rear. Mary Rose Pub and Restaurant Front. Mary Rose Pub and Restaurant

5 6

View from Upper Landywood Lane. Links at a pedestrian/cycling crossroads traffic free (SAD 136 Open Space) extends this community green network to intersection greenspace infrastructure providing a great Landywood train Station connecting with the West Midlands place to live for walking and cycling. conurbation providing walking/cycling on a traffic free route from the Station to the proposed Housing site. NPPF 2019 para 98 states: Planning policies and decisions should protect and enhance public rights of way and Core Strategy 11.20 states: Green space networks connecting access… for example by adding links to existing rights of residential areas with recreational sites and open countryside can way networks including National Trails. help promote healthier lifestyles and greater recreational activity 49 50 51 52

September 2019

NPPF 98 adding links.

Blue infrastructure connecting with green infrastructure connecting into the site NPPF 2019 (ref para 138) 2018 SHELAA site refs: 116 & 131 where it has been concluded that it is necessary to release

Green Belt land, plans should give first consideration to

land which has been previously‐developed

and/or is well served by public transport

Landywood

Station Communal wellbeing this community hub, Academy, Primary School, Leisure Centre, is 600m from the housing site South Staffordshire District Council the community centre and library Local Plan Review Initial Submission are 900m from the site PROVIDING NEW HOMES FOR THE GROWTH IN JOBS MAKING GOOD THE SHORTFALL IN THE HOUSING REQUIREMENT IN A REGIONALLY SIGNIFICANT AND ATTRACTIVE LOCATION FOR NATIONAL AND INTERNATIONAL INVESTMENT Proposed Extension of Cheslyn Hay Host Settlement for Residenti al Development

NPPF 96 Sport. Health and well‐being of communities.

1 of only 4 Leisure Centres in South Staffordshire 1

FRONT COVER RAILWAY IMAGE – upgraded railway track and longer platform Recent electrification scheme 2014-2018 £100m Public Transport investment on the Chase Line between Rugeley Trent Valley and Walsall

This plan has been reproduced from page 6 of the South Within South Staffordshire, rail connections to the Staffordshire Site Allocations Document 2018. West Midlands are particularly important as 48% of Approx 80% is Green Belt residents work in the conurbation, para 5.4, South Staffordshire Integrated Transport Strategy – October 2017 Public Transport in South Staffordshire is generally poor, Section 4 page 7 Infrastructure Delivery Plan (IDP) 2018

Landywood Station is unique because it is the only Station on the Chase Line to benefit from the electrification scheme within South Staffordshire connecting to the West Midlands conurbation.

Landywood Station is within 1.6km of the proposed Housing site. This is within Staffordshire County Council’s preferred 2km maximum commuting walking distance.

refer to paras 4.34 -- 4.38 below also to APPENDIX 4

BY TRAIN TO 3 SUB-REGIONAL SHOPPING CENTRES, CANNOCK – WALSALL - WOLVERHAMPTON It’sBY TRAIN3 minutes TO by3 SUB-REGIONAL train from Landywood SHOPPING to Cannock CENTRES Station, CANNOCK to the – WALSALL Sub-Regional - WOLVERHAMPTON Shopping Centre. It’sIt’s 7 3 minutes minutes by by train train to Bloxwichfrom Landywood Town Centre. to Cann It’sock 13 minutesStation toto Walsallthe Sub-Regional Sub-Regional Shopping Shopping Centre. Centre. It’s 7 minutes by train to Bloxwich Town Centre & 13 minutes to Walsall Sub-Regional Shopping

The GBHMA is highly accessible from the Chase Line, a Strategic Rail Corridor Greater Birmingham Housing Market Area (GBHMA) – by train Within the Birmingham Housing Market Area 38% of all a.m. peak journeys into Birmingham City Centre are now made by rail, this is predicted to grow by 49% from 2013 to 2033 and 114% by 2043 Network Rail West Midlands and Chiltern railway route study 2016.for 2 mattin2019 LOCAL PLAN REVIEW -INFRASTRUCTURE DELIVERY PLAN (IDP) 2018

Section 4 page 7 states: “With the exception of some of the larger villages, public transport in South Staffordshire is generally poor.”

2018 SHELAA para 5.63 states: the vast majority of potentially suitable new supply (housing) from village or urban area extensions would require development on Green Belt land.

NPPF 2019 para 138 where it had been concluded that it is necessary to release Green Belt land,

plans should give first consideration to land which has been previously- developed and/or

is well served by public transport.

NPPF 2019 para 122 is a requirement for decision makers to ensure that development

makes the most efficient use of land, taking account of availability and capacity of

services and transport connections. By Bus…By Train … By Tram … Passengers in the GBHMA

accessing 3 international airports by rail and HS2 at Crewe or Birmingham

The Proposed Housing Site will support and sustain this exceptional public transport connectivity and services By Bus…By Train … By Tram … in the GBHMA with excellent intermodal public transport services including 2 Core Bus Routes to Cannock Town Centre, including the Strategically important Chase Line Rail Corridor and intermodal bus connectivity with the Metro Tram

Page 14 Strategic Rail Corridor the Chase Line paras 3.10 & 3.11 Page 16 Cannock Bus Network Map connectivity Page 17 West Midlands Metro Tram Extension Map connectivity Page 21 Strategic Transport Connections & Employment Sites, growth in jobs

Before the £100m electrification of the Chase Line, recently completed 2018 and

£1.5billion spend on public transport including the Metro Tram system in the GBHMA, the 2006 Housing Appeal Inspector’s decision para 9.2 stated: “The proposal meets the sustainability development objectives set out in PPG 13.” Para 9.29 stated “it is agreed that Cheslyn Hay is highly accessible by public bus services including those along Wolverhampton Road” Statement of Common Ground with District Council APPENDIX 8 of this submission. 3

2019 LOCAL PLAN REVIEW PREFERRED SPATIAL OPTIONS LOOKING AT BROAD AREAS FOR GROWTH & STRATEGIC INFRASTRUCTURE OPPORTUNITIES,

FOLLOWING ON FROM WORK IN 2014 BY LOCAL AUTHORITY CHIEF EXECUTIVES.

South Staffordshire Council’s Site Allocations DPD (2018) para 9.23 states:

NOTE. It identifies the M54 corridor, M54/M6 Northern Motorway Link Road M6 Toll and Cheslyn Hay

The proposed Housing Site providing new homes for the growth in jobs is highly accessible from the Strategic Transport Connections and Employment sites. The Housing Site is also highly accessible by intermodal public transport By Bus… By Train… By Tram… accessing three international airports by rail and HS2 at Crewe or Birmingham.

South Staffordshire District Integrated Transport Strategy, October 2017, para 5.2 states:

D MORGAN PLC IS THE SITE PROMOTER MR formatting this document FOR 3 ADJACENT SITES COMPRISING THIS SUBMISSION Herein referred to as the proposed Housing site APPENDIX 1 & PAGE 50

SHELAA SITE 116 – 23 HA GROSS 13.8 HA NET (441 HOUSES) SHELAA SITE 131 - 18 HA GROSS 10.8 HA NET (345 HOUSES) & ADJOINING LAND NOT PREVIOUSLY ASSESSED FOR HOUSES PROVIDING SOME 800 NEW HOMES FOR THE GROWTH IN JOBS

About this submission

This submission is made by D Morgan PLC as the Promoter and Peacock and Smith Ltd as planning and development consultants.

The entirety of this initial submission is to be considered as a material consideration in respect of the Local Plan Review. It will inform the Preferred Spatial Options consultation and the Call for Sites Exercise to make good the shortfall in the housing requirement both locally and within the GBHMA.close the

Formatting the document to reds spaces like here It will inform a planning application to be submitted in due course within this broad location SAD 2018 para 9.23 ‘as a Regionally Significant and attractive location for National and International investment’ supported by Local Authority Chief Executives across the West Midlands. Frmattingformatting again n this ag. This National and International investment is creating some 20,000 highly skilled employment opportunities in advanced manufacturing and aerospace within the GBHMA within this Regionally Significant and attractive location in which people require houses, para 1.1 SHELAA ‘Study of potential housing and employment sites’. Housing and employment are interlinked. They go hand in hand.ffe to The proposed Housing site ‘providing new homes for the growth in jobs’ has exceptional Strategic Transport connections to Strategic Employment Sites, this is fundamental (Plan pages 4 & 21) West Midlands Transport Strategy. It has exceptional access to bus, tram, train services using intermodal public transport. It has rail links to 3 international airports and HS2 connections at Crewe or Birmingham from Landywood Station on the Chase Line a Strategic West Midlands Rail Corridor in the GBHMA where people require houses for the growth in jobs, in this Regionally Significant and attractive location. Please refer to CONCLUSION paras 8.1 – 8.20, which must be read with the entirety of this detailed initial submission.

For More Information - Points of Contact

D Morgan PLC www.dmorgan.co.uk New Hey, Chester Road, Great Sutton , South Wirral, CH66 2LS For further information contact Victoria Morgan [email protected]

Peacock and Smith Chartered Town Planning and Development Consultants, 53 King Street, Manchester, M2 4LQ Gareth Glennon [email protected] 5

CONTENTS Page Description 1 Front Cover Walking to Community hubs within 1 mile (1.6km). 2 Inside Front Cover Walking to Landywood train Station within 1 mile (1.6km). Cannock Sub-Regional Shopping Centre, 3 minutes by train. The Greater Birmingham Housing Market Area (GBHMA) is connected by train + National Rail Network connections + 3 international airport rail links + 2 HS2 rail links 3&4 Local Plan Review Infrastructure Delivery Plan & Strategic Infrastructure 5 Points of Contact D Morgan PLC site Promoter; Peacock &Smith Ltd planning and development consultants; South Staffordshire District Council LPA; 6 CONTENTS 9 INTRODUCTION ‐ 2018 SHELAA Site 116 (441 houses) and Site 131 (345 houses) with adjoining land (coloured blue) not previously assessed for houses 12 2018 SHELAA RELEVANT PLANNING APPEAL DECISIONS

2006 – Planning Appeal for Housing, Campians Wood Quarry (2018 – SHELAA 116) 2005 – Planning Appeal for Housing, Landywood Lane (2018 - SAD 136) 13 2019 STRATEGIC PLANNING AND SUSTAINABILITY, SPATIAL OPTIONS ‐ 2018 SHELAA The vast majority of potentially new suitable (housing) supply would require development on Green Belt land ‐ 2019 NPPF para 122 requirement for decision makers to ensure that development makes the most efficient use of land, taking account of availability and capacity of services and transport connections. ‐ Electrification of the Chase Line between 2014 and 2018 it is a strategically important rail corridor benefitting from £100m upgraded infrastructure and improved services with significantly increased passenger capacity prioritising housing growth in the GBHMA. ‐ New longer electric trains commenced service May 2019. ‐ Bus Services, 2 Core Bus Routes to Cannock Sub-Regional Shopping Centre and McArthur Glenn Designer Outlet. ‐ Bus Services, intermodal connectivity with Metro Tram benefitting from £1.5 Billion public transport investment in the GBHMA. 18 Cross-Boundary Employment Land Assessment, Spatial Options ‐ Accessing Strategic Employment Sites from the Motorway Network. ‐ Highways England proposed new Northern Motorway Link Road providing the highest benefit to the local economy, connecting the M54/M6/M6 Toll & the Strategic Employment Sites across Boundaries. ‐ The new Link Road is 750m from the proposed Housing site. 21 Strategic Transport Connections and Employment Sites in the GBHMA with 20,000 employment opportunities creating highly skilled jobs ‐ 2018 SHELAA is a study of potential housing and employment sites in the South Staffordshire District within the GBHMA ‐ West Midlands Transport Strategy & New Northern Motorway Link Road ‐ West Midlands Strategic Employment Study supporting this Broad Location as a Regionally Significant and attractive location for National and International investment creating highly skilled employment supported Local Authority Chief Executives across the West Midlands. ‐ Site Allocations Document (SAD) 2018 Employment Site Allocations. 6

Page Description 22 LOCAL PLAN Local Plan consultation process – 2018 SHELAA site 116 24 Local Plan consultation process – 2018 SHELAA site 131 28 2018 – Site Allocation Document (SAD) ‐ Allocated and or Safeguarded parcels 119, 141, 139, 136. ‐ Safeguarded land to be reviewed in the current Local Plan Review ‐ Comparison with proposed Housing site 116, 131 & adjoining land not previously assessed providing new homes for the growth in jobs. 30 Walking short distances of 2km and 1.6km source documents

32 Wolverhampton Road (B4156) a short walking distance legible pavement link to host settlement Cheslyn Hay from proposed Housing site also connecting to the Leisure Centre 1 of only 4 in South Staffordshire for personal physical fitness, sport and communal wellbeing, Academy, Primary School, Community Centre, Library, Allotments for recreation. ‐ Vehicle access will be from Warstone Road (A462). 34 Public footpath PRoW 11/18 connecting with Forest of Mercia Way A short walking distance legible link to host settlement Cheslyn Hay from proposed Housing site also connecting to community green infrastructure and land parcel SAD 136 and to Landywood train Station by walking. 40 Warstone Road (A462) a short driving distance linking to the Strategic Transport Connections and Employment Sites & Cannock Town Centre, providing vehicle access to proposed Housing site with no traffic on the Local Authority network through the settlement of Cheslyn Hay. ‐ Highways England new Northern Motorway Link Road from the M6 J11 to the M54 and Strategic Employment Sites accessible within 750m (0.4miles) from the proposed Housing site with no traffic through Cheslyn Hay. ‐ Cannock Town Centre Catchment Area a Sub-Regional Shopping Centre and Four Retail Parks page 41 connected by road or by non car modes of travel using 2 Core Bus Routes or by the Chase Line by train – it’s a 3 minute train journey. ‐ Bloxwich Town Centre connected by road or by non car modes of travel using 1 Core Bus Route from Cannock via Cheslyn Hay or by the Chase Line by train – it’s a 7 minute train journey. ‐ Walsall a Sub-Regional Shopping Centre connected by road or by non car modes of travel using 1 Core Bus Route from Cannock via Cheslyn Hay or by the Chase Line by train – it’s a 13 minute train journey. ‐ A462 travelling south onto Broad Lane (B4120) toward Bloxwich and Walsall connecting with the A34 in Bloxwich, with no traffic through Cheslyn Hay for the best journey times to Bloxwich and Walsall. ‐ For vehicles the proposed Housing site access on Warstone Road (A462) will be opposite the approved access to the Weinerberger Quarry close to the National Distribution Hub & West Midlands Transport Depot. Plan P.50 ‐ The West Midlands Transport Strategy, Strategic Transport Connections and Strategic Employment Sites (pages 4 & 21) supported by Local Authority Chief Executives across the West Midlands. 44 GREEN BELT AND LANDSCAPE CONTEXT 57 GREEN BELT EXCEPTIONAL CIRCUMSTANCES 59 IMPACT ON LANDSCAPE 58 CONCLUSION 62 APPENDICES

CONTENTS

Appendix 1 - Location Plan showing proposed Housing site comprising SHELAA Sites 116,131 & adjoining land not previously assessed for houses providing new homes for the growth in jobs

Appendix 2 - South Staffordshire District Council 2018 SAD Employment Allocations ‘delivering transport infrastructure – is fundamental’, South Staffordshire Integrated Transport Strategy October 2017 para 5.2

Appendix 3a - The Quarry land owners agent, Axis indicated that the safeguarded Campions Woodland & Quarry can be brought forward with a restoration scheme to be submitted no later than 2021 with some housing. The SAD 2018 para 11.2 confirms New Open Spaces will only be provided through the SAD as part of the delivery of new housing sites’

Appendix 3b - Chronology. South Staffordshire District Council 1996 Local Plan Policy R6 restoration proposals for Campions Woodland & Quarry carried forward over 23 years into 2018 SHELAA site 116 suggested open space and safeguarded land (Campions Woodland) connecting into existing community green infrastructure and Forest of Mercia Way

Appendix 4 - Promoting physical and emotional health and communal wellbeing accessing existing high quality community green infrastructure for walking and cycling inline with the Government’s ambitions using PRoW 11/18 from the proposed Housing site, linking with SAD 136 providing a great place to live paras 5.17 and 5.28 South Staffordshire Integrated Transport Strategy October 2017

Appendix 5 - Local Plan provision SAD 136 extending the community green infrastructure linking to Landywood Station by walking

Appendix 6a - Core Strategy para 11.20 and NPPF 2019 paras 96 and 98 Green Flag Awarded Roughwood Country Park 61 ha (151 acres) including link to Monarchs’ Way, 7km (4.4miles) from the proposed Housing site

Appendix 6b - Core Strategy para 11.20 and NPPF 2019 paras 96 and 98 connecting residential areas into longer distance routes such as Staffordshire Way,fMonarch’s Way and the Sustrans Cycle Network

Appendix 6c - Disused Wyrley branch canal Forest of Mercia Way community green infrastructure connecting into the proposed Housing site layout using Public footpath PRoW 18 to be enhanced/improved where necessary

Appendix 7 - Campions Woodland & Quarry ROMP Environmental Statement concept restoration plan, flooded quarry with safeguarded woodland 2018 SHELAA site 116 suggested open space and safeguarded land (Campions Woodland) connecting into existing community green infrastructure and Forest of Merica Way. A Quarry restoration scheme must be approved 2021

Appendix 8 - Housing Planning Appeal Decision extracts. 2006 Campions Woodland & Quarry (2018 – SHELAA site 116) 2005 Landywood Lane (2018 – SHELAA site 136)

Appendix 9 - Peacock and Smith request for a meeting email dated 24/05/19 LPA response email dated 31/05/19 Peacock and Smith letter in response to LPA email 04/09/19

1. INTRODUCTION

1.1 South Staffordshire District Council, has within its Statutory Development Plan (SDP) Core Strategy (2012) and Site Allocations Document (2018) confirmed, in addition to the District’s

own housing need, there is within the Greater Birmingham Housing Market Area (GBHMA)

which includes the South Staffordshire District Council administrative boundary, an unmet

housing need for some 60,000 houses.

1.2 South Staffordshire is on the edge of the West Midlands conurbation and approximately 80% lies within the West Midlands Green Belt . The Council has confirmed within the SDP that a Green Belt Review as part of the future Local Plan preparations will take place to identify housing sites to meet the District’s own Housing Need and also a proportion of the unmet housing

need from within the GBHMA.

