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SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW
SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION
LAND OFF STATION ROAD, CODSALL
ON BEHALF OF RICHBOROUGH ESTATES
TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004
©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited
Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
CONTENTS:
Page No:
1. INTRODUCTION 1 2. CONTEXT 3 3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS 5 4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION 6 5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS 8 6. INFRASTRUCTURE DELIVERY PLAN 2019 12 7. GREEN BELT STUDY 2019 17 8. LANDSCAPE STUDY 2019 23 9. SUSTAINABILITY APPRAISAL 2019 26 10. RURAL SERVICES AND FACILITIES AUDIT 2019 28 11. HABITATS REGULATION ASSESSMENT REVIEW 2018 29 12. LAND AT STATION ROAD, CODSALL 30 13. CONCLUSION 36
APPENDIX 1: SITE LOCATION PLAN APPENDIX 2: ILLUSTRATIVE MASTERPLAN
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
1. INTRODUCTION
1.1 This representation is made by Pegasus Group on behalf of Richborough Estates to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to land off Station Road, Codsall, which Richborough Estates is promoting for residential development.
1.2 These representations respond to the following documents, including addressing the questions set out within the Local Plan Review Consultation Document:
• Spatial Housing Strategy, October 2019
• Infrastructure Delivery Plan, 2019
• Habitats Regulations Assessment Review, 2018
• Green Belt Study, 2019
• Landscape Study 2019
• Rural Services and Facilities Audit 2019
1.3 The representations are framed in the context of the requirements of the Local Plan to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework (NPPF), paragraph 35. For a Plan to be sound it must be:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
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d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.
1.4 The representations also give consideration to the legal and procedural requirements associated with the plan-making process.
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2. CONTEXT
Adopted Local Plan
2.1 The South Staffordshire Local Plan comprises the Core Strategy (adopted December 2012) and the recently adopted Site Allocations Document (adopted September 2018).
2.2 Policy SAD1 of the Site Allocations Document requires South Staffordshire Council to carry out an early review of the Local Plan, which must be submitted to the Secretary of State for Examination by the end of 2021. The Review must be comprehensive and consider the need for additional growth and plan appropriately for it. This Plan will review, as a minimum, the following matters:
• South Staffordshire’s own objectively assessed housing need and the potential for housing supply within the District (including existing safeguarded land identified through the Site Allocations Document) to meet this need;
• The potential role of housing supply options within the District to meet unmet cross boundary needs from the wider Greater Birmingham Housing Market Area (GBHMA), including from the Black Country;
• Employment land requirements for South Staffordshire, as identified through a comprehensive Economic Development Needs Assessment (EDNA);
• South Staffordshire’s potential role in meeting wider unmet employment needs through the Duty to Co-operate;
• The appropriateness of the existing settlement hierarchy and the strategic distribution of growth in light of new housing and employment needs;
• The need for further additional safeguarded housing and employment land for longer term development needs, and the role of safeguarded land in meeting housing shortfalls across the GBHMA, including South Staffordshire’s own needs;
• Gypsy, Traveller and Travelling Showpeople provision; and
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• A comprehensive Green Belt Review undertaken jointly with the Black Country authorities, to inform any further Green Belt release to accommodate new development within the District.
Local Plan Review
2.3 The Local Plan Review is necessary in order to respond to the increasing need for development, both within South Staffordshire, and within neighbouring authorities which form the Greater Birmingham Housing Market Area (GBHMA). South Staffordshire District Council has determined that the Local Plan Review will cover the period to 2037.
2.4 South Staffordshire District Council commenced on an Issues and Options (Regulation 18) consultation between Monday 8 October and Friday 30 November 2018.
2.5 The Spatial Housing Strategy and Infrastructure Consultation represents a second ‘Regulation 18’ consultation, prior to the publication of a ‘Preferred Options’ (‘Regulation 19’) Local Plan, anticipated to occur in Summer 2020.
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3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS
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?
3.1 The consultation document identifies a range of evidence relied upon by the Council to inform the preparation of the seven Spatial Housing Options.
3.2 Richborough Estates is pleased to see the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Strategic Growth Study forms part of the Council’s evidence base, along with the Strategic Housing and Economic Land Availability Assessment (SHELAA). The SHELAA 2018 provides the most up-to- date evidence on housing land availability in the district and, as such, is a key to identifying the reasonable alternative growth strategies to be considered through the plan-making process.
3.3 Richborough Estates is also pleased that the Council has had regard to evidence that will inform an updated Infrastructure Delivery Plan, including input from key stakeholders outside the District where necessary.
3.4 Whilst the Spatial Housing Strategy will represent a significant element of an overall spatial development strategy, the distribution of housing should be considered in the round having regard to other uses that are required within the District to 2037. The distribution of other requirements, including employment and social and community infrastructure, are intrinsically linked to the delivery of homes as part of a comprehensive, sustainable strategy.
3.5 In light of the above, the evidence identified to inform the Spatial Housing Options appears to omit other relevant technical reports identified at the Issues and Options stage which, it is assumed, will be utilised by officers in formulating the Preferred Options document in Summer 2020.
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4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION
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?
4.1 It is noted that all Spatial Housing Options take account of existing ‘potential’ sources of supply i.e. permissions, completions and current allocations. This approach, in principle, is supported. However, it is considered necessary to scrutinise the supply position for robustness.
4.2 Through the Local Plan Review it is considered essential to review all sources of housing supply, including existing commitments. Whilst it is recognised that the Site Allocations Document was only adopted in September 2018, further information or evidence may have arisen since adoption that raises questions of suitability or delivery of sites allocated.
4.3 All potential sources of supply should be scrutinised through the Local Plan Examination in Public, especially non-allocated windfall sites, and it is recommended that a site-specific housing trajectory is prepared to support the Preferred Options consultation in the Summer of next year. This should provide delivery assumptions in respect of any proposed preferred option allocation i.e. build out rates and lead in times.
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 dwellings per hectare?
4.4 It is noted that all Spatial Housing Options assume existing ‘safeguarded land allocations’ will be released for development. This approach, in principle, is supported. However, it is considered necessary to apply a level of further scrutiny to this potential source of future supply for robustness.
