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SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW
SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION
LAND OFF WROTTESLEY PARK ROAD, PERTON
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 Wrottesley Park Road, Perton 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 25 9. SUSTAINABILITY APPRAISAL 2019 30 10. RURAL SERVICES AND FACILITIES AUDIT 2019 32 11. HABITATS REGULATION ASSESSMENT REVIEW 2018 34 12. LAND AT WROTTESLEY PARK ROAD, PERTON 35 13. CONCLUSION 42
APPENDIX 1: VISION DOCUMENT
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Richborough Estates Land off Wrottesley Park Road, Perton 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 Wrottesley Park Road, Perton, which Richborough Estates is promoting for a residential led development with supporting services, facilities and infrastructure.
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
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rather than deferred, as evidenced by the statement of common ground; and
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.
4.1 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?
4.2 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.
4.3 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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4.4 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.
4.5 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?
4.6 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 country park at Perton.
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 Perton, the IDP identifies the opportunity to provide a new country park at Perton, which would provide an opportunity to give residents access to strategic recreational opportunity, including access to the wider Green Belt and a significant area of green infrastructure with potential to link to the wider public Right of Way network beyond. Furthermore, the IDP identifies the opportunities for highways improvements around Perton, including improvements to the A41 junction that would alleviate some of the existing congestion.
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 Perton should be explored further. In particular, the development of Land off Wrottesley Park Road offers the direct opportunity to deliver the country park identified within the IDP. The ability for Land off Wrottesley Park Road to deliver a country park is explored further in the Vision Document submitted as part of 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.
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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.
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
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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 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
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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.
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
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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 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 However, the Study considers that this includes those settlement areas deemed close enough to the ‘core’ urban area for development associated with those settlements to be considered to be part of the ‘large built-up area’. Perton is stated to be one of these settlements.
7.6 Richborough Estates objects to this inclusion. Perton is of sufficient size and boasts a separate identity sufficient to be considered separate to the West Midlands Conurbation.
7.7 The parcels of land which separate Perton from the West Midlands Conurbation1 are assessed within the Green Belt Study and are, on the whole, identified as making a lesser contribution towards Green Belt Purpose 1. This is as a direct result of the Council’s consideration that Perton forms part of the West Midlands Conurbation. Given that Perton should be considered separate to the West Midlands Conurbation, these parcels of land in fact serve a far greater purpose in checking the unrestricted sprawl of the built-up area. This should be reflected in the Council’s Green Belt Study.
Land at Wrottesley Park Road; Contributions to Green Belt Purposes
7.8 The Green Belt Study shows Land off Wrottesley Park Road, Perton, as falling within Green Belt Sub-Parcel reference: S54B – ‘Perton Park/Cranmoor/Wrottesley Park’, which is identified as making the following contribution to the five purposes of the Green Belt:
1 Green Belt Parcels: S46A, S56A, S57A, S58A and S59D.
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GB Purpose Assessment Rating Land is close or adjacent to the West Midlands P1: Checking the conurbation, contains no significant urban unrestricted sprawl of development, and has strong openness. It retains Strong large built-up areas a stronger relationship with the wider countryside than with the urban area. P2: Preventing the Land plays no significant role due to the distance Weak / No merging of between the West Midlands conurbation and contribution neighbouring towns Albrighton, the nearest town to the west. Land contains the characteristics of open P3: Safeguarding the countryside (i.e 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 S54B Contribution Towards Green Belt Purposes
7.9 The Study goes on to identify that, should Green Belt Sub-Parcel ref: S54B be released for development, the resulting harm would be ‘high’, stating:
“The sub-parcel makes a strong contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. This part of the sub-parcel directly adjoins the settlement of Perton. The expansion of Perton into the sub-parcel would result in a weaker Green Belt boundary than that formed by Wrottesley Park Road and tree cover along the golf course boundary that forms a boundary to land released for existing development allocations. Therefore, release of this part of the sub-parcel would constitute a limited weakening of the Green Belt. Loss of openness between Perton and Nurton/Old Perton would weaken distinction between the two, but would not increase overall harm.”
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Figure 7.1: Harm Ratings for Land Parcel S54B
7.10 Whilst the conclusions of the above assessment are noted, it remains that Green Belt Sub-Parcel ref: S54B extends significantly beyond Land off Wrottesley Park Road, Perton (particularly to the north), which itself 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
7.11 The site relates well to the existing residential edge of Perton, whilst also being located immediately north of Housing Allocation Reference: 239, as well as Safeguarded Site Reference: 239. These two sites will result in the provision of residential development west of Wrottesley Park Road, significantly altering the character and appearance of this area. The masterplans contained within the Vision Document appended to this representation illustrate that development is not proposed to extend any further than the western boundaries of the housing allocation or safeguard land, meaning development would not extend any further westward into the countryside.
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7.12 The site is bounded to the north by woodland, containing the site both physically and visually within the wider landscape whilst providing a strong boundary to restrict future development. It is clear that the site has defensible boundaries on all sides and would form a natural extension to the existing urban area and as such, the site is not required to check the unrestricted sprawl of the existing built-up area.
7.13 Lastly, the provision of a country park to the western portion of the site would serve to restrict the sprawl of the built-up urban area in the long-term.
7.14 It is therefore considered that the site makes a ‘moderate’ contribution to checking the unrestricted sprawl of large built-up areas, rather than the ‘strong’ contribution identified within the Green Belt Study.
To Prevent Neighbouring Towns from Merging into One Another
7.15 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 Perton and the nearest settlement of Pattingham to the west due to the distance of over 3km. As such, the development of the site would not result in the merging of neighbouring towns and would maintain the functions and separation of the Green Belt in this location. There are opportunities for the strengthening of the boundary at the interface with the wider landscape to the west which could provide increased physical and visual separation and a soft edge to development to further reinforce the edge.