1.3 The SDP also identifies the Settlement Hierarchy and confirms that Main Service Villages will be the main focus for housing supply, employment growth and service provision. Cheslyn Hay, is one such Main Service Village and the vast majority of new (housing) supply would require development on Green Belt land. Para 5.63 SHELAA (2018) “the vast majority of potentially suitable new supply (housing) from village or urban area extensions would require development on Green Belt land”

1.4 The proposed housing development is an extension of Cheslyn Hay requiring the release of Green Belt land. Housing supply, employment growth and infrastructure/service provision are fundamental factors, they are interlinked ‘creating the right conditions for growth in jobs’ in contributing to the achievement of sustainable development and the most efficient use of land well served by public transport is a requirement for decision makers NPPF para 138. Land not well served by public transport should not be released from the Green Belt first.format Most Green Belt land in South Staffordshire is not well served by public transport which is generally poor. Para 3.17 below.

1.5 Cheslyn Hay has access to Landywood train Station, it is uniquely placed in the Chase Line rail corridor as the only Station on the line in South Staffordshire in the GBHMA. Public investment in this rail corridor was and continues to be of Strategic Importance, it was prioritised for electrification of the line, this was completed between 2014 and 2018

1.6 This £100m investment of public funds in public transport upgrading the Chase Line rail infrastructure including longer platforms to accommodate longer trains with more seats for more passengers, has resulted in new electric train services that commenced in May 2019, significantly increasing passenger capacity and service provision to facilitate the planned housing delivery within the GBHMA.

1.7 From December 2017, all railway stations and local services within South Staffordshire are now managed by West Midlands Railway. 9

1.8 It follows that release of Green Belt land and housing delivery should be directed in the first instance to the Main Service Village of Cheslyn Hay accessing the recently electrified Chase Line. This is entirely consistent with NPPF 2019 para 138 which states:

“…. Where it is has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously- developed and/or is well served by public transport…”

1.9 Within Cheslyn Hay/Great Wyrley, the District Council considered a number of sites in the Strategic Housing and Employment Land Availability Assessment (SHELAA) October 2018 to identify at this early stage of the emerging Local Plan, any potential sites for housing and employment. These are addressed in paras 4.28 – 4.41 below.

1.10 This initial submission deals with inter alia matters raised in the SHELAA October 2018 with respect to site 116 – 23ha Gross 13.8 ha net (441 houses) & site 131 – 18ha Gross 10.8 ha Net (345 houses) and adjoining land not previously assessed for houses. Para 1.1 of the SHELAA (2018) – Assessment of Housing Land, is a study of potential housing and employment sites in the District. These 3 sites Promoted by D Morgan PLC providing new homes for the growth in jobs are addressed in paras 4.33 – 4.41 below.

1.11 Access to job opportunities provided by the allocated Strategic Employment Sites is also addressed using the Motorway Network M54/M6/M6 (Toll) and Highways England proposed new Northern Motorway Link Road providing the highest benefits to the local economy linking the M54 Junction 1and M6 Junction 11 referable to the West Midlands Transport Strategy, Strategic Transport connections and Employment Sites (page 21 below paras 3.30 – 3.40 + Plans).

1.12 South Staffordshire Council’s Site Allocations DPD (2018) para 9.23 States

‘West Midlands Strategic Employment Study 2015 commissioned in 2014 by Local Authority Chief Executives across the West Midlands also supported this broad location as a Regionally Significant and attractive location for National and International investment.’ ‘This broad location’ has Strategic Transport connections & Employment Sites. The proposed Housing site is in this broad location for National and International investment.

1.13 Public Transport Infrastructure and service provision is also addressed, including inter-modal connectivity in the GBHMA using Core Bus Routes, the Metro Tram and the Chase Line rail corridor. There is exceptional rail connectivity from Landywood Station to 3 international airports and to HS2 in Crewe or Birmingham which exceptional connectivity will assist able bodied and less mobile people using intermodal travel.

1.14 The interlinking of the supply of housing, employment growth, Strategic Transport connections and accessibility including inter-modal public transport systems accessible to all age groups and mobilities in the GBHMA, is detailed in this submission and demonstrates the proposed Housing site is in a highly accessible and exceptionally sustainable ‘broad location’ as a Regionally

Significant and attractive location for National and International investment. 10

1.15 This submission will inform future discussions with Officers, as part of the public consultation duty. Cheslyn Hay and ROF Featherstone are within ‘this broad location’ identified as being a Regionally Significant and attractive location for National and International investment. This Broad location is the result of work in the former Structure Plan, which identified these areas. The scale of investment and new employment provision will also require additional housing. A new Northern Motorway Link Road is also required between the M6 and M54.

1.16 The proposed Housing site will have access from Warstone Road (A462) within 750m (0.4 miles) of M6 Junction 11, the new Highways England Northern Motorway Link Road is due to open 2025

1.17 Peacock and Smith are instructed to attend any meetings with the LPA and the County Highway Authority to assist the LPA in its public consultation duty to bring the proposed Housing site forward for development in ‘this broad location’ (page 21 below West Midlands Transport Strategy Strategic Transport connections and Employment Sites).

1.18 Further information will be provided as requested by the LPA in respect of bringing forward this housing development, offering a choice of house types in a highly accessible and exceptionally sustainable location in this Regionally Significant and Attractive Broad Location for National and International investment accessing 3 international airports, and HS2, to sustain and develop the local economy creating many thousands of jobs, with people needing houses. The New Northern Motorway Link Road will provide the highest benefit to the local economy in ‘this broad location’.

1.19 The boundaries of the proposed Housing site are detailed within this submission. They include land previously assessed in the 2018 SHELAA which is an assessment of housing land, it is a study of potential housing and employment land in the district (referred to above – para1.10) together with adjoining land shown coloured blue on the plan below not previously assessed for houses.

Extract taken from 2018 SHELAA map for Cheslyn Hay D Morgan PLC is promoting all three sites 116, 131 and the blue land providing new homes for the growth in jobs. APPENDIX 1, APPENDIX 8 and page 50. 11

2. 2018 SHELAA - RELEVANT PLANNING APPEAL DECISIONS

2.1 Notwithstanding the observations, made in the SHELAA by the LPA, two previous Appeal Decisions in respect of site 116 (Campians Wood Quarry) and site 136 (Landywood Lane) will influence the emerging Local Plan. Both appeal decisions are material considerations.

2.2 Both appeal sites were within and continue to be located within the Green Belt with the exception of some land at the Landywood Lane site SAD 136, which has since been released. Further development potential of SAD 136 is being considered in the current emerging Local Plan Review. A key consideration of the Inspector’s decisions in both appeals related to how each site performed against the five key purposes of the Green Belt.

2.3 The Inspector’s findings are highly relevant and have been referred in APPENDIX 8. They are a material consideration in the emerging Local Plan process, as set out below.

TWO PLANNING APPEALS FOR HOUSING (2018- SHELAA Site 116 & Site 136)

2.4 The two planning appeals in 2006 and 2005 each referred to below were dismissed as neither appellant at that time was able to demonstrate ‘very special circumstances’ that outweighed the harm to the Green Belt. This has now changed. ‘The vast majority of potentially suitable supply from village or urban area extensions would require development on Green Belt land’, refer to para 5.4 below.

2.5 The respective Inspector’s conclusions on Green Belt and ‘sustainability credentials’ are referred to below. There is cross referral to both sites in both appeal decisions.

2018 - SHELAA Site ref: 116 ‘study of potential housing and employment sites’

Campians Wood Quarry, Wolverhampton Road WS6 7LQ. Housing Appeal - APP/C3430/A/06/2019854 Section 3 – Inspector’s Conclusions

2.6 Para 26.7: The land has no role in preventing Cheslyn Hay from merging with Great Wyrley and it is to the north west and outside the area that is important to maintaining a gap with Walsall.

2.7 Para 26.45: With appropriate ‘refreshments’ the Local Planning Authority expects to use its suite of studies for its Deposit Draft Plan to inform its Core Strategy and other DPDS. In terms of peak hour public transport accessibility Cheslyn Hay is in equal top place with Great Wyrley and Bilbrook and day time services are also good.

2.8 Para 26.46: On the basis of its ‘sustainability credentials’, the appeal site was considered suitable for inclusion in the list of 7 sites identified in Policy H1 of the abandoned deposit draft Local Plan intended to make good the shortfall in the Structure Plan housing requirement to 2011. That Local Plan is abandoned but if there is to be new housing in South Staffordshire then Cheslyn Hay/Great Wyrley would appear to be at or very near the top of locations on sustainability grounds. 12

2.9 Para 26.111: The appeal failed at that time because ‘very special circumstances’ did not exist to justify development in the Green Belt. 2018 - SHELAA Site ref: 136 ‘study of potential housing and employment sites’

Landywood Lane, Cheslyn Hay, WS6 8W/7AX. Housing Appeals - APP/C3430/A/05/1194463 & APP/C3430/A/05/1194464

2.10 Para 21: The SoS agrees with the Inspector (IR16.43) that the Campians Wood site is broadly comparable to the appeal site with regard to conformity with the development plan and its locational relationship to the MUA but the appeal site is preferable in terms of accessibility. However, the SoS also agrees with the Inspector that the harm which the appeal (the Landywood Lane appeal) proposals would cause to the Green Belt, in terms of the coalescence of Cheslyn Hay and Great Wyrley, should carry greater weight and that, whilst in the case of appeal B the balance is fine, of the two the Campians Wood site is preferable.

Inspector’s Overall Conclusions

2.11 Para 30: The proposed development of this Green Belt site (the Landywood Lane appeal site) would lead to substantial harm through encroachment and the almost complete merging of Cheslyn Hay and Great Wyrley and the ‘very special circumstances’ needed to outweigh this harm are not present. APPENDIX 8

3. 2019 STRATEGIC PLANNING AND SUSTAINABILITY, SPATIAL OPTIONS

3.1 Para 1.1 of the SHELAA 2018 – study of potential housing and employment sites in the District Both Appeal Decisions APPENDIX 8 referable to site 116 and site 136 will inform the emerging Local Plan intended to make good the shortfall in housing requirement via inter alia, Green Belt Review and public transport accessibility “sustainability credentials”formatting the document so

3.2 The SHELAA October 2018 para 5.63, states “the vast majority of potentially suitable new supply (housing) from village or urban area extensions would require development on green belt land”

3.3 South Staffordshire District Council, has within its Statutory Development Plan (SDP) Core Strategy (2012) and Site Allocations Document (2018) confirmed that it will sustain and develop the local economy (Core Policy 7) as a Regionally Significant and attractive location for National and International investment. A new Northern Link Road is to be provided (page 19 below).

3.4 National and International investment of some £1.1billion has been attracted to the prestigious and high quality i54 Strategic Employment Site for advanced manufacturing and aerospace industry creating highly skilled employment opportunities. In March 2019 South Staffordshire District Council approved an extension to the prestigious i54 Site creating more highly skilled employment opportunities, requiring an increase in the housing supply for the growth in jobs.

3.5 In close proximity, the ROF Featherstone employment site is identified as a Regionally Significant Site to provide an additional future high quality Employment Site for South Staffordshire and the West Midlands, for continued employment growth, requiring an increase in the housing supply.

3.6 The Strategic Employment Sites creating some 20,000 jobs have all been sited with access to the Motorway Network, in close proximity to the proposed Housing site (refer to page 21 below).

3.7 In addition to the District’s own housing need (likely to increase as a result of Core Policy 7), there is within the Greater Birmingham Housing Market Area (GBHMA) which includes the South Staffordshire District Council administrative boundary, an unmet housing need for some 60,000 houses.

3.8 The Council has confirmed within the SDP that a Green Belt Review as part of the emerging Local Plan will take place to identify sites to meet the District’s own Housing Need, and also a proportion of the unmet Housing Need from within the GBHMA.

3.9 Taking account of the Inspector’s Appeal conclusions (above paras 2.4 – 2.11) SHELAA site 116 and the adjoining blue land and SHELAA site 131 APPENDIX 1 should all be released from the Green Belt to increase the housing supply to support employment which is planned in this ‘broad location’ by virtue of the exceptional Motorway Network M54/M6/M6 Toll to be further improved with the new Northern Motorway Link Road and by virtue of the exceptional public transport infrastructure with excellent service provision that has already been provided, all of which makes the proposed Housing site highly accessible in an exceptionally sustainable location (refer to para 8.06 below) ‘The proposal meets the sustainable development objectives set out in PPG 13’, refer to the 2006 planning appeal Statement of Common Ground with the District Council 2018 - SHELAA site 116 APPENDIX 8

3.10 Cheslyn Hay has access to Landywood train Station, it is uniquely placed in the Chase Line rail corridor as the only Station on the line in South Staffordshire benefitting from significant publicly funded investment which has recently taken place, upgrading transport infrastructure, improving service provision, increasing passenger capacity, providing for prioritised housing growth.

3.11 This rail corridor is of Strategic Importance and was prioritised for electrification of the line which was completed between 2014 and 2018. This £100m publicly funded investment in rail infrastructure including longer platforms with improved access for all age groups and all mobilities to accommodate longer trains, significantly increasing passenger capacity has resulted in new electric train services that commenced in May 2019. The new trains are twice as long and twice as frequent and almost twice as fast as the previous underfunded (old diesel) service significantly increasing passenger capacity.

Public Transport Serving the West Midlands conurbation The Chase Line Corridor is prioritised for economic and housing growth More trains more seats more passengers 14

West Midlands conurbation - National Rail Network Connectivity + HS2capacity

NPPF 2019 para 138 £100m public transport investment completed 2018 with new electric train service May 2019 on Chase line providing significantly increased passenger capacity

prioritising economic and housing growth accessible from Landywood Station

3.12 A Core Bus Route Wolverhampton to Cannock Town Centre passes the proposed housing site boundary NPPF 2019 para 138.

It is agreed that Cheslyn Hay is highly accessible by public bus services, including those

along Wolverhampton Road (para 9.29 Appeal Ref (APP/C3430/A/06/2019854) APPENDIX 8

3.13 The proposed Housing site is located within the Cannock Town Centre Catchment Area. Cannock is a Sub-Regional Shopping Centre well served by public transport and is highly accessible by public bus services from Cheslyn Hay using 2 Core Bus Routes or alternatively its 3 minutes by train from Landywood to Cannock Station for the Sub-Regional Shopping Centre and McArthur Glenn Designer Outlet.

3.14 Using the Cemetery Street bus stop along Wolverhampton Road travelling in the other direction away from Cannock there is a direct connection with the Metro Tram in Wolverhampton providing public transport bus/tram interconnectivity. The Metro Tram is part of a £1.5 billion public transport investment.

3.15 Release of Green Belt land in this highly accessible and exceptionally sustainable location to bring forward the proposed housing development is entirely consistent with para 138 of the NPPF which states: “…. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been

previously- developed and/or is well served by public transport…”

3.16 The proposed Housing site is exceptionally well served by public transport (Chase Line which is of Strategic Importance electrified between 2014 - 2018) and is also highly accessible by public bus services. The Cannock Bus Network Map (below) shows bus route availability within the area ticket boundary which provides discounted public transport. 15

Cannock Bus Network Map. Cheslyn Hay is on 2 core routes to Wolverhampton City and to Walsall Town Centre - from Cannock Town Centre. The proposed housing site is within the Cannock Town Centre Catchment Area

70,71 to 1,2, 2E, X51 to Bloxwich and City of Wolverhampton Walsall Town Centres Metro Tram

3.17 South Staffordshire Local Plan, Infrastructure Delivery Plan (IDP) 2018 Section 4 page 7 states: With the exception of some of the larger villages, public transport in South Staffordshire is generally poor, with links between north and south of the District particularly lacking. In more rural parts of the District, bus services are poor, with a greater reliance on publicly resourced bookable bus services, particularly targeting individuals with mobile difficulties and other health issues.

3.18 Poor public transport in South Staffordshire - is in stark contrast to Cheslyn Hay which is uniquely placed with access to Landywood Station on the Chase Line and having the choice of two Core Bus Routes available within the Cannock Town Centre Catchment Area for use by residents in Cheslyn Hay accessing Cannock a Sub-Regional Shopping Centre, with one of these Core Bus Routes to Wolverhampton City using the Cemetery Street stop 100m from the proposed Housing site on Wolverhampton Road (para 3.12 above) connecting with the Metro Tram in the GBHMA. The other Core Bus Route accesses Walsall, a Sub-Regional Shopping Centre.

3.19 The Metro Tram is part of a £1.5billion public transport investment, with plans to extend it. It has intermodal connectivity with a Core Bus Route passing the proposed Housing site.

3.20 Passengers using bus services from the proposed Housing site and passengers from Landywood train Station can access the Metro Tramline by bus and rail connections from both ends at the Wolverhampton City intermodal public transport hub using bus services from the Wolverhampton Road Cemetery Street stop 70, 71 or by using Landywood Station on the Chase Line to access Birmingham New Street ‘Grand Central’ connecting with the Metro Tram. By Bus…By Train By Bus… By Train… By Tram … Passengers in the GBHMA

accessing 3 international airports by rail and HS2 at Crewe or Birmingham

There are plans to extend the Metro system as outlined below with Intermodal Bus… Train… Tram… connectivity within the GBHMA

3.21 The proposed Housing site has access to exceptional public transport infrastructure benefitting from excellent service provision with inter modal connectivity, by bus, train and tram. Using inter-modal public transport helps reduce private car use (para 8.06 below) ‘The proposal meets the sustainable development objectives set out in PPG 13’ APPENDIX 8.

3.22 The interlinking of all 3, housing supply, employment growth and transport infrastructure/ intermodal service provision are fundamental for sustainable development. of course The proposed Housing site is in a highly accessible and exceptionally sustainable location. 17

Proximity to Motorway Network - Site Location Cross – Boundary Employment Land Assessments, Spatial Options

3.23 With reference to the Cross-Boundary employment land assessments and the proposed new Northern Motorway Link Road connecting the M54/M6/M6 (Toll), the South Staffordshire Site Allocations Document (September 2018) paragraph 9.22 states:

that through the local plan review process and further cross-boundary employment land assessments, the Council will consider the implications of the Highways England preferred solution (to be confirmed) to the proposed new Northern Motorway Link Road connecting to the M54/M6/M6 (Toll). It is anticipated that a preferred route will be identified in 2018, following further consultation on the remaining two route options under consideration.

3.24 Subsequently Highways England announced in September 2018 the M54/ M6/M6 (Toll) proposed new Northern Motorway Link Road would be ‘Option B west’ (see image page 19) as it:

provides the highest benefit to the local economy: will provide the best journey

time of the options: is preferred by the majority of the respondents to the public consultation: protects ancient woodland and provides the best value for money.

3.25 The new Northern Motorway Link Road will provide access from the M6/M6 (Toll) to the M54 accessing the Regionally Significant Employment Sites between M54 Junctions 1 and 2. 3.26 The proposed Housing site (see image page 19) will have direct access to Warstone Road (A462) connecting to M6 Junction 11 within 0.75km (0.47miles). Access to M6 Toll (T8) is within 1km (0.62miles) for journeys south. The M6 Toll offers an

alternative choice for journeys south (instead of using the M6).