4.5 As set out above in respect of current commitments, further information or evidence may have arisen since adoption of the Site Allocations Document that raises questions of suitability or delivery of individual safeguarded land allocations.
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4.6 In respect of the safeguarded land allocations an assumption of 35dph has been utilised to determine the likely yield from this source of supply. This relates back to the recommendations of the Greater Birmingham Housing Market Area Study and is considered to represent a reasonable average assumption. However, this average density assumption should only be applied to a net developable area and not the total safeguarded area of 86.8ha established through Policy SAD3. This appears to be the case albeit the calculations utilised in arriving at the Council’s stated yield of 1,651 additional dwellings is not set out.
4.7 The safeguarded land allocations identified in Policy SAD3 are not strategic in size and there are no reasons why their delivery should be delayed. These sites are likely to provide a helpful boost to delivery in the early years of the plan period which would help to support longer-term delivery of strategic sites that may experience longer lead in times to delivery.
Question 4: Are there any other options we should consider?
4.8 Richborough Estates considers that there are no further options that need to be considered.
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5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS
Question 5: Do you agree that the 7 Spatial Housing Options are appropriate options to consider? Are there any alternative options we have not considered?
5.1 Richborough Estates supports the identification of the reasonable alternative spatial housing options that have been identified by the Council. It is considered that these represent appropriate high-level options to inform a preferred spatial strategy for housing growth.
5.2 Whilst the Spatial Housing Strategy Options have been presented as separate and distinct options, alternative strategies could be achieved through a hybrid of the options identified.
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 within the GBHMA?
5.3 Spatial Housing Strategy Option G is supported by Richborough Estates and represents an amalgamation of options identified through the Issues and Options consultation published in 2018. Richborough Estates considers that this option not only assists in providing improved infrastructure but also has due regard to where housing needs exist, including within the top tier sustainable villages and locations close to the Black Country conurbation. Allowing growth in the Tier 1 and Tier 2 settlements provides an opportunity to meet locally arising housing needs and offers opportunity to deliver new services, facilities and infrastructure that would assist in addressing local issues and provide community benefit for residents, including the provision of a new railway station car park at Codsall.
5.4 This strategy provides the opportunity to ensure that the necessary homes, along with supporting infrastructure, would be delivered in a timely and coordinated manner, to meet both the local needs arising from within the District, alongside those arising from the wider GBBCHMA.
5.5 In addition, the accompanying Sustainability Appraisal concludes it is the best performing option on the basis it is likely to result in the greatest positive impacts in terms of sustainability. It is recognised that the emerging Local Plan is not site- specific at this stage and through the proposed site selection process
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opportunities will be present to consider ways in which any negative impacts can be reduced through good design and/or mitigation proposals. Richborough Estates considers that the presence of environmental constraints, such as historic and natural environment assets, do not necessarily preclude development, as such assets can often be positively included or considered through informed site layout and good design.
Question 7: Do you agree that we should continue to explore options for a new settlement?
5.6 Richborough Estates supports the Council’s approach to continue exploring an option for the provision of a new settlement for delivering growth beyond this new Plan period. This is aligned to the recommendations of the Greater Birmingham Strategic Housing Market Area study which identifies two areas of search:
• Around Dunston
• Between Wolverhampton and Penkridge
5.7 Spatial Housing Option G only seeks to identify an ‘area of opportunity for a new settlement beyond the plan period’ recognising that, to date, no proposal has been put forward to demonstrate self-containment and deliverability. Therefore, it is clear that this potential source of supply should not be relied upon to meet the proposed housing requirement of 8,845 dwellings between 2019 and 2037.
Question 8: What other information (if any) should we consider before concluding that Green Belt release is justified?
5.8 The Issues and Options document highlighted the issue of ‘protecting the Green Belt’ recognising that around 80% of the South Staffordshire is designated Green Belt. In addition, it highlighted the issue of ‘protecting sensitive areas of Open Countryside beyond the Green Belt,’ recognising that much of the character of the countryside beyond the Green Belt is of high landscape quality.
5.9 In light of the emerging housing requirement, capacity within the existing urban areas and the issues and challenges associated with the natural and built environment identified by the Council, development will have implications for Green Belt or the open countryside beyond. Richborough Estates considers the
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Council’s evidence is clear and conclusive in requiring Green Belt release to deliver a sustainable and sound spatial development strategy to 2037. This evidence supports a strong case for demonstrating the necessary exceptional circumstances for such release.
5.10 Of the seven Spatial Housing Strategy options identified, only one (Option A) would negate the need to remove land from the Green Belt. The Council concludes that this option is ‘unsustainable and potentially undeliverable’ as set out in paragraph 5.11 of the consultation document. Richborough Estates supports the Council’s conclusion in respect of this option.
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?
5.11 Richborough Estates broadly agrees with the site selection methodology that will inform the identification of preferred options. It is considered that the methodology provides a more appropriate basis for assessing sites than the methodology utilised through the formulation of the Site Allocations Document (SAD) that utilised a flawed scoring system.
5.12 In respect of the staged approach outlined in Appendix 6, Richborough Estates agrees it is sensible to sieve promoted sites to exclude those that are likely to yield less than 10 dwellings and to remove those that are poorly related to existing settlements or which are adversely affected by key constraints that cannot be overcome.
5.13 The methodology identifies a range of criteria to inform the Council’s judgement. It is noted that the ordering of these factors does not imply the level of weight that will be given to each criterion in the site selection process and this is supported as the correct approach.
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?
5.14 Richborough Estates agrees that when selecting sites to deliver the preferred spatial housing strategy, the Council should seek to avoid allocating housing sites
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that would result in very high Green Belt harm wherever possible. Having regard to the Council’s Green Belt evidence it would appear that there are options for delivering spatial housing option G without the need to allocate very high harm Green Belt land.
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6. INFRASTRUCTURE DELIVERY PLAN 2019
6.1 South Staffordshire District Council has produced an Infrastructure Delivery Plan (2019) to identify infrastructure projects required to support growth through preparation of the Local Plan Review. This forms part of the evidence base for the Local Plan Review.