7.16 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.
To Assist in Safeguarding the Countryside from Encroachment
7.17 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 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. Whilst these boundary hedgerows are in place, they are degraded and gappy in places. There are therefore opportunities for reinstating and enhancing field boundaries and
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providing new hedgerow, tree and woodland planting in this area to strengthen the landscape character and the physical and visual boundaries to the site at the interface with the wider landscape and Green Belt to the west.
7.18 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
7.19 Perton is not a historic town. The site is situated away from the Conservation Area and there are no views towards any heritage assets from within the site 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.
7.20 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
7.21 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.
7.22 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
7.23 Overall, it is therefore considered that Land off Wrottesley Park Road, Perton, 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: S54B. This contribution is summarised in the table overleaf:
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Previous Revised GB Purpose Rating Rating P1: Checking the unrestricted sprawl of large Strong Moderate built-up areas 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 Wrottesley Park Road, Green Belt Assessment
Compensatory Improvements
7.24 Paragraph 138 of the NPPF confirms that, when releasing Green Belt land for development, local plans should ‘… 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’.
7.25 As set out within the accompanying Vision Document (see Appendix 2 to this representation) a country park delivered at Land off Wrottesley Park Road would remain in the Green Belt and would serve as an enduring defensible boundary in the long-term, beyond the plan period. In particular, the country park would provide an opportunity to give residents access to the wider Green Belt and a significant area of green infrastructure with potential to link to the wider public Right of Way network beyond. The Illustrative Masterplan included within the Vision Document indicates that the country park could provide a number of environmental and accessibility benefits, including: a café/visitor centre, a community orchard, an informal sports area, an equipped play area, natural play areas, a picnic area, wildflower meadows, heathland areas, formal and informal walking routes and connectivity to wider public right of way network.
7.26 These benefits should be considered when assessing overall Green Belt harm.
Green Belt Harm
7.27 Given the reduced impact upon the five purposes of the Green Belt and the compensatory improvements set out above, is contented that the Green Belt harm identified within the Study should be reduced from ‘high’ to ‘low-moderate’.
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7.28 It is the view of Richborough Estates that the site makes a moderate contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. The expansion of Perton into the site would serve to facilitate the delivery of a new country park, which would result in a stronger Green Belt boundary than that formed by Wrottesley Park Road. The site would form a logical location for the expansion of the settlement edge, and new Green Belt boundaries could be readily drawn without compromising the functions of the designation. The provision of a new country park in this location would provide compensatory improvements to the environmental quality and accessibility of the remaining Green Belt land, in accordance with Paragraph 138 of the NPPF.
7.29 Therefore, release of this site would constitute a limited weakening of the Green Belt.
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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. The majority of Land off Wrottesley Park Road falls with Landscape Parcel Reference: SL29S1, with the western edge of the site falling within SL29S2. These two landscape parcels subsequently fall within the ‘Settled Farmlands’ Landscape Character Type. The landscape areas are located west of Perton and Wightwick (Wolverhampton), and include a narrow strip of land which separates the two settlements. The southern boundary is formed by the A454, the eastern boundary by the settlement edge, and the south western boundary by Pattingham Road. Nurton Brook forms the western boundary, and the northern boundary is formed by field boundaries. The area incorporates Perton Park Golf Course.
8.2 An extract of the Council’s Appraisal of Landscape Sensitivity is included below:
Moderate Higher Characteristic / Lower Sensitivity to Sensitivity to Sensitivity to Attribute Development Development Development Fields separating Perton and Wightwick The area is are smaller in scale dominated by regular with outgrown hedges medium to large or fenced boundaries scale arable fields and generally used for Scale divided by mature horse grazing. As the trimmed hedgerows gap between the with occasional settlements narrows hedgerow and in-field to the west, it is trees. characterised by scrubby woodland. The landform is very gently undulating, with elevations between 100m and 140m AOD. To the west of Perton the landscape rises to the Landform west before descending to Nurton Brook. To the south, the landform is a gentle slope enclosed by a more pronounced scarp slope south of Pattingham Road. Field patterns are mixed in origin and Landscape include 19th century pattern and reorganised time depth piecemeal enclosure, 18th/19th century
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semi-planned enclosure, as well as post-war amalgamated fields. Priority habitat deciduous woodlands near Cranmoor and tree belts along the Staffordshire Way are identified as Ancient Woodland. The remaining woodland 'Natural' is predominantly
character coniferous, including planting within the Perton Park Golf Club. Natural features of value include the mature hedgerow and occasional in-field trees. A limited number of historic features Built features are important to limited to a number of landscape character modern farms and including Trinity Built character properties along Cottage and a Pattingham Road and dovecote associated within the golf club. with South Perton Farmhouse which are Grade II Listed. The promoted long-distance A large part of the Monarch’s Way area is within Perton passes through the Recreational Park Golf Club which west of the area. . character provides restricted Two footpaths recreational cross the narrow opportunities. strip of land between Wightwick and Perton. The north and west of the area has a strongly rural character and reads as part of The golf course the wider Perceptual introduces an countryside,
aspects urbanised element to becoming the landscape. particularly tranquil with an experience of 'dark skies' away from the settlement edge. Coniferous plantation The area provides a The settlement Settlement at Perton Golf Club rural setting to edge of Wightwick setting provides enclosure to Perton and ribbon is looser and more the south west of the development along rural in character
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settlement reducing Pattingham Road than the southern its sensitivity. extending from settlement edge of Nurton. However, Perton. The two settlement on the settlements are edge of Perton is separated by an generally inward increasingly looking and narrow buffer of Wrottesley Park Road open green space provides an abrupt which has an edge to the important role in settlement. preventing coalescence. The landscape is not The rising visually prominent topography to the within the wider north west of the landscape due to its Visual area and the stream gently undulating prominence valley sides along the topography and large Nurton Brook are areas of woodland visible within the which provide wider landscape. enclosure. Inter-visibility with adjacent There is no inter- designated visibility with any
landscapes or designated landscapes promoted view or marked viewpoints. points The landscape is considered to have a moderate overall sensitivity to residential Landscape development. The narrow buffer of open Sensitivity agricultural land between the southern Moderate Judgement settlement edge of Perton and Wightwick has (SL29S1) a particular sensitivity due to its role in preventing coalescence between the settlements. The increasingly rural and wooded landscape Landscape to the north and west of the area at Cranmoor Sensitivity and along the Nurton Brook, is more sensitive Moderate-high Judgement to residential development due to its stronger (SL29S2) natural character and visual prominence.