SIGN ON WARSTONE ROAD (A462) - WITH ACCESS TO NEW MOTORWAY LINK ROAD AND 3 MOTORWAYS M54/M6/M6 (TOLL) 3.27 Access to all 3 motorways, M6, M6 Toll, M54, is achievable without any traffic going through Cheslyn Hay or Great Wyrley.

3.28 There is no need to use the M6 Junction 11 travelling south. There is travel choice to instead use the M6 Toll (T8) for journeys south. 3.29 Instead of using the A460 to access Wolverhampton City and the M54 motorway (as signposted), the recently announced Highways England preferred option two lane dual carriageway Northern Motorway Link Road will provide a direct link from the M6 Junction 11 to the M54 Junction 1 accessing the Strategic Employment Sites in a Regionally Significant and attractive broad location for National and International investment.

Highways England New Northern Motorway Link Road between M54

Junction 1 and M6 Junction 11 & proposed Housing site location

which is within 0.75km (0.47miles) of M6 Junction 11

3.30 The proposed Housing site with access to Warstone Road (A462) will benefit from the best journey time of the options to the Strategic Employment Sites with the highest benefit to the local economy from exceptional access to this Highways England preferred option two lane

dual carriageway new Northern Motorway Link Road from M6 Junction 11. 3.31 The Housing site access is within 0.75km (0.47miles) of M6 Junction 11 and ideally located to benefit from the new Link Road, it is then only 3km (1.9miles) to the M54 junction 1. The M6 Toll (T8) is within 1km (0.62miles) from the proposed Housing site .

3.32 All of this access to the new Northern Motorway Link Road and 3 Motorways within this Regional Significant broad location for employment growth supported by Local Authority Chief Executives across the West Midlands, is achievable from the ideally located proposed Housing site access to Warstone Road (A462) - without any traffic going through Cheslyn Hay or Great Wyrley.

3.33 The plan below shows connectivity to the Motorway Network: M6 Motorway: M6 Toll Motorway: M54 Motorway with the recently announced A460 (preferred option two lane dual carriageway Link Road) from M54 junction 1 to M6 Junction 11. The plan also shows onward Regional connections with the M42, M40, M5 using the M6 Toll (T8) for journeys south. 3.34 The plan also shows the proximity of the proposed Housing site to the Strategic Highway Network, A5, A34, A460 at M6 Toll (T7) Churchbridge Triangle (Interchange) and Four Retail Parks (para 4.72) for best journey times, reducing use of private car travel and emissions. 19

Proximity of Five Strategic Employment Sites all within 5km (3.1miles) of the proposed housing site creating 20,000 job opportunities

3.35 The recently announced Highways England preferred option new Northern Motorway Link Road provides the highest benefit to the local economy and is highly accessible from the proposed Housing site. The proposed Housing site is exceptionally well positioned to benefit from development of the local economy, in this area of employment growth, in this Regionally Significant area for National and International investment.

3.36 Within exceptionally close proximity, all within 5km ( 3.1miles) of the proposed Housing site are Four Strategic Employment Sites and the proposed West Midlands Strategic Rail Freight Interchange. These Strategic Sites when they are all developed will all be directly accessible from Motorway junctions. Highways England preferred option new Northern Motorway Link Road will further improve connectivity between these Strategic Employment Sites and Motorways M54/M6/M6 (Toll) in ‘this broad location ’ including Four Retail Parks. page 41 below

3.37 Some 20,000 job opportunities will be available within 5km (3.1miles) of the proposed Housing site creating highly skilled employment, supported by South Staffordshire District Council’s Core Policy 7 to sustain and develop the local economy. The West Midlands Strategic Employment Study (2015) is similar to that previously carried out some years ago which resulted in the identification of 2 Regional sites- i54 South Staffordshire within 5km (3.1miles) from the proposed Housing site accessible from the M54 motorway Junction 2 and Hilton Cross within 3.9km (2.5miles) accessible from the M54 Junction 1.

3.38 As the local economy is developed (Core Policy 7), creating highly skilled employment the availability of high quality housing must keep pace. The proposed Housing site providing new homes for the growth in jobs (approx. 800 units) will provide a choice of house types in an attractive, highly accessible and exceptionally sustainable location, accessible by all modes of transport, including from airports and HS2.

South Staffordshire District Integrated Transport Strategy, October 2017, para 5.2 states: “ SouthDelivery Staffordshire of transport Council’s infrastruc Siteture Allocations and reducing DPD traffic(2018) delayspara 9.23 on statesthe wider: strategic network and West local Midlands authority Strategicnetworks Employmentwithin settlements Study is 2015 fundamental commissioned to creating in 2014 the right by Local conditions Authority for growthChief Executives in jobs and across new homes” the West. Midlands also supported this broad location as a Regionally Significant and attractive location for National and International investment (Fig 5.1 below) South Staffordshire Council’s Site Allocations DPD (2018) para 9.23 states: “West Midlands Strategic Employment Study 2015 commissioned in 2014 by Local Authority Chief Executives across the West Midlands also supported this broad location as a Regionally Significant and attractive location for National and International investment” (Fig 5.1 below)

Figure 5.1 reproduced from West Midlands Transport Strategy. APPENDIX 2 South Staffordshire District Council’s (SAD) 2018 Employment allocations.

3.39 The proposed housing site benefits from exceptionally close proximity to Strategic Transport Connections including new Northern Motorway Link Road accessing Strategic Employment Sites creating some 20,000 job opportunities in this broad location as a Regionally Significant and attractive location for National and International investment. Further developments (Core Policy 7) including ROF Featherstone, a future Strategic Employment Site, will create more highly skilled employment opportunities, all within 5km (3.1miles) of the site. Short travel to work journeys using the new Northern Motorway Link Road will provide the best journey times of all the options, minimising car usage and emissions by reducing private car travel distances. This is fundamental for creating the right conditions for creating the growth in jobs and new homes. The proposed Housing site with access on Warstone Road (A462) is 750m from the Strategic network M6 junction 11 and new Northern Motorway Link Road.

3.40 Employment growth and housing supply in this Regionally Significant and attractive broad location go hand in hand with the Strategic Transport Connections West Midlands Transport Strategy and new Northern Motorway Link Road (delivery of transport infrastructure is fundamental). Without any traffic using the Local Authority network through Cheslyn Hay the proposed Housing site is exceptionally well connected in ‘this broad location.‘ to the Highways England Strategic Transport connections, new Link Road and Strategic Employment Sites. 21

4 LOCAL PLAN

Local Plan Process. 2018 - SHELAA Site 116 (Campians Wood Quarry) 4.1 This quarry (site ref: 116 – 23ha gross 13.8ha net) using a density of 32 d.p.h (441 houses) was considered in the SHELAA 2018. It was observed and noted that the site is potentially suitable for housing but is subject to policy constraints – Green Belt. Not currently available.

4.2 Following a Call for Sites exercise the proposed housing development (site 116) was submitted to the Council with a red line plan. The 2018 Assessment has provided the Council’s observations on the site including ‘suggested open space and safeguarded land’ noting that: The site is potentially suitable, but subject to policy constraints – Green Belt. Not currently available. Site also suggested for open space and Safeguarded Land. Site currently an operational quarry, landowners have indicated it can be brought forward and that they are in consultation with Staffordshire County Council but no further information has been provided at this stage to demonstrate necessary restoration conditions and quarry lifespan do not affect availability.

4.3 The quarry restoration conditions, do require a restoration scheme APPENDIX 3a, 3b. APPENDIX 7 concept restoration scheme

4.4 Site 116 named after Campians Wood contains safeguarded woodland within the quarry boundary – it has a modern set of working conditions (as required by the Environment Act 1995 Review of Mineral Planning Permissions ROMP) and there is a concept restoration scheme, the precise details of which must be submitted for approval to the MPA by 2021, the District Council is an important consultee, this will enable it to achieve its Local Plan objectives set out in the Chronology below for the restoration of Campians Wood Quarry APPENDIX 7

4.5 South Staffordshire District Council’s 1996 Local Plan, took into account the existence of the quarry in making provision through the requirement of Policy R6 APPENDIX 3b for restoration of the quarry site, it notes in respect of site 116 (Campians Wood Quarry) that:

 A footpath link leading north from the canal is to be provided as part of the restoration proposals. The restoration proposals for the site will create an attractive amenity/nature conservation area of great value to the community. The site would be a natural extension of the Wyrley/Essington Canal and the existing Open Space at Lapwing Close. Chronologically this policy has been carried forward from 1996 as follows: 4.6 In 2006 the quarry owners lodged a planning appeal to achieve housing development in the quarry, it was heard via a Public Inquiry (referred to in paras 2.6 – 2.9 above) APPENDIX 8 The appeal was dismissed because the appellant was unable at that time to demonstrate ‘very special circumstances’ to outweigh the harm to the Green Belt. Had this planning appeal for 22

housing succeeded the quarry owners agreed to provide public open space and recreational land. This was offered at that time as follows:

 7.7ha (19acres) of landscaped open space to the south east of the site taking in the remnant woodland and some of the regenerated open cast coal area.

4.7 The 2010 Environmental Statement for Campians Wood Quarry (accompanying the ROMP submission) referable to a concept restoration scheme APPENDIX 7 at paragraph 13.2 states:. “ The quarrying proposals will result in the provision of a substantial amount of recreational open space after restoration.” 4.8 This was carried through from 2010 into the site assessment 2018 SHELAA site 116 Campians Wood Quarry, which states: ‘Site also suggested for open space and safeguarded land’ This chronology and policy commitment goes back to the 1996 Local Plan (Para 4.5 above) connecting green infrastructure and protecting the woodland ‘of great value to the Community’.

4.9 During the 1970s houses were permitted, extending the housing area of the host settlement Cheslyn Hay up to the Campians Wood quarry boundary (Kestrel Way, The Nook, Lapwing Close), with Kestrel Way linking with Dundalk Lane.

4.10 During the 1980s/90s houses were permitted in the area surrounding the Mary Rose Pub and Restaurant, accessed from Moon’s Lane and Upper Landywood Lane linking with Dundalk Lane.

4.11 In 1999 planning permission (ref 99/00127/FUL. Approved 08/10/1999) was granted to Redrow Homes on land within the mineral extraction quarry area accessed from Pinfold Lane in close proximity to the Pinfold Allotments, Community Centre and Library, access on Pinfold Lane.

Local Plan Process. 2018 - SHELAA Site 131 (consented 9 hole golf course)

4.12 This site ref:131 -18.0ha gross – 10.8ha net using a density of 32 d.p.h (345 houses) was considered in the 2018 assessment. It was suggested that the site is disassociated from the existing settlement (Cheslyn Hay) by virtue of the distance from the host settlement and the nature of the walking links between the site and the village. ust some random words to format . If released from the Green Belt, this site is immediately available for housing.

4.13 The nature of walking links between the site and the village are exactly the same walking links for both sites 116 and site 131, using the Wolverhampton Road kerbside pavement and public footpath PRoW 11/18. These are existing walking links over a short distance.

4.14 The proposed Housing site comprises the whole of planning consent 89/00885 (Change of use to golf driving range), 90/00341 (clubhouse, tennis courts and additional parking for driving range) and 94/00507 (9 hole golf course putting green and mounding) approved in 1989 and 1994. The development did commence but the developer failed. An entrance from Wolverhampton Road (B4156) was constructed and exists into the golf course development.

4.15 Following the Call for Sites exercise the proposed housing development, site 131 was submitted to the Council with a red line plan including land which had received planning permission for a 9 hole golf course ref: 94/00507.

4.16 The site was considered unsuitable because it was disassociated from the existing settlement. However, in the same Assessment, the Council set out its (different) position going forwards referable to Key Methodology Assumptions – Suitability, Availability and Achievement of Sites.

Para 3.1 it was agreed that footnote 4 defining ‘disassociated’ would be

amended. The revised footnote would recognise that (on a case-by-case basis) it may be appropriate to include sites as ‘potentially suitable’ to a nearby village/urban area where the site is a short distance to the settlement and where strong visual and physical links could be demonstrated to the host settlement (e.g legible pedestrian connections).

4.17 The SHELAA at paragraph 5.37 refers to footnote 4 and refines ‘disassociated’ as follows:

“ A site is considered disassociated from a village boundary when it is not directly adjacent to it. On a case by case basis, it may be appropriate to consider a site not directly adjoining a development boundary as a ‘potentially suitable’ extension to a village/urban area where the site is a short distance from the host settlement and a legible pedestrian route and means of access to the host settlement can be demonstrated by the site promoter.” F

4.18 This submission by the proposed Housing site promoter demonstrates that site 131 (together with additional land coloured blue) APPENDIX 1 is a short distance from the host settlement Cheslyn Hay and that walking and cycling is easily achievable along existing legible legally 24

protected highway links including public footpath PRoW 11/18 and using the highway pavement along Wolverhampton Road (B4156) paras 4.33 – 4.40 below and all of page 35.

4.19 This submission also demonstrates that site 131 (together with additional land) is adjacent to the quarry restoration scheme, to provide ‘public open space and safeguarded land’ 2018 SHELAA site 116 ‘of great value to the Community’ 1996 Local Plan for the enjoyment of local people including the safeguarded Campians Woodland chronologically carried forward over a period of some 23 years with a footpath link as a natural extension of the Wyrley/Essington Canal and the existing Open Space at Lapwing Close – of great value to the Community (1996 Local Plan Policy R6 – para 4.5 above). The potential to realise this ‘great value to the Community’ is achievable through the Campians Woodland Quarry restoration scheme, with a deadline of 2021. 4.20 Site 131 (together with additional land) is in close proximity to the one way traffic system (used as a bus route) in the host settlement of Cheslyn Hay and site 131 is exceptionally well served by a well lit, safe, traffic free, high quality community green infrastructure link for walking and cycling to the Mary Rose pub & restaurant (Moon’s Road) within a short distance. APPENDIX 4 4.21 The Local Plan makes provision for the community green infrastructure to be extended through safeguarded land (SAD 136) to Landywood train Station – APPENDIX 4, APPENDIX 5

4.22 The existing community green infrastructure public footpath PRoW 11/18 will be enhanced/improved where necessary satisfying paras 96 and 98 of 2019 NPPF connecting into the proposed Housing site layout APPENDIX 6c and connecting in the opposite direction with SAD 136 providing Green Infrastructure linking to Landywood Station. SHORT DISTANCE LEGIBLE PEDESTRIAN LINKS PUBLIC FOOTPATH PROW CHESLYN HAY 11 AND SAREDON 18

4.23 There are numerous short distance established legible pedestrian links, which are legally protected highways. PRoW 18 is accessible from the proposed Housing site connecting with Lapwing Close ‘and the existing open space at Lapwing Close,’ Dundalk Lane, Moon’s Lane and 25

Upper Landywood Lane and will connect with SAD 136 to the train Station. Public footpath PRoW 18 links Cheslyn Hay with Warstone Road (A462) and will connect into the proposed Housing site layout.

4.24 Adjoining the proposed Housing site there is existing residential development fronting Wolverhampton Road (B4156). 4.25 This public highway has a pavement along its kerbline as shown below. This highway pavement/footpath is a short distance legible route from these existing houses to the host settlement Cheslyn Hay. This short distance highway pavement will also be used by pedestrians to access the proposed Housing site, located to the rear of these existing houses.

Proposed Housing site to rear of this housing frontage

Hollybush Garden Centre

Entrance to Materials Recycling Facility

Image above shows Wolverhampton Road (B4156) with existing highway pavement and existing housing. Behind these houses is the proposed Housing site. Opposite the houses is the entrance to Hollybush Garden Centre and entrance to the Materials Recycling Facility (paras 5.58 & 5.62 below).

4.26 This sizable existing commercial development, former CityLink National Distribution hub (approved under application refs: 93/00052 and 94/00170) adjoins the proposed Housing site. This commercial development now Go Direct/Distribution Centre and Warehouse – height not exceeding 9m has access from Warstone Road (A462) behind which is the proposed Housing site.

Image above shows existing commercial development Go Direct/Distribution Centre and Warehouse, access from Warstone Road (A462). The proposed Housing site is adjacent to this commercial development, Plan page 50.

4.27 The adjoining land not previously assessed APPENDIX 1 is located at the rear of the above Go Direct/Distribution Centre & Warehouse up to the boundary with Campians Wood Quarry. 26

Wolverhampton Road Pedestrian Access (B4156) - using the pavement

Walking accounts for 4/5 of journeys less than 1 mile (1.6km)

this community hub Academy, Primary School, Leisure Centre, is 600m from the Housing site combining personal and communal wellbeing, improving physical health

CHESLYN HAY HAS 1 OF ONLY 4 LEISURE CENTRES IN SOUTH STAFFORDSHIRE

NPPF 96 Sport. significant recreational provision 600m from the site

walking accounts for 4/5 of journeys less than 1 mile (1.6km) NPPF 2019 para 96 states : Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. SHORT DISTANCE LEGIBLE PEDESTRIAN ROUTES TO COMMUNITY HUB

People in the Community Accessing Community Facilities for support and wellbeing the Community Centre and Library are 900m from the site

Site Allocations Document 2018 Cheslyn Hay/Great Wyrley - (Comparatives) These Allocated Housing Sites and areas of Safeguarded land (paras 4.28 – 4.32 below) are now compared with the Proposed Housing Site (paras 4.33 – 4.41 below): 4.28 The Four Allocated/Safeguarded Parcels below are extracts from the Council’s 2018 SAD, only one is allocated in Cheslyn Hay. 3 Parcels are in Great Wyrley but the Cheslyn Hay Leisure Centre important for sport and physical activity and for the health and wellbeing of communities is within 600m of the proposed Housing site in Cheslyn Hay (SHELAA sites 116, 131 and adjoining land not previously assessed).