6.2 At this stage, the role of the IDP is to identify the district’s baseline infrastructure requirements as well as known requirements that have emerged through engagement with infrastructure providers to date.
6.3 Regarding Codsall, the IDP identifies the opportunity to provide a deliver additional parking close to the station through the Local Plan Review. Staffordshire County Council has also identified parking for the Station as an issue in their Integrated Transport Strategy, October 2017.
Question 1: Do you agree that the delivery of the above infrastructure opportunities should be explored further? If not, please explain why
6.4 Richborough Estates agrees that that the infrastructure projects identified in relation to Codsall should be explored further. In particular, the development of land off Station Road, Codsall, offers the direct opportunity to deliver the additional railway station parking identified within the IDP. The ability for land off Station Road to deliver this additional parking is explored later within this representation.
Question 2: Having regard to the level of growth proposed for each village and broad location (see map), are there any other infrastructure projects that you like to see delivered?
6.5 At this time, Richborough Estates has not identified any other infrastructure projects required in respect of the broad locations for growth. However, this position may change once specific sites come forward at future stages of the Local Plan Review process.
General Comments
6.6 In additional to the questions set out within the IDP, Richborough Estates would make the following general comments in relation to the IDP.
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Delivery Mechanisms
6.7 Paragraph 3.1 of the IDP states:
“New development will need to be supported by new infrastructure where there is an evidenced need, and this will need to be at the cost of the developer. 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.”
6.8 Whilst Richborough Estates recognises the importance of development contributions towards the funding of infrastructure, public sector funding can, and should, also play a key role in the delivery of infrastructure, particularly strategic infrastructure. Public sector funding sources include Local Enterprise Partnership (LEP), central Government, grant funding or National Lottery funding. These funding streams should not be ignored.
Strategies
6.9 A number of strategies and studies are currently being drafted which will identify existing infrastructure provision and deficiencies, with a view to guiding future requirements. It is strongly recommended that these documents are expedited in order to understand relative infrastructure requirements across the District and how these may influence the proposed spatial strategy. The documents currently being prepared include:
• Playing Pitch and Sports Facilities Audit and Strategy
• Open Space Audit and Strategy
• Strategic Flood Risk Assessment and Water Cycle Study
• Brinsford Strategic Park and Ride Feasibility Assessment
• Viability Study
6.10 Whilst all of the above documents are important in informing the Local Plan, of paramount importance is the Viability Study, which will evidence the viability of development proposals, including the costs associated with the infrastructure identified to support the delivery of development sites. Abnormal costs associated
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with a development site may reduce the scope to deliver identified infrastructure requirements. The Viability Study will therefore determine if identified infrastructure is feasible in financial terms and whether the proposals and polices in the Plan are deliverable. It is therefore a key piece of evidence which will underpin and inform all elements of the Local Plan and should be completed before, and used to inform, a draft version of the Plan.
Community Infrastructure Levy (CIL)
6.11 The IDP identifies that the Council does not have a Community Infrastructure Level (CIL) charging schedule. However, the decision on whether to implement CIL will be taken ‘as the Local Plan progresses’, following identification of preferred sites, the outcome of the stage 2 viability assessment, and once a cost- benefit analysis of introducing a CIL has been undertaken.
6.12 Richborough Estates supports the acknowledgement that ‘new settlements or urban extensions need to be CIL exempt due to their significant upfront infrastructure costs’; a CIL requirement could otherwise make such developments unviable.
6.13 Richborough Estates nevertheless recommends caution regarding CIL, following changes to the CIL Regulations which came into force on 1st September 2019. These changes included the removal of the pooling restrictions and Regulation 123 Lists, and the introduction of new reporting requirements through Infrastructure Funding Statements (IFS). CIL authorities must produce their first IFS by 31st December 2020.
6.14 Although the new IFS will include information on how much money authorities have collected in developer contributions and how it has been spent, it is unclear how authorities will ensure effective monitoring, regulation and control of the relationship between CIL and Section 106 obligations.
6.15 With the removal of statutory Regulation 123 lists and the restriction on ‘double- dipping’ previously contained in Regulation 123, the only means of addressing the potential risk of ‘double-dipping’ between CIL payments and section 106 obligations will be through the limitations on the use of Section 106 obligations set out in Regulation 122 i.e. that the contribution is necessary to make the development acceptable in planning terms; is directly related to the development; and is fairly and reasonably related in scale and kind to the development.
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6.16 Regulation 122 assumes that the infrastructure to be secured through CIL will be identifiable and fixed for the whole development programme and that when entering into a section 106 agreement there is this certainty that the identified developer contributions will not be replicated in CIL payments.
6.17 However, with the removal of Regulation 123 lists, authorities will no longer be restricted in the application of anticipated CIL payments for any specific purpose. Authorities will be able to allocate CIL funds as they see fit and to re-direct such funds should the need arise.
6.18 As such, there is the potential for an authority to secure a S106 contribution to a certain infrastructure project, then subsequently divert CIL funds to ‘top up’ this funding in the future, effectively resulting in ‘double dipping’.
6.19 The absence of Regulation 123 lists accordingly places a significant emphasis on the importance of producing detailed IFS, which are then regularly kept up to date, to ensure that ‘double dipping’ does not occur.
Highways
6.20 Paragraph 5.20 of the IDP states:
“SCC confirmed that they are unable to determine the cumulative effect that the proposed level of growth (circa 9000 dwellings) for the plan period will have on the local highway network without knowing site specific locations. Once preferred sites are identified these will be provided to SCC who will then be able to consider traffic flows at specific junctions and identify where further assessment may be required.”
6.21 Whilst it is accepted that detailed highways modelling cannot be undertaken without considering traffic flows at specific junctions, it nevertheless remains a concern that this modelling will only take place once preferred sites are identified. It is plausible that sites may be identified in a ‘preferred options’ version of the Local Plan, which are subsequently demonstrated to be undeliverable in highways terms, or the cost of highways mitigation is so significant so as to render a site unviable.
6.22 Ideally, detailed highways modelling would be undertaken after the identification of preferred sites, but prior to the publication of the ‘preferred options’ version of
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the Local Plan, so that this modelling forms part of the evidence base at this stage.