8.3 The Study concludes that Landscape Parcel SL29S1 (which encompasses the majority of Land at Wrottesley Park Road) is considered to have a ‘moderate’ overall sensitivity to residential development, as identified on Figure 8.1 overleaf.
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Figure 8.1: Landscape Sensitivity Rating Parcels SL29S1 and SL29S2
8.4 The findings of the Landscape Study are not necessarily disputed by Richborough Estates. However, the site has previously been assessed through the Site Allocations Document process as having a ‘low impact’ on landscape sensitivity. It is, therefore, not understood how the landscape sensitivity of the site has increased, particularly now land to the south (Site Allocation Ref: 239) has been allocated for residential development.
8.5 Nevertheless, it is considered that the development of the site for residential purposes represents an opportunity to strengthen existing field boundaries within and to the edges of the site. Furthermore, the development of the site facilitates the opportunity to provide a new country park, which would serve to define the western edge of Perton.
8.6 The county park would be partly located within the area of greater landscape sensitivity (parcel SL29S2) and would contribute towards the natural rural character of the land, easing the transition between the urban edge and the countryside in this location.
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8.7 Matters relating to site-specific landscape sensitivity are considered further in Chapter 11 of this Representation.
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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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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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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 Perton is identified as falling within ‘Tier 2 Settlements’ which are described as:
“Settlements within this tier typically have a food store and a range of services and facilities and education establishments, but the level of provision will typically be less than Tier 1 villages. These villages do not have access to rail stations and have lesser levels of employment access than Tier 1 villages. There is still a degree of access to services outside the village via public transport.”
10.4 The overall settlement hierarchy scoring for Perton 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 Perton, RSFA (2019)
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10.5 Whilst the identification of Perton as a Tier 2 Settlement is not disputed overall, Richborough Estates considers that Perton benefits from ‘medium’ access to employment opportunities, rather than ‘low’ as identified within the RSFA.
10.6 The RSFA assesses access to employment locations through ‘Hansen’ scores, which measures the number of destinations that can be accessed within a 60 minutes journey time, the disbenefits of travel in terms of journey time, origin point population and the total number of jobs available at the destination. This is calculated using a digital model.
10.7 Whilst the detailed modelling is not available for scrutiny as part of this consultation, it remains that Perton benefits from frequent bus services to Wolverhampton (the number 10 service), operating approximately every 15-25 minutes from 6am until 7:30pm, whereupon they become hourly until 10:30pm. The journey time between Perton and Wolverhampton is scheduled as taking 29 minutes. In the context of the Hansen scoring identified within the RSFA, that leaves an additional 31 minutes to make an onward journey to an employment destination.
10.8 Whilst this represents a simplification of the modelling that appears to have been utilised by the Council, it remains that Wolverhampton is the largest settlement adjacent to Perton (and indeed, South Staffordshire District), both in terms of total number of jobs offered, but also the diversity of jobs offered. It is therefore not understood how Perton could be said to have ‘low’ access to employment locations.
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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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12. LAND AT WROTTESLEY PARK ROAD, PERTON
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 Wrottesley Park Road, Perton. The site is located to the west of Wrottesley Park Road and to the north and immediately adjacent to housing allocation and safeguarded site ref: 239 contained within the adopted Site Allocations Document (SAD).
12.3 Land at Wrottesley Park Road comprises a number of field parcels is currently in agricultural use which total approximately 45.9 hectares. The parcels of land are subdivided by existing tree/hedgerow boundaries associated with the agricultural use of the land. The parcels are accessed via Wrottesley Park Road to the east or via a private road to the north.
Green Belt Harm
12.4 Given the reduced impact upon the five purposes of the Green Belt and the compensatory improvements set out above, is contented that the Green Belt harm identified within the Study should be reduced from ‘high’ to ‘low-moderate’.
12.5 It is the view of Richborough Estates that the site makes a moderate contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. The expansion of Perton into the site would result serve to facilitate the delivery of a new country park, which would result in a stronger Green Belt boundary than that formed by Wrottesley Park Road. The site would form a logical location for the expansion of the settlement edge, and new Green Belt boundaries could be readily drawn without compromising the functions of the designation. The provision of a new country park in this location would provide compensatory improvements to the environmental quality and accessibility of the remaining Green Belt land, in accordance with Paragraph 138 of the NPPF.
12.6 Therefore, release of this site would constitute a limited weakening of the Green Belt.
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Landscape Sensitivity
12.7 Again, Chapter 6 of this Representation sets out how South Staffordshire District Council’s Landscape Study (2019) finds that the eastern extent of the site has ‘moderate’ sensitivity in landscape terms.