4.29 Parcel 119 – Land off Saredon Road, Cheslyn Hay

 0.7km from village centre directly adjacent to Cheslyn Hay Leisure Centre/Cheslyn Hay High School and Cheslyn Hay Primary School;formatting the document so no big gaps LANDYWOOD STATION IS NOT REFERRED TO. IT IS 1.84KM (refer to paras 4.34 – 4.36)

4.30 Parcel 141 – Land at 154a Walsall Road, Great Wyrley  The site is just of Walsall Road near to shops and services and directly opposite a bus stop.  The site is approximately 1.4km away from Landywood Railway Station and 0.5km from Great Wyrley High School

4.31 Parcel 139 – Land at Cool View, Churchbridge, Great Wyrley  The site is within close proximity to St Thomas Moore Primary School.  Approximately 0.4km from Walsall Road.  0.8km from Great Wyrley Performing Arts High School.  About 3km from Landywood Railway Station (refer to paras 4.34 - 4.36)

4.32 Parcel 136 – Land at Landywood Lane, Great Wyrley  Approximately 200m from Landywood Railway Station.  0.9km from Walsall Road.  Around 1.64km from Cheslyn Hay High School  Proposed Public Open Space Green Infrastructure SAD 136 APPENDIX 5

4.33 Parcels 116 and 131 (and adjoining land) – the proposed Housing site in Cheslyn Hay will be accessed by vehicles from Warstone Road (A462), Plan page 50, opposite the approved access to the Weinerberger Quarry close to the Go Direct Distribution Centre, avoiding vehicles going through Cheslyn Hay to access the M6 Junction 11, M54 New Link Road & Employment Sites. The Housing site connects with the host settlement Cheslyn Hay using short distance legible pedestrian links, Wolverhampton Road (B4156) pavement and public footpath PRoW 11/18.  0.1km from Cemetery Street bus stop “Highly accessible by public bus services” Cannock to Wolverhampton City Core Bus Route connecting with the Metro Tram GBHMA.  0.25km from Pinfold Community Allotments recreational provision.  0.25km from Hollybush Garden Centre, aquaria, including 12 retail franchises, one of the largest independent Garden Centres in the UK.

 0.6km from the Mary Rose pub and restaurant (Moon’s Lane)  0.6km from Community hub, Cheslyn Hay Leisure Centre for sport and physical activity – a significant recreational facility, important for the health and wellbeing of communities, Cheslyn Hay Academy and Cheslyn Hay Primary School, sharing a site.  0.9km from Community hub for communal wellbeing, Cheslyn Hay Community Centre, Library and other community facilities supporting people sharing a site.  1.1km from Low Street/High Street, shops and services para 4.49. Cheslyn Hay is a Main Service Village with 6 other bus stops and two Core Bus Routes, connecting with Cannock a Sub-Regional Shopping Centre and McArthur Glenn Designer Outlet. From Cannock Town Centre, Chasewater Country Park is accessible by Bus. Refer to Bus Map page 16.  1.6km from Landywood train Station on the Chase Line a Strategic rail corridor within the GBHMA with Landywood Station accessing 3 international airports and HS2 in Crewe or Birmingham. SAD 136 provides extended Green Space Infrastructure to Landywood Station. There is a community network of Green Space Infrastructure from the proposed Housing site to the Station. APPENDIX 4, APPENDIX 5, APPENDIX 6c  0.0km from public footpath Cheslyn Hay 18 and Saredon11 community green infrastructure linking Cheslyn Hay using the footpath to access Warstone Road (A462)  0.0km from Warstone Road (A462) – 0.75km M6 Junction 11/1km M6 Toll (T8)  0.0km from Warstone Road (A462) – 0.75km M6 Junction 11/Highways England two lane dual carriageway new Northern Motorway Link Road preferred option providing the highest benefit to the local economy with the best journey times, reducing travel.  0.0km from Warstone Road (A462) – 0.75km M6 Junction 11/ 3km to M54 Junction 1, Hilton Park Strategic Employment Site/5km to M54 Junction 2 i54 Strategic Employment Site and ROF Featherstone future Strategic Employment Site for more growth in jobs in ‘this broad location’ as a Regionally Significant and attractive location for National and International investment to sustain and develop the local economy, supported by Local Authority Chief executives across the West Midlands.  0.0km from Warstone Road (A462) – 0.75km M6 Junction 11/5km to proposed West Midlands Strategic Rail Freight Interchange – M6 Junction 12 and new link road to Four Ashes Strategic Employment Site.  0.15km from the Campians Woodland & Quarry proposed restoration scheme suggested safeguarded land public open space, protected woodland and recreation area ROMP planning condition 56 (Site 116 SHELAA 2018) and Environmental Statement (paras 4.5 - 4.8 above) and 1996 Local Plan Policy R6 ‘of great value to the community’ APPENDIX 3b. Community green space linking with the existing public open space Lapwing Close linking, with the Forest of Mercia Way network APPENDIX 6c the proposed Housing site linking with Cheslyn Hay APPENDIX 4 high quality green infrastructure, walking and cycling links providing a great place to live. NPPF 2019 para 98 ‘adding links to existing Rights of Way Networks including National Trails.’ APPENDIX 6b 29

 0.3km from disused Wyrley Branch canal existing Forest of Mercia Way APPENDIX 6c with connections to a wider network of National Trails. The Forest of Mercia Way also connects with Cheslyn Hay APPENDIX 4 and will connect with SAD 136 to Landywood train Station APPENDIX 5 and will connect with the proposed Housing site PRoW 18.  0.45km using public footpath Cheslyn Hay 18 connecting the proposed Housing site with Dundalk Lane/’Lapwing Close public open space’ and with the protected Campians Wood safeguarded woodland extending the Forest of Mercia Way APPENDIX 3b. Cheslyn Hay 18 also connects with the Mary Rose pub and restaurant Moon’s Lane, and with Upper Landywood/Landywood Lane and Landywood train Station using the public highway pavement or SAD 136 APPENDIX 5  4.4km from the navigable Wyrley & Essington canal blue infrastructure using the disused Wyrley Branch canal Forest of Mercia Way community green infrastructure recreational route, for walking, jogging or running and or cycling, linking with the wider network.  7.0km from the prestigious Green Flag Awarded Roughwood Country Park LNR covering 61 hectares (151 acres) accessing Monarch’s Way using the Forest of Mercia Way disused Wyrley Branch canal community green infrastructure and navigable Wyrley & Essington canal blue infrastructure APPENDIX 6a, 6b, 6c (Core Strategy para 11.20 applies).  7.0km to 20km accessing the wider network of longer distance recreational routes and National Trails including Monarch’s Way, Staffordshire Way, Forest of Mercia Timberlands Trail, Beacons Way, the Heart of England Way and the National Cycle Network all interlinked with the navigable Wyrley & Essington canal blue infrastructure.(CS para 11.20)  20km from Chasewater Country Park using the Forest of Mercia Way disused Wyrley Branch canal green infrastructure and using the navigable Wyrley & Essington canal blue infrastructure linking with the short Anglesey Branch canal, accessing Chasewater Country Park, a Regional recreational facility covering 360 hectares (889 acres). (CS para 11.20)

4.34 Landywood train Station is unique, it is the only Station in South Staffordshire with access to the Chase Line, a Strategic public transport corridor in the GBHMA. Staffordshire County Council’s Transport Plan confirms that the preferred maximum walking commuting distance is 2km. Walking Distance (SAD 2018) to Landywood Station

 Cheslyn Hay, Parcel 119 – 1.84km refer to para 4.36  Great Wyrley, Parcel 141 – 1.4km  Great Wyrley, Parcel 139 – 3.0km refer to para 4.36  Great Wyrley, Parcel 136 – 0.2km

*Cheslyn Hay, Parcels 116/131 and adjoining land, (proposed Housing site) – 1.6km 4.35 With the exception only of parcel 139, the above parcels are within Staffordshire County Council’s 2km walking commuting distance to Landywood Station. Formatting the cdoument Parcel 139 is not, it is 3km. Parcel 119 – at 1.84km is beyond 1.6km refer to para 4.36 30

4.36 The Chartered Institution of Highways and Transportation (CIHT) ‘Guidelines for Providing for Journeys on Foot’ (2000) notes that walking accounts for over a quarter of all journeys and 4/5 of journeys less than 1 mile (1.6km).

4.37 Therefore, 4/5 of all journeys to the facilities which are described below, referable to the proposed Housing site which are no more than 1 mile (1.6km) from the proposed Housing site are easily accessible by foot and are highly likely to take place by walking.

4.38 Such facilities, which are easily accessible by foot over a short distance include:  Proposed Public Open Space & Green Infrastructure Forest of Mercia Way footpath link through Campians Woodland to Pinfold Lane Community Centre. Refer to Plan page 50.  100m to the Cemetery Street bus stop Core Bus Route connecting with the Metro Tram.  250m to the Pinfold Community Allotments recreational provision + Garden Centre.  600m to Community hub, Leisure Centre a significant recreational facility for sport and physical activity promoting healthier lifestyles important for the health and wellbeing of communities, Academy and Primary School sharing a site.  900m to Community hub for support, wellbeing, Community Centre, Library sharing site.  1.1km to the High Street one way traffic system, shops, services and 2 Core Bus Routes.  1.6km to Landywood train Station (Staffordshire County Council’s Transport Plan confirms that the preferred maximum walking commuting distance is 2km APPENDIX 4

4.39 NPPF 2019 paras 96 & 98 are relevant, refer to the Plan on page 35, it shows short distance legible pedestrian and cycling links providing a great place to live including Wolverhampton Road (B4156) pavement/footpath and footpath PRoW 11/18.APPENDIX 4, APPENDIX 6c Core Strategy 11.20 ‘Green Space Networks connecting residential areas with recreational sites (including allotments & Leisure Centres) and open countryside can help promote healthier lifestyles and greater recreational activity’ NPPF 2019 Para 96 States: ‘Access to a network of high quality open spaces and opportunities for sport and physical activity (Cheslyn Hay Leisure Centre) is important for the health and wellbeing of communities’

4.40 For these reasons the proposed Housing site providing new homes for the growth in jobs is in a highly accessible and exceptionally sustainable location within a short walking distance to all the above Green Space Networks, Community and wellbeing facilities and transport services. It accesses Cannock a Sub-Regional Shopping Centre by a short 3 minute train journey or by using 2 Core Bus Routes making good use of the exceptional public transport infrastructure with excellent intermodal public transport services using the Metro Tram, including accessing 3 international airports by rail and HS2 at Crewe or Birmingham.

4.41 The Weinerberger quarry planning permission (paras 5.45 - 5.47) implemented but not yet operational has an approved access to be constructed off Warstone Road (A462). For vehicles the proposed Housing site access (refer to plan page 50) will be located opposite the approved Quarry access, with details to be agreed with the Highway Authority. atting the sentence again There will be no vehicle access from the site to the B4156 Wolverhampton Road. ne 31

Wolverhampton Road (B4156) & it’s Highway Pavement is a short walking distance legible pedestrian link to the host settlement Cheslyn Hay

4.42 The Cemetery Street bus stop is 100m (0.06miles) walking distance which is highly accessible by public bus services including those along Wolverhampton Road (para 3.12 above), using 1 Core Bus Route connecting with the Metro Tram accessible using the highway pavement from the proposed Housing site. In close proximity to this bus stop are existing houses with a frontage on Wolverhampton Road (B4156). Behind these existing houses is the proposed Housing site (para 4.25 above). The same highway pavement used by residents from these existing houses, will also be used by residents from the proposed Housing site, to walk alongside this public highway, using the highway pavement/footpath over a short distance to access the Allotments and bus stop. (beyond the bus stop is the Leisure Centre)

4.43 There are 11 allotments in South Staffordshire. One of these is the Pinfold Allotments with a frontage on Wolverhampton Road, within 250m (0.16miles) short walking distance from the site, for open air recreational activity and communal wellbeing.

4.44 Across Wolverhampton Road and beyond the Pinfold Allotments is Cheslyn Hay Leisure Centre for sport and physical fitness and communal wellbeing within 600m (0.37miles) short walking distance from the site. The Leisure Centre shares the same extended site with Cheslyn Hay Academy and Cheslyn Hay Primary School supporting the community creating a Community hub. Students from the Academy and Primary School are able to use the adjacent Leisure Centre, there is no need to travel outside of this Community hub to do so.

4.45 Residents from the existing housing fronting Wolverhampton Road (B4156) can use the existing highway pavement to access the Leisure Centre by foot as well as using the same highway pavement to access the Allotments and bus stop. There are only 4 Leisure Centres in South Staffordshire. This Leisure Centre is on the ‘door step’ a short 600m walk from the proposed Housing site using the Wolverhampton Road highway pavement, so short a walking distance that use of the highly accessible Wolverhampton Road bus service will not be necessary.

4.46 The 600m walk is significantly less than 1 mile (1.6km). Walking accounts for 4/5 of Journeys less than 1 mile (1.6km para 4.36). Walking is highly likely to be the most practical and preferred option of choice. Walking this 600m also applies to students accessing the Academy and Primary School located on the same extended site as the Leisure Centre providing a valuable recreational and educational hub for communal wellbeing.

4.47 From Wolverhampton Road, Hill Street connects over a short distance with Pinfold Lane and another valuable Community hub for communal support and wellbeing, (page 27 above) comprising the Community Centre and Library. This Community hub is within a 900m (0.56miles) short walking distance from the proposed Housing site using Wolverhampton Road highway pavement, to access Hill Street, connecting with Pinfold Lane and the Community Centre and Library.

4.48 Pinfold Lane connects with High Street (and Low Street) forming a one way traffic system accessing a range of shops and services (para 4.49 below) and 2 Core Bus Routes along High Street, within a 1.1km (0.7miles) short walking distance from the proposed Housing site.

4.49 The South Staffordshire Local Plan identifies Cheslyn Hay as a Main Service Village. It is described as a sustainable settlement with a number of facilities including a Leisure Centre, several schools/Academy, convenience stores, pub/restaurants, library, village hall, doctors’ surgeries and dentists all easily accessible by using clearly defined legible public highway links Wolverhampton Road (B4156) pavement and public footpath PRoW 11/18, walking a short distance from the proposed Housing site. Using non car modes of travel Cannock Town Centre, a Sub-Regional Shopping Centre and the McArthur Glenn Designer Outlet are also highly accessible using public transport, by bus or by train from Cheslyn Hay.

4.50 The above plan demonstrates the existence of short walking distance, legible pedestrian links and means of access as described above to the host settlement Cheslyn Hay using an existing highway pavement alongside Wolverhampton Road (B4156) and using the existing community green infrastructure/network including public footpath PRoW 11/18.

Proposed housing site to rear of this housing frontage

Holly Bush Garden Centre Entrance to Materials Recycling Facility 4.51 View along Wolverhampton Road (B4156) towards Hollybush roundabout showing a continuous housing frontage. To the right is Hollybush Garden Centre and entrance to it and entrance to the Materials Recycling Facility (paras 5.58 - 5.62) 33

4.52 To the left of the above photograph extending almost from opposite the Garden Centre entrance is existing housing fronting Wolverhampton Road (B4156) up to the Hollybush roundabout. The proposed Housing site is at the rear of this existing housing. There is a short gap between the existing housing in which there is a private roadway junction with Wolverhampton Road previously constructed to access the 9 hole golf course and golf driving range development.

From the Hollybush roundabout to the M6 J11 and Highways England New Northern Motorway Link Road, is a short distance 500m

4.53 View from Wolverhampton Road (B4156) towards Hollybush roundabout showing a HGV vehicle on the roundabout turning into Wolverhampton Road (B4156) with housing frontage and pavement on the left. From the roundabout to the M6 J11 is 500m to access the Highways England new Link Road and Strategic Employment Sites without any traffic using the Local Authority network through the settlement of Cheslyn Hay.

Community green infrastructure Public Footpath PRoW 11/18 is a short walking distance legible pedestrian link to the host settlement Cheslyn Hay and to Landywood Station, the Forest of Mercia Way & National Trails

4.54 The proposed Housing site straddles Parish boundaries of Cheslyn Hay and Saredon Parish Councils. A Public Right of Way (PRoW) is located to the south east of the site (Cheslyn Hay 18 and Saredon 11). Cheslyn Hay 18 from the proposed Housing site provides an existing short walking distance legible pedestrian access to the Main Service Village of Cheslyn Hay. Saredon 11 extends this public footpath, linking with Warstone Road (A462).

4.55 There are numerous other short legible pedestrian links off Cheslyn Hay 18 accessing the existing housing estate, Lapwing Close, Dundalk Lane and accessing the Forest of Mercia Way.

4.56 Cheslyn Hay 18 also accesses the existing housing estate along Moon’s Lane, where the Mary Rose pub and restaurant is located APPENDIX 4 also accessing the Forest of Mercia Way..

4.57 Cheslyn Hay 18 also accesses the existing housing estate along Upper Landywood/Landywood Lane, from here there is a highway pavement to Landywood train Station. Cheslyn Hay 18 will connect with SAD 136 APPENDIX 5 extending the community green network to Landywood Station extending the Forest of Mercia Way to the train Station. Cheslyn Hay 18 already accesses the proposed Housing site as does Saredon 11, it will be enhanced/improved where necessary. APPENDIX 4 APPENDIX 6c 34

4.58 NPPF 2019 para 96 states : Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Cheslyn Hay has 1 of only 4 Leisure Centres in South Staffordshire ‘for sport and physical activity’.

NPPF 2019 para 98 states: Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails by adding links. EXISTING PROW 11/18 LINK WITH PROPOSED HOUSING SITE

Mary Rose Pub and Restaurant

New open spaces will be provided through the SAD as part of the delivery of new housing sites, to meet demands these will create. Opportunities to maintain and connect to, green infrastructure through new development, should be maximised. APPENDIX 4

Above image, using Cheslyn Hay 18 view towards Mary Rose pub and restaurant half way along the existing high quality, traffic free, community green infrastructure for walking/cycling. There is network access to another interconnected green infrastructure route at this pedestrian/cycling cross roads, in the middle of the host settlement of Cheslyn Hay APPENDIX 4, APPENDIX 6c This community green infrastructure includes public footpath PRoW 11/18 accessing the proposed Housing site. Using PRoW 11/18 from the proposed Housing site, it will be possible to walk/cycle to Landywood Station using the existing community green infrastructure community connections linking with the allocated SAD 136 green infrastructure providing extended links for the community. APPENDIX 5 35

Disused Wyrley Branch

Forest of Mercia Way Network from disused Wyrley branch canal to Mary Rose Pub and Restaurant, Moon’s Lane. APPENDIX 4

The Core Strategy para 11.20 states: It is recognised that Green Spaces and recreational facilities are important, but equally linkages between them are significant. Green Space Networks connecting residential areas with recreational sites and open countryside can help promote healthier lifestyles and greater recreational and physical activity. These Networks should be accessible as far as possible to all users including pedestrians, cyclists and horse riders and should link with existing networks such as Public Rights of Way and cross-boundary links. NPPF 2019 PARA 98 ‘ ADDING LINKS’ This network does connect with the proposed Housing site using PRoW 11/18. Above image from the Mary Rose pub and restaurant continuation of Cheslyn Hay 18 through the host settlement Cheslyn Hay to the disused Wyrley Branch canal Forest of Mercia Way. From this point the proposed Housing site is 300m continuing to use public footpath Cheslyn Hay 18 which will be improved/enhanced where necessary connecting into the Housing site layout. From the Forest of Mercia Way there are also existing walking/cycling connections to Lapwing Close public open space and Dundalk Lane within the host settlement of Cheslyn Hay. APPENDIX 6c South Staffordshire District Council proposes to link the Forest of Mercia Way with Campians Wood as part of the Campians Woodland & Quarry restoration scheme 2018 SHELAA ref: site116 – site also suggested for open space and safeguarded land for recreational use – refer to Core Strategy para 11.20. Refer also to Local Plan 1996 Policy R6 reproduced below. The restoration proposals for the site will create an amenity /nature conservation area of great value to the community. APPENDIX 3b POLICY R6 RECREATION AND OPEN SPACE PROPOSALS Details of the Proposals SITE 16: LAND AT CAMPIANS WOOD, CHESLYN HAY (3.4 Ha / 8.3 acres) The site contains the remnants of the old Campians Wood, which are strong landscape features, and it is proposed to thicken the existing woodland with further tree planting. A pond has been created and wetland plants will be introduced during the aftercare period. A footpath link leading north from the canal is also to be provided as part of the restoration proposals. The restoration proposals for the site will create an attractive amenity/nature conservation area of great value to the community. The site would be a natural extension of the Wyrley/Essington Canal and the existing Open Space at Lapwing Close. *This Restoration proposal was chronologically carried forward for 23 years paras 4.5 – 4.8 above.