Baseline Infrastructure Projects
6.23 Appendix 1 of the IDP identifies upwards of 80 specific infrastructure projects which are anticipated to be delivered during the plan period. A number of these are identified as being funded either entirely by private developers, or as a combination of public and private sector funding. However, in the vast majority of cases, the estimated cost of these projects is identified as being ‘unknown’.
6.24 If a planning application was to come forward on a development site which SSDC considered eligible to contribute towards an identified infrastructure project, SSDC would not be able to request a Section 106 contribution towards the project, as the total cost of that project, and therefore the necessary proportional contribution, would be unknown. Therefore, there would be no way of assessing whether the request for a S106 contribution met the tests set out in Regulation 122 i.e. that the contribution is necessary to make the development acceptable in planning terms; is directly related to the development; and is fairly and reasonably related in scale and kind to the development.
6.25 It is therefore of paramount importance that SSDC works with relevant parties to assess and cost specific infrastructure projects as soon as possible, particularly as these costings may have implications for the viability of certain sites and, by extension, the viability of the Local Plan.
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7. GREEN BELT STUDY 2019
7.1 South Staffordshire District Council has commissioned a Green Belt Assessment, alongside the City of Wolverhampton, Dudley, Sandwell and Walsall, (together comprising the Black Country authorities). The Study forms an important piece of evidence for the partial review of the Black Country Core Strategy (the Black Country Plan) and the strategic site allocations and individual development plans of the Black Country Authorities, as well as South Staffordshire District.
7.2 The Green Belt Study has two stages; the first is to assess ‘strategic variations’ between the contribution of land to the five purposes of the Green Belt, whilst the second includes a more focused assessment of the potential ‘harm’ of removing land from the Green Belt. Alongside the Green Belt Study, a Stage 3 assessment involved undertaking a landscape sensitivity assessment in order to assess the sensitivity of land within the South Staffordshire to housing and employment development. Whilst there is a relationship between landscape sensitivity and Green Belt contribution/harm in that physical elements which play a role in determining landscape character, there are fundamental distinctions in the purposes of the two assessments. As such, the findings of the Stage 3 landscape sensitivity assessment for South Staffordshire and the Black Country are presented in a separate document (Landscape Study 2019) and is considered later is this representation.
Green Belt Purposes
7.3 The National Planning Policy Framework (NPPF) states that the Green Belt should serve the five following purposes:
• To check the unrestricted sprawl of large built-up area;
• To prevent neighbouring towns merging into one another;
• To assist in safeguarding the countryside from encroachment;
• To preserve the setting and special character of historic towns; and
• To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
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West Midlands Conurbation
7.4 Paragraph 3.15 of the Green Belt study describes the area that has been identified as ‘the West Midlands conurbation’, which is defined as the main ‘large built-up area’ against which Purpose 1 of the Green Belt is considered.
7.5 The Study identifies that Codsall (contiguous with Billbrook) is considered to have sufficient separation from the main built-up area of Wolverhampton in order to be distinctly separate from the West Midlands conurbation.
7.6 Richborough Estates agrees with this assessment. Sites which separate Codsall and Billbrook from the West Midlands Conurbation1 therefore play an important role in their contribution towards Green Belt Purpose 1.
Land off Station Road, Codsall; Contributions to Green Belt Purposes
7.7 The Green Belt Study shows Land off Station Road, Codsall, as falling within Green Belt Sub-Parcel Ref S53H – ‘West of Codsall’, which is identified as making the following contribution to the five purposes of the Green Belt:
GB Purpose Assessment Rating Land contains no or very limited urban P1: Checking the development, and has strong openness. It is unrestricted sprawl of close enough to the large built-up area to have Moderate large built-up areas some association with it, but also retains some distinction. P2: Preventing the Land plays no significant role due to the distance Weak / No merging of between the West Midlands conurbation and the contribution neighbouring towns nearest neighbouring towns. Land contains the characteristics of open P3: Safeguarding the countryside (ie an absence of built or otherwise countryside from urbanising uses in Green Belt terms) and does Strong encroachment not have a stronger relationship with the urban area than with the wider countryside. P4: Preserve the setting and special Land does not contribute to the setting or special Weak / No character of historic character of a historic town contribution towns P5: Assist urban regeneration, by All parcels are considered to make an equal encouraging recycling Strong contribution to this purpose. of derelict and other urban land
Table 7.1: Land Parcel S53H Contribution Towards Green Belt Purposes
1 Site Refs: 221, 210 and 503.
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7.8 The Study goes on to identify that, should Green Belt Sub-Parcel ref: S53Hs2 (within which Land off Station Road falls) be released for development, the resulting harm would be ‘moderate-high’, stating:
“The sub-parcel makes a strong contribution to preventing encroachment on the countryside and a moderate contribution to preventing the sprawl of the West Midlands conurbation. Although these parts of the sub-parcel are separated from the edge of the adjoining inset settlement of Codsall by Oaken Lanes and a railway line, they are well contained by tree cover, as well as the existing house and grounds in the south of the sub-parcel to the east of the stream. These parts of the sub-parcel are also more strongly separated from the inset settlement of Oaken to the west. Release of this land would constitute a limited weakening of the Green Belt.”
Figure 7.1: Harm Ratings for Land Parcel S53H
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7.9 Whilst the conclusions of the above assessment are noted, it remains that Land off Station Road serves a reduced function against the five purposes of the Green Belt, as assessed below.
To Check the Unrestricted Sprawl of Large Built-Up Areas
7.10 The harm assessment for Green Belt sub-parcel S53Hs2 indicates that the parcel makes a ‘moderate’ contribution to preventing the sprawl of the West Midlands conurbation. However, as set out above, paragraph 3.15 of the Green Belt indicates that Codsall/Billbrook is not considered to form part of the West Midlands conurbation. It is therefore not understood how the Green Belt parcel can make a moderate contribution in preventing its sprawl, particularly when the parcel is located on the western side of Codsall i.e the side furthest away from the conurbation.