12.8 Whilst the findings of the Landscape Study are not necessarily disputed by Richborough Estates, the site has previously been assessed through the Site Allocations Document process as having a ‘low impact’ on landscape sensitivity. It is, therefore, not understood how the landscape sensitivity of the site has increased, particularly now land to the south (Site Allocation Ref: 239) has been allocated for residential development.
12.9 Nevertheless, it is considered that the development of the site for residential purposes represents an opportunity to strengthen existing field boundaries within and to the edges of the site. Furthermore, the development of the site facilitates the opportunity to provide a new country park, which would serve to define the western edge of Perton.
12.10 The county park would be partly located within the area of greater landscape sensitivity (parcel SL29S2) and would contribute towards the natural rural character of the land, easing the transition between the urban edge and the countryside in this location.
12.11 Initial work undertaken by EDP has revealed that there are no ‘in principle’ constraints to the development of housing at the site with regard to landscape. The site does not fall within close proximity to any nationally designated landscapes or sites of nature conservation importance.
12.12 The general visual baseline of the Study Area – that is the distribution and availability of both internal and external intervisibility – is heavily influenced by topography, existing woodland cover or other landscape features and existing settlement both within the site and in the immediate locality. The interaction of topography, woodland cover and built form restricts the size of the area from which views of the site are possible to the north, east and south to within a relatively close range (i.e. resulting in a high degree of visual containment). The land has a strong relationship to the settlement edge of Perton, particularly further to the east of the site, where topography screens this area of the site from the west.
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12.13 The site consists of six arable fields bordered by low hedgerows and scattered mature oak trees that give it a relatively simple landscape fabric and an open character. There are few intrinsically valuable landscape features and the fabric is considered to have a low sensitivity to change, provided that the retention of the majority of trees and key hedgerow connections can be achieved, which has been inherent when developing the proposals.
12.14 The illustrative masterplan for the site (see Vision Document at Appendix 2) offers a significant opportunity to enhance the landscape fabric and character of the site through the retention of the existing trees and hedgerows and the creation of new public open space. The proposals also provide a significant opportunity to improve the legibility of the Staffordshire Way.
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 Perton with good access to the village centre, including being within walking distance of its many facilities and bus links.
12.16 The site also benefits from good access to further services and facilities located within the wider urban area, including Wolverhampton.
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 draws together the available archaeological, historic, topographic and land-use information in order to clarify the heritage significance and archaeological potential of land proposed for development.
12.19 The assessment establishes that there are no designated heritage assets (World Heritage Sites, Scheduled Monuments, Listed Buildings, Registered Battlefields, Registered Historic Parks or Conservation Areas) within the study site, and that development of the study site will not affect the significance of any designated heritage assets, nor their settings, in the surrounding area.
12.20 Heritage Gateway depicts two non-designated heritage assets within the site, which include two north south aligned field boundaries that are shown on a map
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of Perton Manor dated to 1663 (MST18002) and a track way dated to the same period. The work undertaken to date however, has identified that these would not be a constraint to development within the site or require to be designed around. This assessment has also established that the site has a negligible potential for significant (non-agricultural) archaeological remains of all periods.
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.
Surface Water Flooding
12.22 Richborough Estates has commissioned a technical review of the flood risk and drainage issues, produced by BWB. The report identifies that the site lies within Flood Zone 1; less than 1 in 1,000 annual probability of river or sea flooding. Surface water flood mapping indicates the potential for pluvial flooding along the northern boundaries of the site, however, this is anticipated to be managed and mitigated as part of the development proposals and drainage strategy.
12.23 OS Plans and an initial site walkover would suggest a system of ditches and drains exists flowing north along Wrottesley Park Road towards the roundabout and ultimately to the River Penk. As part of the detailed Flood Risk Assessment, investigations would be made to verify a surface water outfall.
12.24 With such mitigation measures in place it is considered that flood risk to and from the development will be managed and betterment will be provided by the development.
12.25 Underlying bedrock is designated as Principal Aquifer and superficial deposits as Secondary Aquifer by the Environment Agency. This information indicates there is potential for soakage on site and therefore detailed soakage testing will be completed as part of any Flood Risk Assessment.
Highways (Accessibility to the Site)
12.26 The site is sustainably located, and a range of local facilities are accessible by modes other than the car. Shared foot/cycle way provision and two new pedestrian points of access could be proposed into the village from Wrottesley Park Road, ensuring the sustainable access to and from the site will be excellent.
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12.27 Vehicular site access can be provided in accordance with relevant local and national design guidance onto Wrottesley Park Road, ensuring there would be no material impact on highway safety or highway capacity as a result.
12.28 Richborough Estates has undertaken further work in respect of transport and has assessed the traffic generation impacts of proposals for 750 dwellings on land at the western edge of Perton (which is assumed to include the sites at Wrottesley Park Road and other sites contained within the adopted Local Plan). The results show that the junctions in the vicinity of the site have sufficient capacity to accommodate 750 dwellings, with the exception of the A41 Holyhead Road/ Wrottesley Park Road/ Heath House Lane junction which is predicted to operate over capacity during the PM peak period. The junction already operates over capacity in 2016 base year.
12.29 An initial potential strategy has been developed to improve the operation of this junction, focussed on increasing the capacity of the two A41 approach arms. The assessment with this improvement shows that the junction will operate within capacity during the AM and PM peak periods and also shortens the cycle time to 90 seconds.
12.30 In summary therefore, this strategic work demonstrates that the development site can be delivered on the highway network with the improvements required being deliverable within highway land.
12.31 In addition, consideration has been given to the provision of new pedestrian linkages between the site and existing built up area of Perton. Land to the east of Wrottesley Park Road has been secured to enable pedestrian linkages to be provided, offering accessibility to services and facilities on foot.