GREAT PLACE to LIVE. South Staffordshire Integrated Transport Strategy, October 2017 Para 5.17: “The health and wellbeing of local communities will benefit from improved walking and cycling facilities ………………….that encourage increased physical activity”.

PHYSICAL ACTIVITY. South Staffordshire Integrated Transport Strategy, October 2017 Para 5.28: “The Cycling and Walking Investment Strategy 21 April 2017, sets out the Government’s ambitions to ………………….make cycling and walking the natural choices for short journeys, or as part of a longer journey”.

Para 5.32: “Increased physical activity will also be encouraged by maintaining and improving the Rights of Way ………………….networks” 36

FOREST OF MERCIA WAY Disused Wyrley branch Disused Wryley Branch Canal from canal providing walking, Lapwing Close public open space and jogging/running and cycling opportunities as Dundalk Lane connecting into the part of a network which proposed Housing site using public South Staffordshire footpath PRoW 11/18 Providing Safe, District Council seeks to extend referable to site Traffic Free, High Quality Green 116 Campians Wood Infrastructure part of the Forest of Quarry. Mercia Way improving emotional “A footpath link leading north from the Canal is health enjoying the open air and also to be provided as nature, inspiring people living in the part of the quarry restoration proposals” GBHMA West Midlands and which the District Staffordshire important for the health Council acknowledges to and well-being of communities, be “of great value to the Community” improving quality of life and physical fitness, creating a great place to live.

4.59 South Staffordshire District Council as part of the chronologically documented Quarry restoration proposals (paras 4.5 -4.8 above), has a requirement to extend a public footpath link from the Forest of Mercia Way shown in the photograph above, north through Campians Woodland linking to Pinfold Lane near to the Pinfold Allotments, in close proximity to the Community hub, Community Centre, Library and Leisure Centre. NPPF para 98 applies. ‘planning policies and decisions should..….. add links to existing Rights of Way Networks’. This is now achievable within a to be approved Campians Woodland/Quarry restoration scheme.

4.60 The Forest of Mercia Way is a high-quality green infrastructure that will link into the proposed Housing site layout using the existing public footpath PRoW 11/18, which will be improved/enhanced for the enjoyment of mobile and less mobile people of all ages.

4.61 The disused Wyrley Branch canal Forest of Mercia Way, for walking, cycling, jogging or running is in close proximity to the host settlement – Dundalk Lane, Lapwing Close public open space, linking with the proposed Housing site using public footpath PRoW 11/18. APPENDIX 6c

This network offers opportunities for health and recreation to those who use the towpath and boats alike with a positive impact on quality of life providing opportunities for enjoyment of this high quality public infrastructure for open air recreation promoting greater physical fitness and improved emotional health

The navigable ‘curly wyrley’, Wyrley and Essington canal with safe traffic free high quality blue infrastructure is an attractive recreational route for able bodied and less mobile people of all ages because it is a contour canal. Contour canals avoid the use of any locks, there is no change in water level.formattin It is popular with walkers, cyclists, runners and anglers. It is free and something the whole family can enjoy regardless of age or mobility and is accessible for everyone from the proposed Housing site, creating a better place to live, improving quality of life.

4.62 The Forest of Mercia Way includes the navigable Wyrley and Essington (‘curly wryley’) canal between the City of Wolverhampton and Chasewater Park Reservoir which was built as a reservoir to supply water into this canal and connecting canals. Chasewater Country Park 360 hecatres (889 acres) is owned by Staffordshire County Council, it is a Regionally Significant recreational facility accessible from the proposed Housing site (Core Strategy para 11.20).

4.63 After walking, cycling or running 4km (2.5miles) from Cheslyn Hay or from the proposed Housing site, to the junction with the navigable Wyrley and Essington canal, you can turn right towards the City of Wolverhampton, accessing the prestigious Green Flag Awarded Roughwood Country Park 61 hectares (151 acres) just 7km (4.4 miles) from the proposed Housing site. APPENDIX 6a

4.64 There are many inter-linking connections to other recreational routes and National Trails including the Heart of England Way, Beacon Way, Forest of Mercia Timberland Trail, Monarch’s Way and Staffordshire Way and National Cycle Network. APPENDIX 6b & APPENDIX 6c

4.65 From the proposed Housing site use of this extensive canal network blue infrastructure connecting with 2 Country Parks and with five National/Regional Trails provides exceptional access to more than 420 hectares (1,020 acres) of recreational facilities/cycle trails within the 2 Country Parks (Core Strategy 11.20 and NPPF 2019 paras 96 and 98 adding links).

4.66 This community infrastructure network for the enjoyment of mobile and less mobile people of all ages from the proposed Housing site, links to an expansive cycling network using canal towpaths throughout the West Midlands area linking with the National Cycle Network shown on the Maps below, which expansive Network the more enthusiastic cyclists (and long distance walkers) may

choose to use over greater distances. 38

The above Section of the Forest of Mercia Way from Cheslyn Hay towards Wolverhampton uses the canal towpath through Roughwood Country Park comprising 6 separate Local Nature Reserves covering 61 hectares (151 acres) linking with Monarchs’ Way within the largest Oak Woodland , in the West Midlands, is 7km (4.4 miles) from the proposed Housing Site. – APPENDIX 6a, APPENDIX 6b, APPENDIX 6c

The Core Strategy para 11.20 states: “It is recognised that green spaces and recreational facilities are important, but equally linkages between them are significant. Green space networks connecting residential areas with recreational sites and the open countryside can help people promote healthier lifestyles and greater recreational and physical activity.” ------“The Networks should where possible, seek to utilise and protect existing features such as footpaths, canal towpaths, and disused railway lines, and link into longer distance routes such as the Staffordshire Way, Monarchs’s Way and the Sustrans Cycle Network.”

Chasewater Country Park is accessible as shown above from the very short Angelsey branch canal linking with the Wyrley & Essington Canal (‘curly wyrley’), it is also accessible by bus from Cannock Town Centre as an option, refer to Cannock Bus Network Map page 16 above. This Country Park covering 360 hectares (889 acres) is accessible from the proposed Housing site (Core Strategy para 11.20 applies). NPPF 2019 para 98 states: “planning policies and decisions should protect and enhance public rights of way and access…for example by adding links to existing rights of way networks including National Trails.” Core Strategy para 11.20 applies.

Warstone Road (A462) is a short driving distance to the Highways England Strategic Transport Connections & Employment Sites (page 21 above) and to Cannock Town Centre and Four Retail Parks (page 41 below)

4.67 The A462 will provide vehicle access to the proposed Housing site. Access to 3 Motorways and Highways England new Northern Motorway Link Road 4.68 Junction 11 of the M6 motorway is within 0.5km (0.3miles) from the Hollybush roundabout and it is a further 250m (0.15 miles) along Warstone Road (A462) to the proposed Housing site access, a total of 750m. We have used the 0.75km distance in this report. 4.69 The Housing site access is within 1km (0.62miles) of M6 Toll (T8) and is within 3km (1.9miles) of M54 Junction 1 (accessing Strategic Employment Sites) using Highways England preferred option two lane dual carriageway Northern Motorway Link Road linking the M6 and M54 Motorways over a short driving distance.

Warstone Road (A462) – Hollybush Roundabout 0.5km (0.3 miles) to M6 J11 & Link Road

Strategic Transport Connections and Employment Sites.

4.70 Vehicular access to the proposed Housing site will be from Warstone Road (A462) opposite the Wienerberger quarry access close to the Go Direct Distribution Centre. There is excellent visibility towards Hollybush roundabout as shown in the photograph.

4.71 Beyond the roundabout and within some 500m (0.3miles) is Junction 11 of the M6 motorway and Highways England new Northern Motorway Link Road (expected opening date 2025) within this Regionally Significant broad location for National and View from the direction of proposed Housing site International investment supported access along Warstone Road (A462) by Local Authority Chief Executives across the West Midlands. 40

4.72 From the M6 Junction 11, the A460 north east links with the M6 Toll (T8) and links with the Churchbridge Triangle (Interchange) where there are Four Retail Parks.formatting the cocument The A460 also links with the A4601 crossing the A5 to Cannock Town Centre. (see image below)

THE SITE IS WITHIN THE CANNOCK TOWN CENTRE CATCHMENT AREA

CONNECTED BY ROAD (ALSO BY BUS – 2 CORE BUS ROUTES)

AND BY THE CHASE LINE (BY TRAIN)

Detailed view of Churchbridge Triangle (Interchange) showing the Retail Parks 41

THE SITE IS CONNECTED BY ROAD TO THE A34 & WALSALL TOWN CENTRE There is a Core Bus Route from Cannock Town Centre through Cheslyn Hay to Walsall Town Centre a Sub-Regional Shopping Centre, alternatively it’s a 13 minute train journey from Landywood Station to Walsall Station which is incorporated within The Saddle Shopping Centre.fo London Euston is an hourly service from Walsall Station. TRAFFIC LIGHT CONTROLLED JUNCTION DRIVING TO WALSALL (A34)

4.73 Warstone Road (A462) travelling south from the proposed Housing site, provides access to Willenhall (A462) and Essington (B4156). Turning left to Bloxwich (B4210) connects in Bloxwich with the A34 towards Walsall.

WARSTONE ROAD (A462) APPROACHING TRAFFIC LIGHT CONTROLLED JUNCTION

4.74 Travelling south a short distance 1.4km (0.84miles) from the proposed Housing site access, is a traffic light controlled junction. Straight ahead (A462) is Willenhall. The Junction has a left turn onto Broad Lane, (B4210) towards Bloxwich and Walsall connecting with the A34 in Bloxwich.

4.75 Using Broad Lane (B4210) driving towards Walsall connecting with the A34 is approximately 5.1km (3.2miles) from the proposed Housing site. This route is the most direct and quickest route from the proposed Housing site with the best journey time to the A34 (South) towards Walsall Town Centre. It is the shortest distance.

4.76 By way of comparison, from Warstone Road (A462) using Wolverhampton Road (B4156) driving through the host settlement Cheslyn Hay, using Station Lane and onto the same point where the B4120 connects with the A34 (towards Walsall) is approximately 10 km (6.2 miles), nearly twice the driving distance and for this reason there will be no traffic going through the settlements of Cheslyn Hay/Great Wyrley to access the A34/Walsall. It is the longest distance.

4.77 The Weinerberger quarry planning permission (implemented but not yet operational) has an approved access to be constructed off Warstone Road (A462) shown below. For vehicles the proposed Housing site access will be located opposite, close to the Go Direct West Midlands Transport Depot and National Distribution Hub with details to be agreed with the Highway Authority. Plan page 50. There will be no vehicle access to the B4156 Wolverhampton Road. There will be no traffic going through the settlement of Cheslyn Hay on the Local Authority network to access the M6 junction 11 new Highways England Northern Motorway Link Road Strategic Network and Strategic Employment Sites. The proposed access off Warstone Road (A462) will protect the Local Authority Network within Cheslyn Hay.

Approved Access to Weinerberger Quarry

5 GREEN BELT AND LANDSCAPE CONTEXT

5.1 The Core Strategy is clear that protecting the Green Belt is a high priority for the District Council together with maintaining the distinctive character and landscape of South Staffordshire.fatting t However, the Core Strategy is also clear that Green Belt release will be necessary to meet the housing requirements. (para 1.3 and 1.9 above)

5.2 Campians Woodland & Quarry was the subject of an appeal for housing in the Green Belt paras 2.6 – 2.9 above (APP/C3430/A/06/2019854I ) APPENDIX 8 which was dismissed as the appellant at that time was unable to demonstrate ‘very special circumstances’ that outweighed the harm to the Green Belt. Release of Green Belt land is now required.

5.3 The District Council has confirmed within the SDP that a Green Belt Review as part of the future local plan preparations will take place to identify sites to meet the Districts’ own housing need likely to increase as result of Core Policy 7 including the ROF Featherstone future Employment Site and to also meet a proportion of the unmet Housing Need from within the GBHMA.

5.4 The Strategic Housing and Economic Land Availability Assessment (SHELAA) October 2018 produced by South Staffordshire District Council paragraph 1.1 – Assessment of Housing Land ‘is a study of potential Housing and Employment Sites in the District’ and paragraph 5.63 states:

“it is clear from the summary table set out in Appendix 3 that there is very little scope to identify new housing supply within South Staffordshire within the current policy framework………. the vast majority of potentially suitable new supply from village or urban area extensions would require development on Green Belt land.”

5.5 The proposed Housing site is an extension to the host settlement Cheslyn Hay a Main Service Village requiring Green Belt release (where development should be focused) it is within the Cannock Town Centre Catchment Area, a Sub-Regional Shopping Centre. Cannock Town Centre and the proposed Housing site are highly accessible by public bus services using 2 Core Bus Routes and with excellent connectivity by train between Landywood and Cannock Stations which is a 3 minute train journey using the Strategically important Chase Line, this also connects with the Greater Birmingham Housing Market Area (GBHMA) and with many Regional destinations accessible from the National Rail Network, including 3 international airports and connections with HS2 at Crewe or Birmingham from Landywood Station.formatting the document to avoid ga There is intermodal connectivity with the Metro Tram within the GBHMA.

5.6 The proposed Housing site is well connected by short walking distance legible footpath links to Cheslyn Hay Leisure Centre (600m) 1 of only 4 in South Staffordshire, Academy and Primary School (all 3 sharing a site for communal support and wellbeing) and is well connected to Cheslyn Hay Community Centre and Library (900m and to the host settlement Cheslyn Hay shops and services (High and Low Street one way system- 1.1km) using short walking distance convenient and easy to use pedestrian links, all much less than 1 mile (1.6km). 44

5.7 The proposed Housing site achieves the objectives of para 11.20 of the Core Strategy and NPPF 2019 paras 96 and 98 (para 4.33 above) in a highly accessible and exceptionally sustainable location. It is highly accessible by public bus services including those along Wolverhampton Road. It has access to two Core Bus Routes within the Cannock Town Centre Catchment Area accessing Cannock a Sub-Regional Shopping Centre and the McArthur Glenn Designer Outlet and a Regional recreational facility Chase Water Country Park.formattting to avoid big gaps in te One Core Bus Route connects with the Metro Tram in Wolverhampton City providing intermodal public transport connectivity accessing the wider GBHMA.

5.8 The proposed Housing site is also located within the Chase Line Rail Corridor where the supply of housing is to be prioritised following £100m of publicly funded investment, which completed the rail electrification scheme in 2018. New electric longer trains were introduced May 2019 with significantly lower emissions (replacing old diesels) with significantly increased passenger capacity, to facilitate the prioritised housing supply planned to take place following on from the £100m investment, supporting the local economy by making good the shortfall in the housing requirement in a Regionally Significant and attractive location for National and International investment supported by Local Authority Chief Executives.

5.9 Landywood Station is unique. It is the only Station on the Chase Line in South Staffordshire that can benefit from this £100m investment in public transport infrastructure, with significantly increased service provision within the West Midlands conurbation where 48% of South Staffordshire residents work. The proposed Housing site is located within Staffordshire County Council’s preferred maximum walking commuting distance of 2km.

5.10 Improving the housing supply for the growth in jobs will sustain the £100m investment in public transport infrastructure with significantly increased capacity and service provision in the GBHMA connecting with the National Rail Network, 3 international airports and HS2 in Crewe or Birmingham and the Metro Tram system.

5.11 NPPF para 122 states:

“The availability and capacity of infrastructure and services (both existing and proposed) is a requirement for decision makers to ensure that development makes the most efficient use of land.”

5.12 This NPPF requirement for decision makers has been addressed in great detail in this submission demonstrating that the proposed Housing site is well served by the exceptional public transport infrastructure and with excellent public transport service provision. The site providing new homes for the growth in jobs enjoys exceptional inter-modal connectivity in the GBHMA. Within a short distance, 500m of the Hollybush Garden Centre roundabout the site has access to the new Highways England Northern Motorway Link Road connecting the M54, M6, M6 (Toll), connecting 5 Strategic Employment Sites accessing some 20,000 highly skilled job opportunities within exceptionally close proximity 5km (3.1 miles) of the proposed Housing site within this 45

broad location, as a Regionally Significant and attractive location for National and International investment. 5.13 The most efficient use of land, will result in the release of Green Belt land where there is the availability and capacity of infrastructure and service provision. The information detailed in this submission demonstrates the availability and capacity of infrastructure and service provision.

5.14 The proposed Housing site is within the Green Belt and for all the reasons detailed in this submission including paras 4.33 – 4.40 should be released to provide a better place to live providing for the health and well being of communities with access to 1 of only 4 Leisure Centres in South Staffordshire and with connectivity to the Forest of Mercia Way Network and should be released to support and sustain the 2 Core Bus Routes, 1 Core Bus Route connects with the Metro Tram – both Core Bus Routes access the Cannock sub-Regional Shopping Centre which bus routes and services are highly accessible. Additionally, the proposed Housing site should be released to support and sustain £100m of publicly funded investment in rail infrastructure and service provision with connectivity to the national rail network which is highly accessible, significantly increasing capacity on the Chase Line to provide for an increase in the supply of housing in the GBHMA with 3 international airports and HS2 connections at Crewe or Birmingham accessible by rail from Landywood Station in the Strategic Chase Line Corridor and should be released to access 20,000 job opportunities on 5 employment sites accessible from the Strategic Transport Connections including New Northern Motorway Link Road at M6 Junction 11, 750m (0.46miles) from the proposed Housing site which is in this broad location as a Regionally Significant and an attractive location for National and International investment.