7.11 Development of the site would not lead to unrestricted sprawl of the built-up area as the site will remain enclosed along its southern and western boundaries by green infrastructure and its eastern and northern boundaries by the existing settlement edge of Codsall. Furthermore, the site would represent a relatively small-scale addition on the south-western edge of Codsall which would not extend further west or south than the existing settlement pattern, or the existing settlement limit set by properties on Canford Crescent/Fairfield Drive to the north. In addition, due to the significant wooded boundary, the site is visually self-contained.
7.12 It is therefore considered that the parcel makes a ‘weak/no’ contribution to the checking the unrestricted sprawl of large built-up areas, rather than the ‘moderate’ contribution identified within the Green Belt Study.
To Prevent Neighbouring Towns from Merging into One Another
7.13 The removal of the site from the Green Belt would amount to a negligible reduction to the separation distances between the built-up area of Codsall/Billbrook and the nearest neighbouring town.
7.14 Richborough Estates therefore agrees with the conclusions of the Green Belt Study, that the site makes a ‘weak/no’ contribution to preventing neighbouring towns from merging into one another.
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To Assist in Safeguarding the Countryside from Encroachment
7.15 Whilst the site contains some characteristics of open countryside, such as an absence of built development, it remains that the site has durable defensible boundaries, particularly to the south-west, that are afforded clear physical enclosure from the wider Green Belt. Furthermore, due to the existing uses that surround the site, its development would prevent further encroachment into the countryside.
7.16 It is therefore considered that the site makes a ‘moderate’ contribution to assisting in safeguarding the countryside from encroachment, rather than the ‘strong’ contribution identified within the Green Belt Study.
To Preserve the Setting and Special Character of Historic Towns
7.17 The site lies outside of Codsall Conservation area and, whilst it is located within the Conservation Area ‘buffer zone’, the existing vegetation along Oaken Drive and Oaken Lane serves to limit the visual relationship between the site and the Conservation Area. The character of the site is one of an ‘ordinary’ agricultural field enclosure defined by mature vegetation, an exposed railway embankment and consisting in part of built form: this is in contrast to the ‘parkland’ character of the Conservation Area. As such the removal of the site from the Green Belt would not affect the purpose of preserving the setting and special character of a historic town.
7.18 Richborough Estates therefore agrees with the conclusions of the Green Belt Study, that the site makes a ‘weak/no’ contribution to preserving the setting and special character of historic towns.
To Assist in Urban Regeneration, by Encouraging the Recycling of Derelict and other Urban Land
7.19 Whilst it is acknowledged that all Green Belt land makes a contribution towards encouraging the recycling of derelict and other urban land, the site and immediate area does not contain significant areas of brownfield land and would therefore not prejudice the redevelopment of urban land in this area. The release of the site from the Green Belt and allocation for residential development would therefore not significantly prevent the recycling of derelict land and other urban land.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
7.20 It is therefore considered that the site makes a ‘moderate’ contribution to this purpose of the Green Belt, rather than the ‘strong’ contribution identified within the Green Belt Study.
Summary of Green Belt Purposes
7.21 Overall, it is therefore considered that Land off Station Road, Codsall, makes a reduced contribution to the five purposes of the Green Belt than that identified within the Green Belt for Green Belt Sub-Parcel ref: S53Hs2. This contribution is summarised in the table below:
Previous Revised GB Purpose Rating Rating P1: Checking the unrestricted sprawl of large Weak / No Moderate built-up areas contribution Weak / No Weak / No P2: Preventing the merging of neighbouring towns contribution contribution P3: Safeguarding the countryside from Strong Moderate encroachment P4: Preserve the setting and special character of Weak / No Weak / No historic towns contribution contribution P5: Assist urban regeneration, by encouraging Strong Moderate recycling of derelict and other urban land
Table 7.2: Land off Station Road, Green Belt Assessment
Green Belt Harm
7.22 Given the reduced impact upon the five purposes of the Green Belt set out above, is contented that the Green Belt harm identified within the Study should be reduced from ‘moderate-high to ‘low-moderate’.
7.23 It is the view of Richborough Estates that the site makes a weak/no contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. The site would form a logical location for the expansion of the settlement edge, with the existing site boundaries representing strong defensible boundaries for the Green Belt edge in the future.
7.24 Therefore, release of this site would constitute a limited weakening of the Green Belt.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
8. LANDSCAPE STUDY 2019
8.1 South Staffordshire District Council has produced a Landscape Study (2019) which forms part of the Local Plan Review evidence base. Land off Station Road falls with Landscape Parcel Reference: SL36S1. These two landscape parcels subsequently fall within the ‘Ancient Clay Farmlands’ Landscape Character Type. The area is located north west of Wolverhampton, on the western outskirts of Codsall and extends to the village of Oaken.