Impact on Current Land Use
12.32 The agricultural land contained within this site is believed to be a mixture of Grade 3 (split of 3a and 3b is unknown at this time), and Grade 2 (which is land of best and most versatile value).
12.33 However, the same is true for the majority of land around Perton and therefore does not reflect negatively against this site.
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Impact on Natural Environment
12.34 Initial work undertaken by EDP has revealed that there are no ‘in principle’ constraints to the development of housing at the site with regard to ecology. There are no statutory sites of nature conservation importance at an international (e.g. Special Areas of Conservation) or national (e.g. Sites of Special Scientific Interest) scale located within a 5km radius of the site.
12.35 The site consists predominantly of arable land with a network of hedgerows and occasional hedgerow and field boundary trees. The network of hedgerows and any notable trees have been, and will continue to be, sought to be retained within any proposals and the site offers opportunities for such networks to be enhanced.
12.36 From the initial work undertaken, there is a low overall diversity of habitats on the site and those that it does support are common and widespread within the local landscape. Therefore, it is considered that the ecological value of the site is limited.
12.37 There are considerable opportunities for biodiversity enhancement through habitat creation given that it proposes a significant area of open space both within the development area and the proposed Country Park. The creation of new habitats should be designed to contribute towards targets set within the UK and Staffordshire Biodiversity Action Plan. The scheme specifically has the opportunity to contribute to the targets for the following BAP habitats: lowland wood and pasture/parklands; lowland acid grassland; ponds and lakes; reedbeds; wildflower meadows; and biodiverse architecture.
Impact on Environmental Quality
12.38 The agricultural site is unlikely to have significant issues in relation to contamination, and the surrounding context of the site is not considered to represent constraints in relation to air quality and noise.
12.39 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 not give rise to any further environmental quality issues.
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Site-Specific Opportunities
12.40 As set out previously within this Representation, the development of the site for residential purposes presents the opportunity to deliver a new country park at Perton, which is identified within the Council’s Infrastructure Delivery Plan as a future project.
12.41 Further detail in respect of the country park is provided within the accompanying Vision Document, included at Appendix 1 to this Representation.
12.42 This represents a significant benefit of allocating Land at Wrottesley Park Road, Perton, for residential development.
Suitability
12.43 The information set out above demonstrates that Wrottesley Park Road is a suitable site for development.
Deliverability
12.44 There is an agreement in place between the landowner and Richborough Estates to facilitate the development of the site.
12.45 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.
12.46 There are no existing uses that would require relocation and no issues of contamination that would require remediation. Many of the impacts identified by the Council through the assessment of the site can be mitigated and, in many cases, a positive outcome can be achieved.
12.47 The site is deliverable and immediately available and, subject to allocation, could deliver homes and associated community benefits within the next 5 years.
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13. CONCLUSION
13.1 This representation is made by Pegasus Group on behalf of Richborough Estates Limited to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to land off Wrottesley Park Road, 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 Wrottesley Park 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 of Wrottesley Park Road should be allocated for development through the Local Plan Review.
December 2019 | NCO/BC | BIR.4758 Page | 42
APPENDIX 1 LAND OFF WROTTESLEY PARK ROAD PERTON
PROMOTIONAL DOCUMENT
Prepared by Pegasus Group on behalf of Richborough Estates DECEMBER 2019 | BIR.4758_08 Pegasus Group 5 The Priory Old London Road Canwell Sutton Coldfield B75 5SH www.pegasusgroup.co.uk I T 0121 308 9570 I F 0121 323 2215
Prepared by Pegasus Group on behalf of Richborough Estates. December 2019. Project code BIR.4758. Document ref BIR.4758_08. Contact: Neil Cox
COPYRIGHT The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Ltd. Crown copyright. All rights reserved, Licence number 100042093.
PAGE 5 1 PAGE 9 2 PAGE 15 3 PAGE 33 4 PAGE 37 5 PAGE 41 6 PAGE 45 7 PAGE 49 8 PAGE 53 9
INTRODUCTION PLANNING THE SITE AND VISION INDICATIVE WEST PERTON DELIVERABILITY COUNTRY PARK SUMMARY & & DOCUMENT POLICY SURROUNDING MASTERPLAN & & KEY BENEFITS CONCLUSIONS PURPOSE CONTEXT CONTEXT DESIGN PRINCIPLES
THIS DOCUMENT IS DESIGNED TO BE VIEWED AS A3 DOUBLE SIDED
1 INTRODUCTION AND DOCUMENT PURPOSE 6 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 1 INTRODUCTION AND DOCUMENT PURPOSE
INTRODUCTION DOCUMENT PURPOSE
1.1 The land at Wrottesley Park Road represents a logical and 1.5 South Staffordshire Council is currently in the process of reviewing Planning: appropriate extension to the sustainable settlement of Perton. their Local Plan to identify and direct growth within the District to Pegasus Group The site is sustainable, is well located to a wide range of existing 2037. This will include consideration of an appropriate housing services and facilities and offers an opportunity to deliver new requirement and a spatial strategy for distributing growth, informed homes alongside supporting infrastructure. by an updated settlement hierarchy. This Promotional Document demonstrates that the site to the west of Wrottesley Park Road Urban Design: RICHBOROUGH ESTATES will form a logical extension to Perton and that exceptional nineteen47 1.2 Richborough Estates is a responsible and specialist strategic land circumstances exist to justify its removal from the Green Belt. promotion business founded with the aim of working in partnership 1.6 This Promotional Document presents an analysis of the site and with landowners. Our projects are located throughout the country its surroundings and sets out in detail the case for the removal of ranging from residential schemes of around 50 dwellings to large the site from the Green Belt. This includes a review of the current Landscape: urban extensions, including sites located within the Green Belt. and emerging planning policy position and an assessment of the Pegasus Group
1.3 Richborough Estates oversees the entire planning process site against the five purposes of the Green Belt contained in the from start to finish and works closely with local communities, National Planning Policy Framework (“The Framework”). Planning Officers and key stakeholders to create the most 1.7 This document also sets out the Vision for the site, informed by a mutually beneficial schemes. Richborough is seeking to apply this consideration of the constraints and opportunities and an Indicative Access & Movement: approach to the proposed development which is the subject of this Masterplan demonstrating how the Vision can be achieved through Hub Promotional Document. a well-designed scheme. The document concludes with a concise
1.4 Richborough Estates has an interest in the land at Wrottesley Park summary of the site, the proposed development and its key Road. The extent of land controlled by Richborough is shown edged benefits. red on the Location Plan on Page 6 of this document. 1.8 Overall, this Promotional Document presents a sustainable site to Flood Risk & Drainage: supports the site’s future allocation through the Local Plan Review BWB process and promotes its release from the Green Belt.