5.15 A Core Bus Route Wolverhampton to Cannock Town Centre passes the proposed housing site boundary, it connects with the Metro Tram. With respect to public transport the appeal decision – paragraph 9.29 appeal ref: APP/C3430/A/06/2019854 states APPENDIX 8:

“it is agreed that Cheslyn Hay is highly accessible by public bus services, including those

along Wolverhampton Road.”

5.16 NPPF para 138 States:

“…. Where it has been concluded that it is necessary to release Green Belt Land for development, plans should give first consideration to land which has been previously developed and/or is well served by public transport…..” 5.17 With respect to the ‘site’s sustainability credentials’ Section 3 of the appeal decision – Inspector’s conclusions clearly states: 26.46 If there is to be new housing in South Staffordshire then Cheslyn Hay/Great Wyrley would appear to be at or very near the top of locations on sustainability grounds.

5.18 South Staffordshire Local Plan, Infrastructure Delivery Plan (IDP) 2018 Section 4 page 7 states: With the exception of some of the larger villages, public transport in South Staffordshire is generally poor, with links between north and south of the District particularly lacking. In more rural parts of the District, bus services are poor, with a 46

greater reliance on publicly resourced bookable bus services, particularly targeting individuals with mobile difficulties and other health issues.

5.19 Poor public transport in South Staffordshire - is in stark contrast to Cheslyn Hay which is uniquely placed with access to Landywood Station on the Chase Line and having the choice of two Core Bus Routes available within the Cannock Town Centre Catchment Area for use by residents in Cheslyn Hay accessing Cannock a Sub-Regional Shopping Centre, with one of these Core Bus Routes to Wolverhampton City using the Cemetery Street stop 100m from the proposed Housing site connecting with the Metro Tram.

5.20 The Metro Tram is part of a £1.5billion public transport investment, with plans to extend it. It has intermodal connectivity with a Core Bus Route passing the proposed Housing site, this will assist able bodied and less mobile people and those with no access to a private car.

5.21 The proposed Housing site has access to exceptional public transport infrastructure benefitting from excellent service provision with inter modal connectivity, by bus, train and tram. Using inter-modal public transport helps reduce private car use and emissions.

5.22 Passengers using bus services from the proposed Housing site and passengers from Landywood train Station can access the Metro Tramline by bus and rail connections from both ends at the Wolverhampton City intermodal public transport hub using bus services from the Cemetery Street stop 70, 71 or by using Landywood Station on the Chase Line to access Birmingham New Street ‘Grand Central’, connecting with the Metro Tram in the GBHMA.

5.23 The interlinking of housing supply, employment growth and infrastructure/service provision is fundamental to the achievement of sustainable development.of course this is how you do it isn’t The proposed Housing site is in a highly accessible and exceptionally sustainable location.

5.24 With respect to the Green Belt Section 3 of the appeal decision – Inspector’s conclusions states:

26.7 The land has no role in preventing Cheslyn Hay from merging with Great Wyrley and it is to the north west and outside the area that is important to maintaining a gap with Walsall. APPENDIX 8 NOTE. This is in stark contrast to the Landywood Lane Appeal where the Inspector concluded the Landywood Lane appeal site (paras 2.10 -2.11 above) ‘ would lead to substantial harm through encroachment and the almost complete merging of Cheslyn Hay and Great Wyrley.’ APPENDIX 8

5.25 With respect to the impact on the landscape and character of the area Section 3 of the appeal decision – Inspector’s conclusions states:

26.43 I agree with the Appellant and Local Planning Authority that appropriate and

necessary landscaping of the site would successfully incorporate the housing development within the landscape.

5.26 Located between the proposed Housing site access to Warstone Road A462 and the M6 Motorway, Hilton Park Motorway Services on both sides of the M6, are two separate mineral planning permissions. These two mineral permissions referable to the Wienberger quarry and to the Redhurst quarry are separated from each other by Hilton Lane shown below. 47

5.27 Hilton Lane crosses the M6 Motorway. Hilton Park Motorway Services are immediately to the south, accessible from Hilton Lane.

5.28 The M6 Hilton Park Motorway Service Area, is west and east of the M6.

5.29 East of the M6 are the two quarry sites described above, separated from each other by Hilton Lane, which has a junction with Warstone Road (A462).

5.30 East of Warstone Road (A462) is Hollybank Quarry forming a cluster of 3 quarries (shown in close proximity below and described on the plan, page 48).

5.31 The Green Belt and landscape context is considered as follows:

Potential Merging of Great Wyrley with Churchbridge (M6 Toll Holiday Inn) and Cannock. GREEN BELT. The remaining Green Belt between Cheslyn Hay/Great Wryley and Cannock is vulnerable, it has a key role in preventing the neighbouring towns merging into one another.

5.32 The merging of settlements Cheslyn Hay and Great Wyrley is highly relevant in the Landywood Appeal Decision, detailed in paras 2.10 and 2.11 above, informing the emerging Local Plan. 5.33 The proposed Housing site e is almost completely surrounded by previous development and ongoing development, with a legacy of mineral planning permissions which have changed, or are changing, or will change the character of the landscape. Plan page 50.

5.34 The Weinberger quarry planning permission (implemented but not yet operational) has an approved access off Warstone Road (A462 shown below). For vehicles the proposed Housing site access will be located opposite, with details to be agreed with the Highway Authority.

GREEN BELT. Potential Merging of Cheslyn Hay/Great Wyrley and potential merging with Churchbridge (M6 Toll, Holiday Inn) and Cannock

The appeal Inspector’s decision, (para 5.24 above) is relevant to the proposed Housing site when considering Campians Wood quarry for housing. “The land has no role in preventing Cheslyn Hay from merging with Great Wyrley” 49

Plan produced by Peacock +

Smith

Key GREEN BELT “The land has no role in preventing Cheslyn Hay from merging with Great Wyrley” (para 5.24 above)

Proposed Housing Site plus part of Quarry Restoration scheme to be approved 2021. Site K. …….CW = Campians Woodland Open Space Recreational Area & footpath link to B.

Education, Leisure and Community support facilities for communal wellbeing A. Cheslyn Hay Primary School, Academy, and Leisure Centre community sport hub B. Community Centre and Library hub near – P. Pinfold Lane Allotments C. The Mary Rose pub and restaurant

D. Landywood Station on the Strategic Chase Line in the GBHMA accessing the West Midlands conurbation with pedestrian/cycling footpath link to the proposed housing site. APPENDIX 4, APPENDIX 5

E. Forest of Mercia Way Network / PRoW 11 & 18 + CW footpath link to B, C + SAD 136 Open Space Proposed Extension of Forest of Mercia Way footpath link through CW to Pinfold Lane Community Centre and Library hub B. NPPF 2019 Para 98 ‘adding links’

Adjacent Built Development 1. Hollybush Composting/Recycling Site used by West Midlands Councils

2. Hollybush Garden Centre 3. Residential Properties fronting Wolverhampton Road (B4156) pavement link to A, B + P 4. Residential Properties by Hollybush roundabout, 500m to M6 junction 11 new M54 Link Road 5. Residential Property on Warstone Road (A462) 6. National Distribution Hub and Warehouse on Warstone Road (A462) 7. Go Direct West Midlands Transport Depot on Warstone Road (A462)

Mineral Extraction Sites F. Redhurst Quarry G. Holly Bank Quarry H. Weinerberger Quarry (opposite is the proposed Housing site vehicle entrance ) J. Cheslyn Hay (Rosemary) Quarry 50 K. Campians Wood Quarry Restoration scheme, CW = Woodland Open Space Re*creational Area footpath L. Former British Coal workings 50 Campians Wood quarry permission granted 1956 GREEN BELT “The land has no role in preventing Cheslyn Hay from merging with Great Wyrley” (para make sp5.24 above)

5.35 The plan below is reproduced from the ROMP Environmental Statement, it shows how the quarry

is to be worked excluding (safeguarding) Campians Wood (CW) and excluding (safeguarding)

the land South East and South West of Campians Wood – APPENDIX 7 Randon formatiing This is site 116 (2018 – SHELAA) which states, ‘Site also suggested for Open Space and Safeguarded land’. It has been carried forward for 23 years from the 1996 Local Plan.

5.36 The permission (ref CCB176) was granted in 1956 and was subject to 14 conditions for the working of clay, associated minerals, including coal. The permission area is known as Campians Wood Quarry comprising 27.1ha including woodland comprising the following areas.

7.7ha was offered to the District Council as public open space/woodland (CW) in the 2006

housing appeal (para 5.41 below). 5.3ha was occupied by British Coal for open cast coal extraction, since restored. 3 ha was acquired by Redrow Homes since developed for housing accessed from Pinfold Lane in close proximity to the Community Centre and Library, near Pinfold Lane Allotments. 4 ha or thereabouts of the quarry is flooded (close to Wolverhampton Road). 2ha or thereabouts perimeter landscape mounding and slopes to flooded area. APPENDIX 7 The balance of the 27.1ha is 5.1ha. paras 4.2 & 4.3 above

5.37 In 1997 a Review of the (1956) Old Mineral Permission (ROMP Review) was determined by the Mineral Planning Authority and a new development consent with a new set of planning conditions issued. An Appeal against the conditions was submitted. It was finally determined by written representations with both the appellant and MPA reaching agreement on planning conditions acceptable to both parties. These planning conditions required the submission of a restoration scheme for the approval of the Mineral Planning Authority (condition 56) by 16 December 2016 in consultation with the District Council. APPENDIX 7 concept restoration scheme.

5.38 The submission of this restoration scheme has been deferred by agreement for a period of 5 years until 2021 APPENDIX 3a to allow discussions with the MPA Staffordshire County Council and South Staffordshire District Council to take place in respect of promoting the site (or some part of it) for residential development which will require its release from the Green Belt including

provision of footpath link/public open space/woodland (CW) bringing forward safeguarded

land for valuable community use, during the emerging Local Plan with some housing.

5.39 The emerging Local Plan will also take into account the Open Space Sport and Recreation SPD and quarry restoration scheme including woodland footpath link to the Forest of Mercia Way. 5.40 As detailed previously, Campians Wood (CW) is referred to in the 1996 Local Plan Policy R6 APPENDIX 3b “ a footpath link leading north from the canal (through Campians Wood) is also to be provided as part of the restoration proposals. Restoration proposals for the site will create an attractive amenity/nature conservation area of great value to the Community. APPENDIX 6c

5.41 The quarry owners in the 2006 housing appeal had committed to provide the following:

 7.7ha (19acres) of landscaped open space to the south east of the site taking in the remnant woodland and some of the regenerated open cast coal area

5.42 The ROMP 2010 Environmental Statement concept restoration scheme para 13.2 states: The quarrying proposals will result in the provision of a substantial amount of recreational open space after restoration. APPENDIX 7 concept restoration scheme

5.43 Restoration proposals for the quarry were carried forward from 1996 into the 2018 SHELAA Site 116, which seeks to provide for open space and safeguarded land as part of the soon to be submitted quarry restoration scheme. (CW) “The site is potentially suitable” (for housing) “but subject to policy constraints – Green Belt not currently available. Site also suggested for open space and safeguarded land” . South Staffordshire District Council is a relevant consultee. Core Strategy para11.20 applies as does NPPF paras 96 and 98 ‘adding links’. The ‘substantial amount of recreational open space after restoration’ can finally be achieved with ‘an attractive amenity/nature conservation area of great value to the community’ with some housing. 52

5.44 The quarry land owner has repeatedly committed to providing a valuable area of public open space including safeguarded woodland for amenity and nature conservation purposes. Such commitment over many years is likely to continue through negotiations with the District Council via the Local Plan Review Process, to achieve some housing on part of the quarry site. The quarry landowner has indicated ‘it can be brought forward’ para 4.2 above & para 8.10.

Weinerberger Quarry and Manufacturing Plant, Warstone Road (A462)

5.45 This quarry site is located opposite the proposed Housing site (across Warstone Road).This quarry planning permission (implemented but not yet operational) has an approved access to Warstone Road (A462). The quarry site extends towards and is in close proximity to the M6 Motorway and Hilton Park Motorway Services.

5.46 Planning permission to construct a clay product’s manufacturing plant, the excavation of clays and restoration through the deposit of inert and controlled waste has been implemented but not significantly developed, it follows the grant of planning permission in 1995.

5.47 Whilst the restoration scheme initially envisaged restoration of the site through the deposit of inert and controlled waste, no final restoration scheme has been agreed.fromatting this thing. Because the Waste Framework Directive seeks to minimise waste going to landfill, there are doubts that the site could be restored via the deposit of inert and controlled waste.

Redhurst Quarry, Warstone Road (A462)

5.48 Planning permission for the extraction of Etruria Marl, used in the manufacture of clay based building products such as bricks exists until February 2042. It is in close proximity to the M6 Motorway and Hilton Park Motorway Services.

5.49 The site does not benefit from an agreed restoration scheme. A concept restoration Masterplan indicates that a potential restoration of the site would be as a woodland and biodiversity enhanced area.

Holly Bank Quarry, Warstone Road (A462)

5.50 Planning permission for clay extraction at Hollybank Quarry was permitted in 1948. Currently the site does not have an agreed restoration scheme. The winning, working, storage of clay and restoration using imported wastes shall be completed by 21 February 2030. 53

Cheslyn Hay (Rosemary) Quarry near South Staffordshire Business Park

5.51 Cheslyn Hay (Rosemary) Quarry is located to the north of the proposed Housing site with access taken from Coppice Lane. This is an important and vulnerable area within the Green Belt currently preventing Cannock and Great Wyrley/Cheslyn Hay from merging into one another.

5.52 The site extends to an area of 38ha with permission for the extraction and stockpiling of mineral up to February 2042.

5.53 A report on the submission of a scheme of conditions under the Environment Act 1995 was presented by Officers to Planning Committee on 18 June 1998. Para 2.1 of the Committee Report States:

The company do not envisage any significant change in the current pattern of operations. There are extensive reserves in the quarry, which at current rates of extraction will last 50 years and well beyond the end date of 2042.

5.54 Whilst the original permission allowed for infilling of the site, this would only take place if material is available, and if it is economically viable to do so.

5.55 Currently, no restoration scheme for the site has been agreed with the Mineral Planning Authority. Such a scheme is unlikely in the immediate future due to a number of uncertainties regarding the availability of waste materials to infill the void, and because the quarry in order to mix and blend the available mineral must be worked in its entirety to create stockpiles, from which the blended mineral is subsequently removed for use.

5.56 Infilling any part of the quarry before the whole of it is worked out, would sterilise the mineral reserve, a nationally scarce resource.

5.57 This quarry and its mineral reserve is important because the manufacturing plant is adjacent to it, and if the mineral were sterilised, then the manufacturing plant would either close down with the loss of jobs, or alternatively would be reliant upon imported mineral, unnecessarily increasing LGV traffic on local roads. fuge gas as word is cpoo andformatting again doesn’t do it The vast manufacturing plant is shown below. The quarry is adjacent.

Holly Bush Garden Centre, Wolverhampton Road (B4156)

in close proximity to Proposed Housing site -- (Opposite)

Hollybush Wolverhampton Road Roundabout B4156 500m to M6 J11 and New Link Road

5.58 On the north side of Wolverhampton Road (B4156), opposite the proposed Housing site, is land comprising Holly Bush Garden Centre. A substantial Garden Centre complex with an extensive range of buildings, with aquaria, with café and children’s play area and pet area amongst its family friendly facilities providing franchise shops, a comprehensive range of garden furniture, house plants, shrubs and trees.format ting the page ag It has an extensive 250 plus macadam car park facility with overflow grass car parking and macadam/concrete delivery yard. 5.59 Hollybush Garden Centre and Aquaria is one of the largest independent Garden Centres in the UK offering a vast range of products at competitive prices. It is the perfect location for a day out in the West Midlands (www.hollybush-garden.com). It is a short walking distance from the proposed Housing site, separated only by Wolverhampton Road (B4156). Recycling Facility & Stockpiles not exceeding 5.5m accessed from Wolverhampton

Road (B4156) in close proximity to Proposed Housing site -- (Opposite)

Proposed Housing Site

Wolverhampton Road Entrance from Wolverhampton B4156 500m Road (B4156) to Materials Recycling Facility M6 J11 with 5.5m high stockpiles and New Link Road

5.60 On the north side of Wolverhampton Road (B4156) (associated with the Garden Centre) is land incorporating a composting facility for the processing of green waste from a number of West Midlands Local Authorities. It is highly accessible from the Motorway Network M6 junction 11 & New Northern Motorway Link Road. Plan page 50. 55

5.61 Planning permission (ref: SS.08/21/619 W) for a materials recycling facility is dated 12 September 2013. The approval permits a soil recycling area; an aggregate recycling area; stockpiling area and a wood recycling area, with stockpiles permitted over an extensive area not exceeding a maximum height of 5.5m above existing ground level. It is one of the UK’s largest compositing operations. It is one the first to be granted BSI PAS 100 standard by the Composting Association (now AFOR), as well as being designated a ‘Best Practice Site’ by WRAP, a government waste reduction initiative.formtaating this line

5.62 In combination, the Garden Centre, one of the largest in the UK and the recycling/compositing facility also one of the largest in the UK are within the Jack Moody group of companies. Both operations use the same common entrance from Wolverhampton Road (B4156).

National Distribution Hub Former City Link Depot accessed from Warstone Road (A462). Warehouse/Distribution Centre height not exceeding 9m

5.63 The proposed Housing site is located to the rear and to the side of this National Distribution Hub. Plan page 50. The Housing site also has a frontage on Warstone Road (A462) with a proposed vehicle access. (see plan below )

5.64 National Distribution Hub & Ware*house approved former City Link 25/06/1993 – application ref: 93/00052 with access from Warstone Road (A462). Go Direct Transport Depot access from Warstone Road (A462) approved 1994 – application ref: 94/00170, highly accessible from the Motorway Network M6 junction 11, M6 (Toll), M54 & New Northern Motorway Link Road.

Proposed Housing Site

Proposed Housing Site Proposed Housing Site Access Distribution Centre Weinerberger * Access Quarry Access Warstone Road (A462) 56

6 GREEN BELT EXCEPTIONAL CIRCUMSTANCES

6.01 Para 136 of the NPPF (2019) confirms that once established, Green Belt Boundaries should only be altered where ‘exceptional circumstances’ are fully evidenced and justified.

6.02 The SHELAA para 5.63 October 2018, clearly states “the vast majority of potentially suitable new supply (housing) from village or urban area extensions would require development on green belt land.”