8.2 An extract of the Council’s Appraisal of Landscape Sensitivity is included below:
Characteristic / Lower Sensitivity to Moderate Sensitivity Higher Sensitivity Attribute Development to Development to Development Generally small pastoral fields well defined by Fields to the north of hedgerows, with Scale the railway are larger in frequent mature field scale. and hedgerow trees which increase the sense of intimacy. Sloping landform which rises sharply Landform to the north from the edge of Landform of the railway line is Codsall at 115m more gently undulating. AOD, to the village of Oaken at 140m AOD. The landscape south of the railway line is characterised by 19th century parkland associated with country houses built for local industrialists and small pastoral fields (identified as post-1880s replanned enclosure). Larger 18th/19th century Landscape pattern planned enclosure and time depth are found north of the railway line and a small area of irregular post- medieval enclosure either side of Wood Lane. The landscape pattern has remained largely unchanged from the 1880s edition OS, resulting in strong time depth. Areas of semi-natural habitats include Priority Habitat deciduous 'Natural' woodland on the edge
character of Oaken and along stream corridors. Valued natural features include the
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
predominance of mature parkland trees, intact hedgerows and hedgerow trees. The parkland landscape to the south of the railway Two overhead electiricity Built features within the line within the routes cut through the landscape area include Codsall Billbrook and north western corner and residential properties on Oaken Conservation Built character the railway line runs the settlment edge of Area is associated east-west through the Oaken and Codsall and with two unlisted centre of the area. a few farms. 19th century country houses, The Terrace at Oaken and Springfield House. The parkland to the south has open Recreational The north of the area is access and is crossed
character not publicly accessible. by the Staffordshire Way Long Distance Recreational Route. The area has a Two overhead electricity strong rural routes introduce an character, extending urbanising element, Perceptual from the parkland to whilst noise from passing aspects the south to the trains may also detract working agricultural from the perceptual landscape to the qualities of the area. north. Although ribbon development along The area provides a Wood Road and rural setting for Moatbrook Lane present Codstall and Oaken, a weaker edge to the particularly within the Settlement settlment, strong Codsall Billbrook and
setting hedgerows and Oaken Conservation woodland belts along Area, which provides these roads and around an important rural Moatbrook Playing gap between the two Fields provide a strong settlements. barrier feature. The slopes surrounding Oaken Visual prominence are visually prominent within the local landscape. Inter-visibility with adjacent There is no inter-visibility designated with adjacent sensitive
landscapes or landscapes or marked promoted view viewpoints. points Landscape The landscape area has an overall high sensitivity to Sensitivity residential development due to its small scale, time High Judgement (SL36 depth, recreational value and visual prominence. S1)
8.3 The Study concludes that Landscape Parcel SL36S1 (which encompasses Land at Station Road) is considered to have a ‘high overall sensitivity to residential development, as identified on Figure 8.1 overleaf.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
Figure 8.1: Landscape Sensitivity Rating Parcel SL36
8.4 The findings of the Landscape Study for the wider parcel are not necessarily disputed by Richborough Estates. However, it remains that land off Station Road performs significantly better in landscape terms, principally due to the presence of mature vegetation including hedgerows, hedgerow trees, parkland trees and woodland, which block views from the west and south of the site. This existing vegetation will help to minimise the visual envelope of the site and will contribute to the capacity of the site to accommodate development.
8.5 Furthermore, the physical and visual relationship of the site to the existing urban edge of Codsall, in conjunction with the presence of features such as the railway line to the north detract from the overall landscape sensitivity of the site.
8.6 Matters relating to site-specific landscape sensitivity are considered further in Chapter 11 of this Representation.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
9. SUSTAINABILITY APPRAISAL 2019
9.1 Lepus Consulting has produced a Sustainability Appraisal of the South Staffordshire Local Plan Review: Spatial Housing Strategy and Infrastructure Delivery (‘the SA’), on behalf of the Council.
9.2 The SA assesses the sustainability effects of the seven growth options identified within the South Staffordshire Local Plan Review and does not assess the sustainability of individual sites or land parcels at this stage.
9.3 A summary of the findings of the SA is included below at Figure 9.1.
Figure 9.1: Summary of SA Appraisal Findings for Each Growth Option
9.4 Whilst it is acknowledged that the SA is ‘high level’ at this stage, it remains that the Council has commissioned a number of pieces of evidence to inform the Local Plan Review at this stage, including a Landscape Sensitivity Study (prepared by LUC, 2019).
9.5 This Study assesses the landscape sensitivity of 96 broad parcels of land and the subsequent degree of harm that would result if these parcels were to be developed. The Study concludes that these parcels demonstrate five degrees of varying sensitivity, from ‘low’ to ‘high’.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
9.6 Given the varying nature of these landscape parcels and their attributed sensitivity ratings, coupled with the varying typologies of the growth options presented in the Local Plan Review, it is illogical that all seven growth options should score the same (a ‘double negative’) in respect of Landscape and Townscape. Such a conclusion effectively renders the findings of the Landscape Study irrelevant in informing the preferred spatial strategy for growth.
9.7 It is therefore considered that more could be done to differentiate between the sustainability benefits of the seven growth options identified within the plan.
9.8 Nonetheless, Richborough Estates agrees with the overall conclusion of the SA at this stage, that Option G – ‘Infrastructure-led development with a garden village area of search beyond the plan period’ represents the most sustainable growth option available.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
10. RURAL SERVICES AND FACILITIES AUDIT 2019
10.1 South Staffordshire District Council has prepared a Rural Services and Facilities Audit (2019) (‘the RSFA’) which presents evidence on the relative level of services and facilities present in settlements within South Staffordshire.
10.2 The RSFA identifies five key indicators to compare the relative sustainability of settlements within the District as follows:
• Access to food stores;
• Diversity of accessible community facilities/services;
• Access to employment locations;
• Access to education facilities; and
• Public transport access to higher order services outside of the village.
10.3 Codsall is identified as falling within ‘Tier 1 Settlements’ which are described as:
“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.”
10.4 The overall settlement hierarchy scoring for Codsall is presented below.
Access to convenience stores/ supermarkets Diversity of other accessible community facilities/ services Access to employment locations Access to primary/ first school within settlement Access to secondary/ high school within settlement Access to 6th form/college within settlement Public transport access to higher order services outside of the village
Figure 10.1: Settlement Hierarchy Scoring for Codsall, RSFA (2019)
10.5 Richborough Estates supports the findings of the RSFA in relation to Codsall.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
11. HABITATS REGULATION ASSESSMENT REVIEW 2018
11.1 South Staffordshire District Council has produced a Habitat Regulations Appraisal (HRA) Review to support the Issues and Options consultation document. The report aims to identify and collect information in relation to designated European Nature Conservation sites which could be affected by proposals promoted through the Local Plan Review process. The report also provides an initial overview of the potential effects on European sites of the policy and growth options contained within the Local Plan Review Document.
11.2 However, the HRA Review has not been updated to consider or reflect the spatial options for growth presented within this latest consultation. The Review should be updated as soon as possible to consider the potential impact and necessary mitigation of preferred Housing Option G.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
12. LAND AT STATION ROAD, CODSALL
12.1 This Chapter sets out a brief description of the site, followed by an assessment of the site against each of the Council’s site selection criteria, as defined within the Site Selection Methodology for Preferred Options document (Appendix 6 of Spatial Housing Strategy & Infrastructure Delivery consultation).
Site Description
12.2 Richborough Estates has current land interests in land at Station Road, Codsall, as shown on the Site Location Plan appended to this representation (see Appendix 1).