1.9 This document has been prepared with input from the following Consultant Team:
Heritage: CgMs
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 7
2 PLANNING POLICY CONTEXT 10 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 2 PLANNING POLICY CONTEXT
NATIONAL PLANNING GUIDANCE
2.1 In February 2019, the Government published a revised National 2.3 Furthermore, paragraph 8 of the Framework sets out that Planning Policy Framework (“Framework”) which replaces the sustainable development has three overarching objectives: previous guidance published in 2018 and provides the overarching economic, social and environmental. The proposed development planning framework for England. Central to the Framework is a accords with each of these objectives, contributing to building a presumption in favour of sustainable development which is the strong, responsive and competitive economy, supporting strong, golden thread running through both plan-making and decision- vibrant and healthy communities and continuing to protect and taking (paragraph 11). The Framework also seeks to boost the enhance the natural, built and historic environment.
supply of housing and requires local authorities to plan positively 2.4 Chapter 5 of the NPPF sets out how local authorities should boost for objectively assessed needs and maintain a sufficient supply of significantly the supply of housing in order to deliver sufficient housing land. supply of homes. The land to the west of Wrottesley Park Road, 2.2 Paragraph 136 of the Framework states that once the general Perton, represents a deliverable site that is available, achievable extent of a Green Belt has been approved, it should only be altered and viable and the provision of housing on the wider site would in ‘exceptional circumstances’ through the plan-making process boost the supply of housing in the District. and that the amended Green Belt boundary should be “capable of enduring beyond the plan period”. There are exceptional circumstances which justify alteration to the Green Belt boundary in South Staffordshire District and the site offers an opportunity to release Green Belt in a sensitive manner, without harming its purposes and functions, as set out in paragraph 134 of the Framework.
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 11 EXISTING DEVELOPMENT PLAN
2.5 The Development Plan for South Staffordshire currently comprises the adopted Core Strategy (adopted 11th December 2012) and the Site Allocations Document (adopted 11th September 2018).
2.6 The Core Strategy establishes the strategic policies for the District, notably the housing requirement and distribution of housing (Core Policy 1 and Core Policy 6), whilst the Site Allocations Document provides a range of allocations to deliver the requirements set out within the Core Strategy.
2.7 The policies map identifies the following designations for the site: • Green Belt (Policy GB1)
2.8 Perton does not lie within a Neighbourhood Area Designation and therefore a Neighbourhood Plan has not been progressed to date.
EMERGING LOCAL PLAN
2.9 South Staffordshire District Council has commenced work on a review of the adopted Local Plan which is essential to respond to unmet housing needs within the District and those confirmed within the wider Greater Birmingham and Black Country Housing Market Area (GBBCHMA). The Local Plan Review provides an opportunity for the Council to establish a robust housing requirement, having regard to local housing needs and cross boundary requirements and comprehensively review the vision, strategic objectives, spatial development strategy and policies for shaping detailed development proposals. The review process will also ensure consistency with the new National Planning Policy Framework (NPPF), which seeks a requirement for local planning authorities to keep their Local Plan up to date by undertaking a review at least every five years.