6.03 The District Council has confirmed within its Statutory Development Plan that within the Greater Birmingham Housing Market Area (GBHMA) there is an unmet housing need for circa 60,000 homes in addition to its own housing need (taking account of Core Policy 7) which will require Green Belt release, South Staffordshire District Council will look to accommodate a proportion of the unmet housing need from the GBHMA.

6.04 The Statutory Development Plan confirms that in addition to the District Council’s own local need, which would require release of Green Belt Land, the requirement to accommodate a proportion of the housing need from within the GBHMA would also require Green Belt release. It is therefore fully evidenced and justified that there are exceptional circumstances for Green Belt release.

7. IMPACT ON LANDSCAPE

7.01 There is significant existing housing fronting Wolverhampton Road (B4156) opposite the HollyBush Garden Centre/Materials Recycling facility. The National Distribution Hub and Go Direct Transport Depot is a significant development with access from Warstone Road (A462). 7.02 When considering the immediate landscape context of the proposed Housing site there is already significant adjacent and nearby built development (including the settlement of Cheslyn Hay) as shown on the Plan (page 50) Proposed Housing Site Location, Adjacent Built Development and Surrounding Mineral Workings with Planning Permission.

7.03 In respect of Site 116 (Campians Wood quarry which ‘has no role in preventing Cheslyn Hay from merging with Great Wryley’ para 5.24 above) with regard to the impact on the landscape and character of the area Section 3 of the housing appeal decision (APP/C3430/A/06/2019854) APPENDIX 8 – Inspector’s conclusions states:

26.43 I agree with the Appellant and Local Planning Authority that appropriate and necessary landscaping of the site would successfully incorporate the housing development within the landscape.

7.04 The proposed Housing site is not located within a sensitive landscape area, such as an AONB or National Park, but is seen against the backdrop of the adjacent and nearby Built Development and surrounding mineral workings with planning permission. (Plan page 50).

7.05 In respect of Site 116 and Site 131 and adjoining land coloured blue – para 1.11 APPENDIX 1 not previously assessed for housing, it is considered there would be no adverse impact on the landscape as a result of the proposed housing development. 57

8. CONCLUSION

8.01 NPPF 2019 confirms at para 138 that where it has been concluded that it is necessary to release Green Belt land, plans should give first consideration to land which has been previously-developed and/or is well served by public transport.

8.02 This submission demonstrates that the proposed Housing site is exceptionally well served by public transport and by Strategic Transport Connections (page 21). It is located in a highly accessible and exceptionally sustainable Regionally Significant and attractive location in the GBHMA providing new homes for the growth in jobs. It will achieve the most efficient use of land within the District Council administrative boundary providing the best journey times, reducing private car travel and emissions, where public transport in South Staffordshire is otherwise generally poor (para 5.18 & 5.19 above).

8.03 The proposed Housing site APPENDIX 1 and page 50 has short walking distance legible pedestrian links using the Highway pavement along Wolverhampton Road (B4156) (refer to Plan page 27 above) to the host settlement Cheslyn Hay within 1.6km walking distance (para’s 4.33 – 4.40) of Cheslyn Hay Leisure Centre (600m) a significant sport and physical fitness recreational facility 1 of only 4 in South Staffordshire ‘physical activity is important for the health and wellbeing of communities’ (NPPF 2019 para 96), Academy, Primary School, Community Centre, Library, Allotments with exceptional public transport infrastructure, that includes 2 Core Bus Routes, 1 Core Bus Route connecting to the Cannock Sub-Regional Shopping Centre and McArthur Glenn Designer Outlet in one direction and Wolverhampton City and its Metro Tram with extensive inter modal connectivity for all ages groups and mobilities in the other direction within the GBHMA (paras 3.12 – 3.22 above). The other Core Bus Route through Cheslyn Hay connects with Walsall another Sub-Regional Shopping Centre. Refer to Cannock Bus Network Map connectivity page 16.

8.04 The site has pedestrian access using PRoW 18 linking into the community green infrastructure (refer to Plan page 35) linking into SAD 136 APPENDIX 5 extending the green infrastructure APPENDIX 6a, 6b, 6c linking with National Trails including 2 Country Parks also providing a traffic free route for walking/cycling in line with the Government’s ambitions (page 36 above) from the proposed Housing site to Landywood Station on the Chase Line within Staffordshire County Council’s 2km walking commuting distance paras 4.34 - 4.36 above. APPENDIX 4.

8.05 The District Council has previously set out its position in the Statement of Common Ground APPENDIX 8 in respect of the Campians Wood Housing appeal – para 9.2 states inter alia

Statement of Common Ground

“… Numerous bus routes pass close to the site with stops within convenient walking distance and it is proposed to provide the infrastructure to allow a bus service to pass through the site when development is substantially complete. Local linkages to other public transport intersections and to local services, employment and education are

sufficiently convenient to encourage future residents to consider journeys by modes other than the private car. The proposal meets the sustainable development objectives set out in PPG 13.” APPENDIX 8 of this submission

8.06 It is therefore without question (it is explicit) that the proposed Housing site is exceptionally well served by public transport and meets the objectives of para 138 of the NPPF.

8.07 The District Council in the Statement of Common Ground also made it explicitly clear that ‘employment and education are sufficiently convenient to encourage future residents to consider journeys by modes other than the private car.’

8.08 Within South Staffordshire 48% of residents work in the West Midlands conurbation.

8.09 The railway infrastructure has benefitted from £100m publicly funded investment upgrading the Chase Line between 2014 - 2018 increasing timetable frequency from May 2019, providing more trains, more seats for more passengers to access the West Midlands conurbation connecting the National Rail Network and HS2 in Crewe or Birmingham and Metro Tram system using Landywood Station. The Metro Tram system is also recent with expanding inter-modal connectivity including by bus with the proposed Housing site, pages 16 and 17.

8.10 The SAD 2018 at para 11.2 confirms that new open spaces will only be provided as part of the delivery of new housing sites:

“New open spaces will only be provided through the SAD as part of the delivery of new housing sites, to meet demands these will create. Opportunities to maintain, enhance, and connect to, green infrastructure through new development, should be maximised.”

8.11 The proposed Housing site APPENDIX 1 and Plan page 50 as detailed in this submission is adjacent to PRoW 18 and includes the Campians Woodland & Quarry restoration scheme APPENDIX 7 concept restoration scheme and does maximise the opportunity to maintain, maximise and connect to green infrastructure as described. APPENDIX 3b, APPENDIX 4, APPENDIX 5, APPENDIX 6a, 6b, 6c APPENDIX 7.

8.12 PRoW 18 connects into the existing community green infrastructure, including the existing Lapwing Close public open space. It connects to Landywood Station RD136 APPENDIX 5, disused Wyrley & Essington branch canal APPENDIX 6c, the Forest of Mercia Way ‘footpath link’ to Campians Woodland 2018 SHELAA site 116 carried forward from the 1996 Local Plan ‘of great value to the Community’ APPENDIX 3b and beyond including 2 Country Parks accessing Local, Regional and National Trails APPENDIX 6a, APPENDIX 6b. The proposed Housing site therefore complies with para 11.2 of the Council’s 2018 SAD and para 11.20 of the Core Strategy and paras 96 & 98 of the 2019 NPPF ‘adding links’ APPENDIX 3b, 4, 5, 6a, 6b, 6c, pages 35 – 39 above.

8.13 The District Council has confirmed that Green Belt release will be necessary to accommodate its own housing need and a proportion of the housing need within the GBHMA. 59

8.14 The site is exceptionally well served by public transport (para 3.1 – 3.22) as evidenced above and is in a highly accessible and exceptionally sustainable location accessing nearby Strategic Transport Connections and Employment Sites providing new homes for the growth in jobs referable to the West Midlands Strategic Employment Study page 21 above. 8.15 There are therefore exceptional circumstances to justify Green Belt release also complying with the SAD 2018 para 11.2 maximising green infrastructure and linking Campians Woodland ‘ of great value to the Community’ with the Forest of Mercia Way. Plan page 50.

8.16 The submission confirms that within 5km (3.1miles), the site has access to 20,000 highly skilled employment opportunities in industries such as advanced manufacturing and aerospace all of which are supported by the Council, for example with the grant of planning permission for the i54 extension in 2019 and the allocation of ROF Featherstone for future employment and for example the new Northern Motorway Link Road between M6 Junction 11 and M54 Junction 1 which will provide the highest benefit to the local economy within this Regionally Significant ‘broad location’ for National and International investment, supported by Local Authority Chief Executives across the West Midlands.

8.17 The proposed Housing site providing new homes and ROF Featherstone a future Strategic Employment Site are within ‘this broad location’ identified as being a Regionally Significant and attractive location for National and International investment creating highly skilled employment opportunities paras 1.10 – 1.12 interlinking houses with employment. Para 1.1 of the SHELAA 2018 – study of potential housing and employment sites in the District.

8.18 This is the result of work in the former Structure Plan which identified these areas for future strategic investment, Strategic Transport Connections and Employment Sites and new Northern Motorway Link Road (due to open 2025) and electrification of the Chase Line completed 2018 a Strategic West Midlands Rail Corridor with people needing homes in this broad location within the GBHMA by making good the shortfall in the housing requirement.

8.19 ‘Public transport in South Staffordshire is generally poor’ (paras 3.17 & 3.18). This submission demonstrates compelling reasons and justification to release the proposed Housing site from the Green Belt making the most efficient use of the land providing new homes for the growth in jobs with exceptional public transport infrastructure and excellent services to meet the unmet housing need in this highly accessible and exceptionally sustainable location where the interlinking of housing supply, employment opportunities and transport infrastructure is fundamental and has been overwhelmingly demonstrated. NPPF para 122 states:

“The availability and capacity of infrastructure and services (both existing and proposed) is a requirement for decision makers to ensure that development makes the most efficient use of land.” 8.20 The site Promoter D Morgan PLC welcomes this opportunity to seek discussion with the District Council and relevant stakeholders to bring forward this site for housing development in the GBHMA accessing the West Midlands conurbation by public transport, interlinking new housing with employment provision, with Strategic Transport Infrastructure and with public transport infrastructure and service provision. The site providing new homes for the growth in jobs is in this broad Regionally Significant attractive location for National and International investment supported by Local Authority Chief Executives across the West Midlands. Refer to APPENDIX 9 Staffordshire District Council’s email 31/05/19 confirming the Preferred Spatial Options consultation will ‘ set out broad locations for growth’. This is our response.

Highways England New Northern Motorway Link Road between M54 Junction 1 and M6 Junction 11 & proposed Housing site location within 0.75km (0.47miles) of M6 Junction 11

APPENDIX 1

The remaining Green Belt between Cheslyn Hay and Great Wyrley and between Cheslyn Hay/Great Wryley and Cannock is vulnerable. It has a key role in preventing the neighbouring towns merging into one another Key South Staffs Boundary Cannock District Council SHELAA 2018 Site 116 and 131 and adjacent blue land is using: Site AJlocations2018 promoted by D Morgan PLC. REFER TO PLAN PAGE 50 AND PARAS 4.28-4.41

LANDYWOOD LANE PLANNING APPEAL, INSPECTOR'S CONCLUSION PARA 30:

"The proposed development of this Green Belt site would lead to substantial harm through encroachment and the almost complete merging of Cheslyn Hay and Great Wyrley and the 'very special circumstances' needed to outweigh the harm are not present" REFERABLE TO SAD 136 ABOVE APPENDIX 8 NORTH Scale 1:2500 © Crown copyright and database rights 2018 Ordnance Survey 100019681

62 APPENDIX 2 South Staffordshire District Council Employment Allocations SHELAA para 1.1study of potential housing and employment sites . Refer also to Strategic Transport Connections and Employment Sites Figure 5.1 reproduced from West Midlands Transport Strategy page 21 of this submission identifying the new Northern Motorway Link Road in ‘this broad location as a Regionally Significant and attractive location for National and International investment, supported by Local Authority Chief Executives across the West Midlands’. Refer also to South Staffordshire District Integrated Transport Strategy October 2017, para 5.2 which states: “delivery of transport infrastructure – is fundamental to creating the right conditions for growth in jobs and new homes”.

The New Northern Motorway Link Road will link M54 Junction 1 and M6 Junction 11 also accessing the M6 Toll (T8). The above plan identifies 3 Strategic Employment Sites, i54, ROF Featherstone, Hilton Cross, within the M54 corridor accessing Junction 1 and 2 within 5km (3.1miles) from the proposed Housing site, M6 Junction 11. 63

APPENDIX 3a The Quarry owner’s agent correspondence with Mineral Planning Authority in 2016

planning

Our Ref: AH/1717-01 transportation planning 13 September 16 Sent via e-mail and post environment design Julie Castree-Denton Team Leader - Waste Planning Policy and Development Control Staffordshire County Council 2 Staffordshire Place Tipping Street Stafford ST16 2DH

Dear Ms Castree-Denton

RESTORATION SCHEME-CAMPIONS WOOD QUARRY (REF: PAD1357).

Thank you for your letter received on 29 June 2016 in relation to the restoration of Campions Wood Quarry.

My Client has now approached South Staffordshire Council in respect of promoting the Site as a residential allocation in the Local Plan Site Allocation Document and we will shortly be writing to South Staffordshire Council to formally request the consideration of the Site in the emerging Plan. Whilst we hope to successfully promote the Site in the emerging Plan, we have been advised that irrespective of whether or not Campions Wood Quarry is included in the emerging Plan, South Staffordshire Council is committed to commencing an immediate review following the Plan's adoption. Therefore, if the current status of the emerging Plan does not enable the consideration of the Site at this juncture then we will engage with South Staffordshire Council to promote the merits of the Site for a residential allocation as part of the forthcoming review.

To clarify the consented position with regard to Site restoration, the current planning permission provides for quarrying up until 2042, with restoration of the Site not being possible until all mineral extraction has ceased. The current indicative arrangement shows the final Phase involving working across the entire quarry and thus precluding the possibility for progressive or early restoration.

As you are aware, Condition 56 of the ROMP Schedule Reference SS.09/08/611M requires a detailed restoration scheme to be submitted by 16 December 2016. Due to the reasons outlined above, we believe that it would be premature to submit a detailed restoration scheme before 16 December 2016 in order to comply with Condition 56. Accordingly, we wish to defer the submission of the scheme for a period of 5 years. The principal reason is to allow discussions with South Staffordshire Council to be progressed in respect of promoting the Site for residential development, upon completion of which we would hope to be in a position to more accurately understand the opportunities for advanced restoration.

Chester Office: South Manchester Office: Well House Barns Camellia House Bretton 76 Water Lane Chester Wilmslow 64 CH4 ODH SK9 SBB

AXIS IS the lrading name or AXIS PED Ltd Registered Office Registered III England and Wall:'s Company No 3872453 65 APPENDIX 3b (Campians Woodland & Quarry) 1996 Local Plan Policy R6 Recreation and Open Space Proposals. Refer to paras 4.5-4.8 above for 23 year chronology from 1996 to the 2018 SHELAA Site 116 ‘Site also suggested for open space and safeguarded land’ NOTE. Campians Woodland will become an extension of the Forest of Mercia Way with a footpath link to the Pinfold Lane Community Centre. NPFF 2019 Para 98 adding links

POLICY R6 RECREATION AND OPEN SPACE PROPOSALS The following sites have been identified for open space and recreation in the Local Plan. Many of the proposals are carried forward from existing adopted Local Plans. The District Council will, where appropriate, prepare design briefs for both large and small sites.

Site Area Number Location (Hectares) (Acres) 13 Land south of Featherstone 4.5 11.0 14 South of A5, Great Wyrley 9.3 23.0 15 South of Manor Drive, Shareshill 1.6 3.9 16 Land at Campians Wood, Cheslyn Hay 3.4 8.3 17 Stag Meadows, Kinver 6.5 16.0 18 The Bratch, West of Canal, Wombourne 2.5 6.2 19 Adjacent to Brickbridge Playing Fields, Wombourne 1.8 4.5 20 Littleton Colliery Spoil Mound, Huntington 10.1 25.0 21 North-west of Teddesley Road, Penkridge 3.5 8.7 22 Land at rear of Lapley Hall Barns, Lapley 0.4 0.9 23 Barnfield Sand Beds, Horsebrook Lane, Brewood 6.0 14.9 24 Land at Codsall Road, Bilbrook 2.3 5.7 Details of the Proposals

SITE 16: LAND AT CAMPIANS WOOD, CHESLYN HAY (3.4 Ha / 8.3 acres) The site lies to the south west of Cheslyn Hay and formed part of the Campians Wood Opencast clay and coal workings. It was included in the Streets Lane Opencast site and is to be reclaimed to amenity use as part of the restoration proposals. The site contains the remnants of the old Campians Wood, which are strong landscape features, and it is proposed to thicken the existing woodland with further tree planting. A pond has been created and wetland plants will be introduced during the aftercare period. A footpath link leading north from the canal is also to be provided as part of the restoration proposals. The restoration proposals for the site will create an attractive amenity/nature conservation area of great value to the community. The site would be a natural extension of the Wyrley/Essington Canal and the existing Open Space at Lapwing Close.

*Refer to 2006 Housing Appeal commitment to provide Landscaped Open Space safeguarding Campians Woodland and the 2010 ROMP Application Environmental Statement to provide a substantial amount of recreational open space after restoration of the quarry and to the 2018 SHELLA site 116, site also suggested for open space and safeguarded land, pages 49 & 50 of this submission. The quarry restoration scheme can achieve all of this. The District Council is an important consultee. * The emerging Local Plan will also take into account the Open Space and Recreation SPD 2018 SHELAA site 116 ‘Open Space and Safeguarded Land’ Core Strategy para 11.20, NPPF paras 96 and 98 adding links. *Staffordshire County Council as the Highway Authority had a duty under the provisions of the Countryside and Rights of Way Act (CRoW) Act 2000 to produce a full Rights of Way Improvement Plan (RoWIP). As requested by Government the County Council aimed to produce a local Cycle and Walking Investment Plan (LCWIP) during 2018.

APPENDIX 4 Existing Community green Network for walking/cycling from the proposed Housing Site to Landywood Station (SAD 136) Published 21st April 2017, “The Cycling and Walking Investment Strategy sets out the Government’s ambitions to make cycling and walking the natural choice for shorter journeys, or as part of a longer journey”.

1 2

3 4

Rear. Mary Rose Pub and Restaurant Front. Mary Rose Pub and Restaurant

5 6

the Station to the proposed Housing site. NPPF 2019 para 98 states: Planning policies and decisions should protect and enhance public rights of way and Core Strategy 11.20 states: Green space networks connecting access… for example by adding links to existing rights of residential areas with recreational sites and open countryside can way networks including National Trails. help promote healthier lifestyles and greater recreational activity 67

APPENDIX 5 (comprising 3 pages: 68, 69 & 70) SAD 136

The remaining Green Belt between Cheslyn Hay and Great Wyrley and between Cheslyn Hay/Great Wryley and Cannock is vulnerable, it has a key role in preventing the neighbouring towns merging.