12.3 The site adjoins the south-western edge of the urban area of Codsall, immediately south of the Birmingham to Shrewsbury railway line and west of the Station Road. The site is well contained and includes an area of agricultural land and woodland.
12.4 The parcels of land are subdivided by existing tree/hedgerow boundaries associated with the agricultural use of the land. The site is identified as Grade 3b quality agricultural land and therefore does not represent best and most versatile land (BMV).
12.5 The site lies within the West Midlands Green Belt but is adjacent to the current development boundary of Codsall. The site is located in Flood Zone 1; land having less than 1 in 1,000 probability of annual flooding. The site is also flat and not constrained topographically. The site represents a sustainable location, close to the village centre and opposite Codsall railway station.
12.6 The site has no other environmental or historical designations.
Green Belt Harm
12.7 As set out in Chapter 7, is contented that the Green Belt harm identified within the Study should be reduced from ‘moderate-high to ‘low-moderate’.
12.8 Development of the site will represent a relatively small-scale addition to the south-western edge of Codsall which will not extend further west or south than the existing settlement pattern, or the existing settlement limit set by properties
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
on Canford Crescent/Fairfield Drive to the north. In addition, due to the significant wooded boundary, the site is visually self-contained.
12.9 It is the view of Richborough Estates that the site makes a weak/no contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. The site would form a logical location for the expansion of the settlement edge, with the existing site boundaries representing strong defensible boundaries for the Green Belt edge in the future. The site is influenced by urbanising features such as the railway embankment and a number of buildings, largely constructed from corrugated metal sheeting.
12.10 Therefore, release of this site would constitute a limited weakening of the Green Belt.
Landscape Sensitivity
12.11 Again, Chapter 8 of this Representation sets out how South Staffordshire District Council’s Landscape Study (2019) concludes that Landscape Parcel SL36S1 (which encompasses the majority of Land at Station Road) is considered to have a ‘high’ overall sensitivity to residential development.
12.12 Nevertheless, Richborough Estates remains of the view that land off Station Road performs significantly better in landscape terms than the wider Landscape Parcel SL36S1, principally due to the presence of mature vegetation which blocks views from the west and south of the site. This existing vegetation will help to minimise the visual envelope of the site and will contribute to the capacity of the site to accommodate development.
12.13 Furthermore, the physical and visual relationship of the site to the existing urban edge of Codsall, in conjunction with the presence of features such as the railway line to the north detract from the overall landscape sensitivity of the site.
12.14 The landform of the site is relatively uniform which will reduce the potential for extensive earthworks during development, whilst existing water bodies and drainage ditches provide opportunities for wetland planting, recreation and habitat enhancement.
The Illustrative Masterplan for the site (see Appendix 2) offer a significant opportunity to enhance the landscape fabric and character of the site through the
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
retention of the existing trees and hedgerows and the creation of new public open space.
Sustainability
12.15 The Council’s Sustainability Appraisal (2019) does not consider site-specific details at this stage. Nevertheless, the site is located adjacent to the current built up area of Codsall, which is identified as a Tier 1 settlement within the Council’s Rural Services and Facilities Audit. The site accordingly benefits from good access to services and facilities in the village centre.
12.16 The site is located immediately adjacent to Codsall Railway Station, which provides regular rail services between Birmingham and Shrewsbury. The site also provides a unique opportunity to provide a dedicated car park to serve the railway station. Due to the location of the site in relation to the railway station, no other site would be able to deliver this benefit.
12.17 The site is therefore sustainably located.
Impact on the Historic Environment
12.18 Richborough Estates commissioned CgMs to prepare a heritage report, which assesses the built heritage implications of development of the site through a review of the identified built heritage assets and consideration of the impact of the scheme on the significance of the built heritage assets.
12.19 The report concludes that the development of the site will have no direct impacts on built heritage assets and no impacts on the settings of the identified assets. The sites location within a Conservation buffer zone instead provides the opportunity to both preserve and enhance the character and the appearance of the Conservation Area through sensitive design.
12.20 The provision of a station car park within the new development will enhance the setting of Codsall station and the southern extremity of the Codsall Conservation Area through the removal of parked cars from the station approach off Station Road.
12.21 In summary, the technical work undertaken to date concludes there are therefore no heritage constraints to the allocation of the site for residential development.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
Surface Water Flooding
12.22 Richborough Estates has previously undertaken technical work and a modelling exercise in respect of flooding and the Moat Brook.
12.23 In summary the modelling exercise demonstrates the flooding extent on the site is reduced from that shown on the EA surface water flood map, although it is recognised that mitigation measures will be required to accommodate built form in certain areas. The report goes on to propose two potential mitigation options utilising either land raising and creation of flood corridor within the site, or realignment of the existing ditch to the northern boundary of the site. Both options, following modelling, have been demonstrated to be able to mitigate flood risk to the 1 in 1000-year standard.
Highways (Accessibility to the Site)
12.24 The site has previously been assessed by Staffordshire County Council through the local plan process, who concluded that highways accessibility is ‘acceptable in principle subject to significant highway improvements.’
12.25 Technical work, has informed the Illustrative Masterplan for the site, with the proposed access arrangement for the site being achieved through a fourth arm of the mini-roundabout junction at Station Road/Chapel Lane/Oaken Lanes. The existing mini-roundabout would need to be enlarged to accommodate the additional arm, however, this is not considered to be significant.
12.26 Work has also been undertaken in relation to traffic generation, distribution and assignment and has been assessed using the TRICS 7.3.4 database. The forecast level of traffic associated with the development is considered to be minimal and the impact of development traffic is considered to be negligible. It is clear from site observations that the proposed junction arrangement can easily deal with the predicted level of traffic from the development proposal.
12.27 It is considered that the access arrangements for land at Station Road would represent fairly minor works and the site is therefore suitable from a highways perspective.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
Impact on Current Land Use
12.28 The site comprises Grade 4 agricultural land and is therefore not best and most versatile land. The loss of this land for development is therefore considered to be acceptable.
Impact on Natural Environment
12.29 A range of ecological assessments have been undertaken and a Tree Survey prepared to inform the Illustrative Masterplan. The Tree Report has recommended the removal of low grade trees to allow for the construction of an access to the site, which would not impinge on the viability of the remaining higher-grade trees on site.