ADOPTED LOCAL PLAN POLICIES MAP | NOT TO SCALE
12 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT CASE FOR GREEN BELT RELEASE
2.10 The Core Strategy was adopted prior to the requirement to 2.13 A revised Settlement Hierarchy has informed these options, which 2.16 Given the need to accommodate an increased amount of establish a housing requirement based on objectively assessed highlights Perton as a “Tier 2” settlement. Tier 2 settlements are housing and employment land, the Council concluded there housing needs and the clear conclusion that a housing shortfall considered to be some of the most sustainable of the District’s were exceptional circumstances to release Green Belt land exists across the Housing Market Area in which the District villages, with good access to services and facilities. It is concluded through the adoption of the Site Allocations Document. The need lies. The current housing supply versus planned development is that: to consider Green Belt release through the Local Plan Review calculated to be a minimum of 60,855 homes between 2020 and process is acknowledged through the Spatial Housing Strategy “Settlements within this tier typically have a food store 2036, as set out within the Greater Birmingham HMA Strategic and Infrastructure Delivery consultation document to support and a range of services and facilities and education Growth Study. This significant shortfall will be an important the preferred strategic option for growth. There are exceptional establishments, but the level of provision will typically be consideration in informing the appropriate housing requirement circumstances that exist for the targeted release of Green Belt less than Tier 1 villages. These villages do not have access for South Staffordshire District to be determined through the land in Perton to meet identified housing needs in a sustainable to rail stations, but still have a degree of access to services review process. location within this Tier 2 village. outside the village via public transport.” 2.11 The Spatial Housing and Infrastructure Delivery consultation document identifies a housing needs figure for South Staffordshire 2.14 Approximately 80% of South Staffordshire lies within the West District of 4,845 dwellings between 2018 and 2037. This figure Midlands Green Belt. The Council acknowledges that it may be takes into account historical completions since 1 April 2018, in necessary to consider Green Belt boundaries in some locations conjunction with the latest affordability ratios under the standard to accommodate the necessary levels of growth in a sustainable method. In addition, South Staffordshire has committed to the manner. The combined requirements of an increased OAN and the delivery of a minimum of 4,000 additional dwellings to contribute potential for meeting an element of the overspill requirement is towards meeting the housing shortfall within the wider GBBCHMA. likely to increase pressures for Green Belt releases, given the lack This results in the requirement of 8,845 dwellings across the plan of urban capacity and the small proportion of the district that lies period. This represents a significant uplift compared with past outside the current Green Belt designation. delivery experienced within the District. 2.15 Perton is completely constrained by Green Belt, with the exception 2.12 The consultation document presents seven different spatial growth of an area of Safeguarded Land directly south of Richborough options, all but one of which would deliver the identified housing Estates’ land interests. In the context set out above it is clear requirement. The Council’s preferred growth option (Option G) that further release of Green Belt land is required to assist in the identifies a significant proportion of housing growth focused on delivery of the housing requirement in sustainable locations such Tier 1 and 2 villages, where opportunities to achieve infrastructure as Perton. In addition, further housing growth within the village improvements through new development exist, having regard to will be required in the longer term, beyond the proposed plan other environmental constraints. period and therefore further safeguarded land should be identified within Perton to allow for future needs to be met.
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 13
3 THE SITE AND SURROUNDING CONTEXT 16 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 3 THE SITE AND SURROUNDING CONTEXT
LAND AT WROTTESLEY PARK ROAD SURROUNDING AREA
3.1 The site is located to the west of Wrottesley Park Road and to the 3.4 The site is located adjacent to the current built up area of Perton north and immediately adjacent to safeguarded land allocation ref: with good access to the village centre, including being within 239 contained within the adopted Site Allocations Document (SAD). walking distance of its many facilities and bus links.
3.2 The site comprises a number of field parcels currently in 3.5 The site also benefits from good access to further services agricultural use which total approximately 45.9 hectares. and facilities located within the wider urban area, including The parcels of land are subdivided by existing tree/hedgerow Wolverhampton. The site is very well located to take advantage of boundaries associated with the agricultural use of the land. local facilities within the centre that are typically used on a day-to- day/ weekly basis, such as convenience stores, post office, library, 3.3 Richborough Estates has secured an interest in this site. dining and coffee facilities, surgery, dental practice and a range of schools. All of these services can be reached easily by foot from the site.
3.6 The site provides an opportunity to deliver much needed housing, together with all necessary supporting infrastructure. Additionally, the site provides the opportunity to deliver a new country park at Perton, resulting in an opportunity for residents to access the wider Green Belt and significant areas of green infrastructure with potential to link to the wider public right of way network beyond.
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 17 LOCAL FACILITIES | NOT TO SCALE
18 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT LOCAL FACILITIES, AMENITIES & SERVICES
3.7 There are a number of local facilities within walking distance of the 3.11 Wrottesley Park Road feeds into The Parkway to the East which site, with all local facilities listed falling within the suggested 2km leads into the village. Pedestrian linkage within the existing upper limited as referenced in Manual for Streets (MfS) guidance. residential road network is taken via both footways alongside local roads and off carriageway footpath links. The footways include 3.8 Both local first schools and one secondary school are located raised kerbs, street lights, lowered tactile paving at crossings within the (Institute of Highway and Transportation (IHT) maximum within a 30mph speed limit environment. walking distance to schools of 2km. 3.12 Bus: Bus stops are located to the east of the site on The Parkway ACCESS & MOVEMENT serving the number 10/10A/10B service. This service is operated by National Express and passes the stop approximately every LOCAL TRANSPORT NETWORK 15-30 minutes and operates between Wolverhampton and 3.9 Highway (Including Pedestrian Networks): Wrottesley Park Road Perton via Compton. It offers access to the village centre (close is the primary local distributor road between the A41 to the North to the Sainsbury’s, the local library and other local facilities and and A454 to the south. The road varies between 6m and 7m wide amenities) and to the local schools on its way to Wolverhampton. with grass verges on both sides of the carriageway (the eastern 3.13 Rail: The nearest railway station to the site is Codsall Station, verge being particularly generous in terms of width). The road is 3.7km to the north off Station Road. The station can be accessed reasonably straight and generally provides good forward visibility. via the 10B bus service which operates from the stops close to the The speed limit is restricted to 40mph. site. Codsall Station offers services to Birmingham New Street (via 3.10 Vehicular access towards the village of Perton from Wrottesley Wolverhampton) every hour. Park Road is taken via two 3-arm roundabouts. The first is approximately 650m to the north of the existing site access on Wrottesley Park Road. The second is 550m south of the site.
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 19 ACCESS 3.14 The nature of the generally straight alignment of the Wrottesley Park Road site frontage provide a range of feasible site access designs. These can be tailored to quantum of development, modified in the longer term as appropriate with land available as necessary.
3.15 Current options include: two simple priority controlled T-junctions; a priority ghost island right turn; a single ghost island right turn lane; and a roundabout. Each can be delivered on available land. The appropriate solution can be agreed with the highway authority in due course, but significant flexibility exists and one example is shown on the adjacent plan. Appropriate visibility splays and geometric designs will be delivered in accordance with prevailing design standards supported by traffic data and independent road safety audit.