Cannock District Council

Cheslyn Hay Great Wryley

*Refer to Landywood Lane Housing planning Appeal paras 2.10- 2.11 of this Submission

*Refer also to para 2.6 of this Submission, the Campians Wood Quarry Housing Appeal

*Refer to Landywood Lane Housing planning Appeal paras 2.10- 2.11 of this Submission

*Refer also to para 2.6 of this Submission, the Campians Wood Quarry Housing Appeal

SEE NOTE BELOW

SEE NOTE ABOVE Safeguarded land at site 136 to consider development potential on 5.2Ha as part of the current current Local Plan Review

*Refer to Landywood Lane Housing planning Appeal paras 2.10- 2.11 of this Submission Planning Appeal Inspector’s Decision referable to where housing development should be located… “Campians Wood site is preferable” APPENDIX 8

*Refer also to para 2.6 of this Submission, the Campians Wood Quarry Housing Appeal and Statement of Common Ground para 8.05 - 8.07 above & APPENDIX 8 70

APPENDIX 6a Roughwood Country Park link to Monarchs’ Way Core Strategy para 11.20 applies

THE PRESTIGIOUS GREEN FLAG AWARDED COUNTRY PARK. THE FLAG OF EXCELLENCE. Roughwood Country Park 61 ha (151 acres) comprising six interlinked LNRs is accessible from the proposed Housing site (refer to Plans on page 39) using the Forest of Mercia Way (and from Monarchs’ Way) in part using the canal towpath providing a great place to live. Within the Country Park there is a 8km (5 mile) circular walking/cycling trail, it includes access to Beechdale Park (on the other side of the M6 motorway) located opposite Rough Wood and Bentley Haye. The canal extends up to the Chase Railway line. Bloxwich North Station is within a short walk. The Chase Line accesses Landywood Station for access to or from Roughwood Country Park by train.

APPENDIX 6b Core Strategy para 11.20, Access to Local and National Connected Trails

Roughwood Country Park, 6 LNRs within 61 hectares (151 acres) with safe traffic free high quality community green infrastructure including 5mile circular trail and Oak Woodland.

Monarchs’ Way 1,000 km/625 miles Monarch’s Way follows the Wyrley and Essington canal towpath through Roughwood Country Park and is based on the lengthy route taken by King Charles II during his escape after defeat by Cromwell in the final battle of the Civil War at Worcester in 1651. There are connections to numerous other long distance trails.

Beacon Way – 29km/18 miles This community green route is from Sandwell at the heart of the West Midlands conurbation, and goes via the outskirts of Birmingham through the countryside of Walsall and into Staffordshire using the blue infrastructure of the Wryley and Essington canal towpath between Harden (Bloxwich) through to Pelsall. The walk takes in the Forest of Mercia and the banks of canals.

Forest of Mercia Timberland Trail – 14.4km/9miles The Timberland Trail is a circular walk in the Forest of Mercia area north of Walsall and south of the M6 (Toll) through and around historic Pelsall including Pelsall North Common (Wood Common) Nature Reserve. It heads to Wyrley and Wryley Common and includes towpath sections of the Wyrley and Essington canal and links with the Beacon Way.

Staffordshire Way – Long distance footpath 147.2km/92miles It was established by Staffordshire County Council spanning the length of the County from Mowcop to Kinver Edge, created by the County Council in responding to a recognised demand for access to the countryside. It is an important link using the blue infrastructure canal network. The Heart of England Way – 160 km/100 miles It provides recreational walking Milford (on the northern tip of Cannock Chase) in the north, and Bourton on the Water in the Cotswolds crossing the Wryley and Essington Canal near Chasewater Country Park, going through the length of the West Midlands Region.

APPENDIX 6c Disused Wyrley branch canal Forest of Mercia Way community green infrastructure linking into the proposed Housing site layout using public footpath PRoW 18

Disused Wyrley Branch

Forest of Mercia Way Network from disused Wyrley branch canal to Mary Rose Pub and Restaurant, Moon’s Lane. APPENDIX 4 The Core Strategy para 11.20 states: It is recognised that Green Spaces and recreational facilities are important, but equally linkages between them are significant. Green Space Networks connecting residential areas with recreational sites and open countryside can help promote healthier lifestyles and greater recreational and physical activity. These Networks should be accessible as far as possible to all users including pedestrians, cyclists and horse riders and should link with existing networks such as Public Rights of Way and cross-boundary links. NPPF 2019 PARA 98 ‘adding links’

EXISTING NETWORK LINKING INTO PROPOSED HOUSING SITE LAYOUT

FOREST OF MERCIA WAY Disused Wryley Branch Canal from Lapwing Close public open space and Dundalk Lane Disused Wyrley branch canal providing walking, connecting into the proposed Housing site jogging/running and using public footpath PRoW 11/18 Providing cycling opportunities as part of a network which Safe, Traffic Free, High Quality Green South Staffordshire Infrastructure part of the Forest of Mercia District Council seeks to Way improving emotional health enjoying extend referable to site 116 Campians Wood the open air and nature, inspiring people Quarry. living in the GBHMA West Midlands and “A footpath link leading Staffordshire, important for the health and north from the Canal is also to be provided as well-being of communities, improving part of the quarry quality of life and physical fitness, creating restoration proposals” a great place to live. which the District Council acknowledges to The Forest of Mercia Way will be extended be “of great value to the to include Campians Woodland with a Community” footpath link to Pinfold Lane and the

Community Centre, Library. Refer to paras 4.5 – 4.8 above for 23 year Chronology.

73 Disused Wyrley branch

canal providing walking, jogging/running and cycling opportunities as part of a network which APPENDIX 7

(SHELAA SITE 116) Campians Woodland & Quarry, Concept Restoration Scheme ROMP ENVIRONMENTAL STATEMENT (2010) REFER TO Paras 5.35- 5.44 and APPENDIX 3a CW = Campians Woodland will become an extension of the Forest of Mercia Way with a footpath link to the Pinfold Lane Community Centre NPPF 2019 Para 98 ‘adding links’. The Core Strategy para 11.20 recognises ‘it is recognised – linkages between them are important’. (refer to page 36 above)

APPENDIX 8 PLANNING HOUSING APPEAL DECISION EXTRACTS

(SHELAA Site 116) Campians Wood Appeal APP/C3430/A/06/2019854

Para 9.29 “…it is agreed that Cheslyn Hay is highly accessible by public bus services, including those along Wolverhampton Road.”

Para 26.7: “…The land has no role in preventing Cheslyn Hay from merging with Great Wyrley and it is to the north west and outside the area that is important to maintaining a gap with Walsall.”

Para 26.43 “…I agree with the Appellant and Local Planning Authority that appropriate and necessary landscaping of the site would successfully incorporate the housing development within the landscape.”

Para 26.111: “…The appeal failed at that time because ‘very special circumstances’ did not exist to justify development in the Green Belt.”

(SHELAA site 136) Landywood Lane Appeal APP/C3430/A/05/1194463 & APP/C3430/A/05/1194464formating

Para 21: “…The SoS agrees with the Inspector (IR16.43) that the Campians Wood site is broadly comparable to the appeal site with regard to conformity with the development plan and its locational relationship to the MUA but the appeal site is preferable in terms of accessibility. However, the SoS also agrees with the Inspector that the harm which the appeal proposals would cause to the Green Belt, in terms of the coalescence of Cheslyn Hay and Great Wyrley, should carry greater weight and that, whilst in the case of appeal B the balance is fine, of the two the Campians Wood site is preferable.”

Para 30: “…The proposed development of this Green Belt site would lead to substantial harm through encroachment and the almost complete merging of Cheslyn Hay and Great Wyrley and the ‘very special circumstances’ needed to outweigh this harm are not present.” 75

APPENDIX 9 CORRESPONDENCE WITH SOUTH STAFFORDSHIRE DISTRICT COUNCIL LPA and PEACOCK + SMITH

From: Sarah Lowe [mailto:[email protected]] Sent: 24 May 2019 12:23 To: Fox, Edward Cc: Gareth Glennon Subject: Meeting with officers: Land at Wolverhampton Road (B4156), Warstone Road (A462), Cheslyn Hay

Dear Mr Fox,

Peacock + Smith are instructed by our client D Morgan PLC to request a meeting with officers in respect of their site at Land at Wolverhampton Road (B4156), Warstone Road (A462), Cheslyn Hay.

We would be grateful if you could consider the content of the attached letter, and liaise with us over potential meeting dates; we have good availability throughout the month of June.

If you have any queries, please do not hesitate to contact us; contact details are included on the attached letter.

Kind regards

Sarah Lowe

Sarah Lowe Planner

0113 243 1919 Suite 9C Josephs Well, Hanover Walk, Leeds, LS3 1AB

peacockandsmith.co.uk

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Registered address: Westwood House, 78 Loughborough Road, Quorn, Leicestershire, LE12 8DX Registration No. 0130 6847

GG/01/5191 (24 May 19) CH

F.A.O. Ed Fox Planning Policy South Staffordshire District Council Wolverhampton Road Codsall WV8 1PX

24 May 2019

Dear Sir,

LAND AT WOLVERHAMPTON ROAD (B4156), WARSTONE ROAD (A642), CHESLYN HAY

I am instructed by our client, D Morgan PLC, to request a meeting with officers in respect of the above- mentioned site.

The Council’s Site Allocation Document (2018) confirms that within the Greater Birmingham Housing Market Area (GBHMA), there is an identified unmet housing need for circa 60,000 homes and South Staffordshire District Council has committed to undertake a Green Belt Review to identify potential housing sites for not only its own housing requirements, but also a proportionate amount of the housing need within the GBHMA.

A large portion of the site (Council ref: 131) was previously considered by the Council as part of the 2018 SHELAA Assessment and discounted as the site was considered to be disassociated with the host settlement of Cheslyn Hay. Notwithstanding, the Council confirmed at paragraph Para 3.1 it was agreed that footnote 4 defining ‘disassociated’ would be amended. The revised footnote would recognise that (on a case-by-case basis) it may be appropriate to include sites as ‘potentially suitable’ to a nearby village/urban area where the site is a short distance to the settlement and where strong visual and physical links could be demonstrated to the host settlement (e.g. legible pedestrian connections).

The SHELAA at paragraph 5.37 refers to footnote 4 and refines ‘disassociated’ as follows:

Our site has excellent connectivity to the host settlement of Cheslyn Hay by reason of existing public highways Wolverhampton Road (B4156) and PRoW 11/18 and as such cannot reasonably be considered to be disassociated from the host settlement of Cheslyn Hay having regard to the comments made at paragraph 5.37 (above).

Our site has the benefit of being free from any current workings or restrictions that would restrict its delivery within a reasonable time frame and nor is it within an area that would result in towns merging with one another. As such, it does not perform a key Green Belt function compared to other sites assessed in the SHELAA.

It also benefits from excellent public transport infrastructure (bus and train) with a Core Bus Route from Cannock Town Centre to Wolverhampton passing the Cemetery street Stop 100m from the site and 77 Peacock + Smith Limited T: 0161 359 4309 Registration No. 0130 6847 Registered Address: Westwood 53 King Street E: [email protected] House, 78 Loughborough Road, Manchester M2 4LQ W: peacockandsmith.co.uk Quorn, Leicestershire LE12 8DX Landywood train Station within a commutable 2km walking distance. Furthermore, the proximity of the site to the Community hub at Cheslyn Hay Leisure Centre, Academy and Primary School further enhances the sustainability credentials of the site.

Given the above, it is respectfully requested that officer’s provide dates to facilitate a meeting between the Council and ourselves and client to discuss compliance with the SHELAA paragraph 5.37 and to guide development at the site in the emerging plan.

Our client wishes to fully engage with the Local Plan consultation process and I look forward to hearing from you.

Should you wish to discuss any aspect of the above, then please do not hesitate to contact me on the number listed above, or via email ([email protected]).

Yours faithfully

GARETH GLENNON

CC D Morgan Esq: D Morgan PLC

Leeds London Manchester Dear Sarah,

Thank you for your email.

Currently our full focus is on proceeding towards our Preferred Spatial Options consultation that’s due to take place in autumn this year. This will set out broad locations for growth and a number of strategic infrastructure opportunities, but will not identify specific sites within these broad locations, as these will be identified as part of our Preferred Options consultation in Spring 2020.

We currently have well in excess of 600 site options and do not have capacity to meet promoters at this early stage before Members have even agreed our preferred spatial strategy. It may be that we request to meet site promoters following this consultation once we know the broad locations for growth following the autumn consultation. Therefore, unfortunately we are not currently in a position to meet you regarding SHELAA site 131.

Kind regards

Ed Fox

Assistant Team Manager (Local Plans) Enterprise & Growth South Staffordshire Council

Tel: 01902696418

Have you visited our website? https://www.sstaffs.gov.uk

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Email dated 31/05/2019 (10:19)

GG/02/5191(4 Sept19)Johnson

A Johnson Esq Director of Planning and Strategic Services South Staffordshire Council Wolverhampton Road Codsall South Staffordshire WV8 1PX

4 September 2019

Dear Mr Johnson

PREFERRED SPATIAL OPTIONS CONSULTATION AUTUMN 2019

Earlier this year, we were instructed by our client D Morgan PLC (www.dmorgan.co.uk) to approach your colleagues in the Local Plans Team to request a meeting to discuss our client’s promoted housing sites in Cheslyn Hay APPENDIX 1 (Site Plan), APPENDIX 9 (Correspondence).formatiting to avoid big gaps in the letter like not pleasemove over n Your colleagues confirmed at that stage members had not even agreed the preferred spatial strategy and as the Council has well in excess of 600 site options, they were not in a position to meet.

The Council has confirmed that the vast majority of new housing sites will require Green Belt release.

The NPPF is clear at paragraph 138 that “….Where it has been concluded that it is necessary to release Green Belt land, plans should give first consideration to land which has been previously developed and/or is well served by public transport…”

The NPPF Para 122 states that the Council should support development taking into account the availability and capacity of infrastructure and services, both existing and planned.

As you will be aware, 80% of South Staffordshire lies within the West Midlands Green Belt and 48% of residents within South Staffordshire commute on a daily basis to the West Midlands conurbation.

The South Staffordshire Infrastructure Delivery Plan (2018) confirms that with the exception of some of the larger villages, public transport in South Staffordshire is generally poor.

However, our site within Cheslyn Hay is the exception. It is exceptionally well served by public transport. Agreement with the Council is set out within the Statement of Common Ground APPENDIX 8 (Appeal extracts) for a housing appeal in 2006 that:

“Numerous bus routes pass close to the site with stops within convenient walking distance and it is proposed to provide the infrastructure to allow a bus service to pass through the site when development is substantially complete. Local linkages to other public transport intersections and to local services, employment and education are sufficiently convenient to encourage future residents to consider journeys by modes other than the private car. The proposal meets with the sustainable development objectives of PPG 13.”

The Council has within its Statutory Development Plan (SDP) Core Strategy (2012) and Site Allocations Document (2018) confirmed, in addition to the District’s own housing need, there is within the Greater

Peacock + Smith Limited T: 0161 359 4309 Registration No. 0130 6847 Registered Address: Westwood 53 King Street E: [email protected] House, 78 Loughborough Road, Manchester M2 4LQ W: peacockandsmith.co.uk Quorn, Leicestershire LE12 8DX Birmingham Housing Market Area (GBHMA) which includes the South Staffordshire District Council administrative boundary, an unmet housing need for some 60,000 houses.

The NPPF is clear at paragraph 138 that:

“….Where it has been concluded that it is necessary to release Green Belt land, plans should give first consideration to land which has been previously developed and/or is well served by public transport…”

As public transport in South Staffordshire is acknowledged to be generally poor, our site is exceptional in that as far back as 2006 it was agreed by the Council to be in a sustainable location with the ability to cater for journeys by non car modes of transport. This remains the case.

However, since the 2006 appeal decision, that position has become even better as there has been significant investment in public transport infrastructure with the introduction of the Metro Tram and the electrification of the Chase Line accessing the West Midlands conurbation with more frequent faster services and with intermodal connectivity by bus, by tram, by train. Refer to pages 14, 16, 17 of the submission.

Landywood Station (on the Chase Line) is within the County Council’s preferred maximum walking commuting distance of 2km, which is accessible via the high quality green infrastructure links for walking and cycling that adjoin and will be extended into the proposed Housing site resulting in a great place to live. The Council’s Integrated Transport Strategy (2017) at para 5.17 states that ‘GREAT PLACE to LIVE. The health and wellbeing of local communities will benefit from improved walking and cycling facilities that encourage increased physical activity’. APPENDIX 4 & 5

Para 5.28 – ‘the Cycling and Walking Investment Strategy 21 April 2017 sets out the Government’s ambitions to make cycling and walking the natural choices for short journeys, or as part of a longer journey’

The NPPF at paragraph 122 confirms that decision makers should support development that makes efficient use of land taking into account inter alia:

“the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use.”

The proposed Housing site is located within a Regionally Significant and attractive broad area for growth which is supported by West Midlands Chief Executives including the District Council. Refer to pages 4 and 21 of the submission. The Council’s Integrated Transport Strategy (2017) at para 5.2 states that:

The proposed Housing site’s location provides exceptional access to the Highways England Strategic Network thereby reducing private car mileage and emissions. It would result in no traffic going through the settlement of Cheslyn Hay to access existing and proposed Strategic Employment Sites at i54 and ROF Featherstone, Hilton Cross respectively, which Strategic Network will be further enhanced via the proposed Highways England new Northern Motorway Link Road. This Link Road will connect the M54 junction 1 to M6 junction 11, which is within 750m of the proposed Housing site access on Warstone Road (A462). The M6 Toll (T8) is within 1km. See Plan page 50 – attached for your convenience.

Leeds London Manchester The site is ideally located in a highly sustainable location exceptionally well served by public transport with exceptional access to the Strategic Transport Network and proposed Link Road within 750m. It will accommodate some 800 homes from the unmet local housing need and from the unmet housing need from within the GBHMA providing new homes for the growth in jobs at the nearby Strategic Employment sites accessible from the Strategic Transport Network.

I would welcome the opportunity of meeting with you to discuss any matters arising from the work we have undertaken in this detailed Spatial Options evidence base submission.

Should you require an electronic copy of the document then please do not hesitate to contact me via [email protected] or via the number below.

I look forward to receiving confirmation that this submission will be taken into account as part of the Preferred Spatial Options Consultation.

With kind regards

GARETH GLENNON

CC V Morgan: D Morgan PLC Enc Plan Page 50 of submission

Leeds London Manchester