Impact on Environmental Quality
12.30 Whilst it is accepted that development is unlikely to improve the environmental quality of the site as there are no existing issues of contaminated land, development would also not give rise to any environmental quality issues.
12.31 It is recognised that the site is adjacent to an existing railway line and a noise report has been undertaken to consider amenity issues. This report demonstrates that suitable mitigation can be achieved. The report concludes that BS 8233 requirements within dwellings can be achieved by use of appropriate acoustic rated windows and vents.
Site-Specific Opportunities
12.32 As set out previously within this Representation, the development of the site for residential purposes presents the opportunity to deliver a new car park to serve Codsall Railway Station, which is identified within the Council’s Infrastructure Delivery Plan as a future project.
12.33 This represents a significant benefit of allocating land at Station Road, Codsall, for residential development.
Suitability
12.34 The information set out above demonstrate that the Station Road site is a suitable site for development.
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
12.35 It is clear that the site has a low impact on the Green Belt purposes and that many of the potential impacts of development can be suitably mitigated.
12.36 The site represents a unique opportunity within Codsall to provide not only additional housing, but wider community benefits that cannot be delivered elsewhere, such as the proposed station car park, which will improve the sustainability of the wider settlement and provide opportunities to enhance the setting of Codsall station.
Deliverability
12.37 The site is within single land ownership and there is an agreement in place between the landowner and Richborough Estates to facilitate the development of the site.
12.38 A considerable amount of technical work has been undertaken to consider deliverability of this site. Richborough Estates can confirm that this work demonstrates that there are no constraints likely to render the site undeliverable in the plan period. The site is available now.
12.39 There are no existing uses that would require relocation and no issues of contamination that would require remediation. The impacts of development can be mitigated and, in many cases, a positive outcome can be achieved.
12.40 The site is deliverable and immediately available and, subject to allocation, could deliver homes and a new station car park within the next 5 years.
Illustrative Layout
5.32 Two Illustrative Masterplans are provided at Appendix 2 to provide an indication of how the site could be developed, taking into consideration the sites opportunities and constraints. The illustrative scheme incorporates the provision of a dedicated car park to serve Codsall railway station.
APPENDIX 2 – ILLUSTRATIVE MASTERPLAN
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Richborough Estates Land off Station Road, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery
13. CONCLUSION
13.1 This representation is made by Pegasus Group on behalf of Richborough Estates UK Limited to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to land off Station Road, Codsall, which Richborough Estates is promoting for residential development.
13.2 The information contained within this representation, read in conjunction with the appended Illustrative Masterplan, demonstrates that land off Station Road is a suitable and deliverable site for residential development, subject to its release from the Green Belt.
13.3 There are no existing uses that would require relocation and no issues of contamination that would require remediation. Many of the potential impacts of the development of the site can be mitigated through design and in many cases a positive outcome can be achieved.
13.4 It is therefore submitted that land off Station Road should be allocated for development through the Local Plan Review.
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APPENDIX 1
8
64
74 4
0 10 20 50 1 to 5 1
21 1
BENTLEY DR 9 7
8
1
47 FLEMMYNGE CLOSE 13 Codsall
GARDENS
8
CODSALL House 9 45 2 49 17 19 11 1 35 El 23 Sub Sta 7
46 FAIRFIELD DRIVE
WARWICK DRIVE
44 33 9
STATION ROAD
116.90
22 42 1
117.06 4 24 1 34
14 15 BRAMALL CL
21 14
117.16
3
1 2
30
6 26
11 45
24
6 20
CANFORD CRESCENT 18
28 36
1 30
20 3
9 1
34
7 5
5 LOVERIDGE
CL
9
4 Fh
1
2
8 57
118.23 42
8 2
Stay wire
10 21
44
El 9
Ppg Sta Sub 25 Sta 23
5 STATION CL
69
1
12 73 Codsall Station
Ward Bdy 24
1
Rb 1a CR 1b
Fh 3
Rb 5 5a 5b 7 7a 11a
9 9a 11 1
Endun
Lower Copperfield 6 Urra
Lodge One Tree
Tivoli CHAPEL 14
5 LANE
2a
16
26 2b
1 1
15
11 2
7 7
KINGSLEY GARDENS
36
2 9
LANES
12 OAKEN DRIVE 8
13
OAKEN Springfield 17
House 46
Penlon
Cilgwyn
BROADWAY
22
25 25
23
32 Pegasus accepts no liability for any use of this document other than its original purpose, or by the client, following Pegasus' express agreement to such use. T 0121 308 9570 www.pegasuspg.co.uk Copyright Pegasus Planning Group Ltd. © Crown copyright. All rights reserved. Ordnance Survey Licence number 100042093. Promap 100020449. Emapsite number. 0100031673. Standard OS licence conditions apply. KEY Site location 8.44 Ac/ LAND OFF STATION ROAD, CODSALL 3.42 Ha SITE LOCATION PLAN | PLANNING | DESIGN | ENVIRONMENT | ECONOMICS | www.pegasuspg.co.uk | TEAM/ DRAWN BY CLE/CLE | APPROVED BY:CLE | Date: 13/02/17 | SCALE: 1:2000@ A3 | DRWG: BIR.4759_12_2 I CLIENT: RICHBOROUGH ESTATES LTD I APPENDIX 2 NOTES
1. Contractors must check all dimensions on site. Only figured dimensions are to be worked from. Discrepancies must be reported to the Architect or Engineer before proceeding. © This drawing is copyright.
2. Reproduced from OS Sitemap ® by permission of Ordnance Survey on behalf of The Controller of Her Majesty's Stationery Office. © Crown copyright 2008. All rights reserved. Licence number 100007126.
SW Attenuation Area
SW Attenuation Area DRAFT 12/12/19
Proposed Access
REV DESCRIPTION DRN CHD DATE
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CONSTRUCTION AS BUILT
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DRAWN GS/JPG CHK CM
DRAWING NO. 18417/1005 REV -
TITLE Land off Station Road Codsall
DETAILS Coloured Sketch Layout
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