3.16 Footway links are to be secured to the east of Wrottesley Park Road to ensure permeability and encourage sustainable trips to services and facilities available within Perton.
PROPOSED SITE ACCESS | NOT TO SCALE
20 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT HERITAGE & ARCHAEOLOGY
3.17 A Heritage Statement has been undertaken which identifies and considers heritage assets located within the site and within the vicinity of the site. The assessment draws together the available archaeological, historic, topographic and land-use information in order to clarify the heritage impacts and below- ground archaeological potential of the site. This study provides an assessment of the archaeological potential of the site and enables relevant parties to identify and assess the impact of the proposed allocation.
3.18 The assessment establishes that there are no designated heritage assets (World Heritage Sites, Scheduled Monuments, Listed Buildings, Registered Battlefields, Registered Historic Parks or Conservation Areas) within the study site, and that development of the study site will not affect the significance of any designated asset in the surrounding area.
3.19 This assessment has also established that the site has a negligible potential for significant (non-agricultural) archaeological remains of all periods. The site is known to contain post- Medieval agricultural features and may also contain ploughed out structures relating to RAF Perton. These non-designated assets are not a constraint to development and will not require to be designed around.
3.20 There are therefore no heritage constraints to the allocation of the site for residential development.
LISTED BUILDINGS | NOT TO SCALE
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 21 GREEN BELT CONTRIBUTIONS TO GREEN BELT PURPOSES 3.21 The Council has commissioned a Green Belt Assessment, 3.23 The National Planning Policy Framework (NPPF) states that the of plans (NPPF paragraph 136). This Vision Document considers alongside the City of Wolverhampton, Dudley, Sandwell and Green Belt should serve the five following purposes: the contribution that land within the site makes to the purposes Walsall, (together comprising the Black Country authorities). The • To check the unrestricted sprawl of large built-up area; and function of the Green Belt, with reference to the Council’s Study forms an important piece of evidence for the partial review of Green Belt Study. Recommendations are also included for the • To prevent neighbouring towns merging into one another; the Black Country Core Strategy (the Black Country Plan) and the release of land for development that does not harm the Green • To assist in safeguarding the countryside from encroachment; strategic site allocations and individual development plans of the Belt and offers options for new boundaries and the enhancement Black Country Authorities, as well as South Staffordshire District. • To preserve the setting and special character of historic towns; and of retained Green Belt land.
3.22 The Green Belt Study has two stages; the first is to assess • To assist in urban regeneration, by encouraging the recycling of 3.25 The Council’s Green Belt Study shows Land off Wrottesley Park derelict and other urban land. ‘strategic variations’ between the contribution of land to the five Road, Perton, as falling within Green Belt Sub-Parcel reference: purposes of the Green Belt, whilst the second includes a more 3.24 The fundamental aim of Green Belt policy is to prevent urban S54B – ‘Perton Park/Cranmoor/Wrottesley Park’, which is focused assessment of the potential ‘harm’ of removing land sprawl by keeping land permanently open. Once established, Green identified as making the following contribution to the five purposes from the Green Belt. Alongside the Green Belt Study, a Stage Belts should only be altered where exceptional circumstances are of the Green Belt: 3 assessment involved undertaking a landscape sensitivity fully evidenced and justified, through the preparation or updating assessment in order to assess the sensitivity of land within the South Staffordshire to housing and employment development. GB PURPOSE ASSESSMENT RATING Whilst, there is a relationship between landscape sensitivity and Green Belt contribution/harm in that physical elements Land is close or adjacent to the West Midlands conurbation, contains no significant which play a role in determining landscape character, there are P1: Checking the unrestricted sprawl of large urban development, and has strong openness. It retains a stronger relationship with Strong built-up areas fundamental distinctions in the purposes of the two assessments, the wider countryside than with the urban area. reflecting the fact that landscape quality is not a relevant factor
in determining the contribution to Green Belt purposes, or harm P2: Preventing the merging of neighbouring Land plays no significant role due to the distance between the West Midlands Weak / No to those purposes resulting from the release of land. As such, the towns conurbation and Albrighton, the nearest town to the west. contribution findings of the Stage 3 landscape sensitivity assessment for South Staffordshire and the Black Country are presented in a separate Land contains the characteristics of open countryside (i.e an absence of built or P3: Safeguarding the countryside from otherwise urbanising uses in Green Belt terms) and does not have a stronger Strong document (Landscape Study 2019) and is considered later is this encroachment relationship with the urban area than with the wider countryside. Vision Document.
P4: Preserve the setting and special character Weak / No Land does not contribute to the setting or special character of a historic town. of historic towns contribution
P5: Assist urban regeneration, by encouraging All parcels are considered to make an equal contribution to this purpose. Strong recycling of derelict and other urban land GREEN BELT PURPOSES SUMMARY: PARCEL S54B - PERTON PARK/CRANMOOR/WROTTESLEY PARK
22 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 3.26 The Study goes on to identify that, should Green Belt Sub-Parcel 3.27 Whilst the conclusions of the above assessment are noted, it To Prevent Neighbouring Towns from Merging into One Another ref: S54B be released for development, the resulting harm would remains that Green Belt Sub-Parcel ref: S54B extends significantly 3.32 The removal of the site from the Green Belt would amount to a be ‘high’, stating: beyond Land off Wrottesley Park Road, Perton, which itself serves negligible reduction to the separation distances between the built- a reduced function against the five purposes of the Green Belt, as up area of Perton and the nearest settlement of Pattingham to the “The sub-parcel makes a strong contribution to preventing assessed below. west due to the distance of over 3km. As such, the development sprawl of the West Midlands conurbation and preventing of the site would not result in the merging of neighbouring towns To Check the Unrestricted Sprawl of Large Built-Up Areas encroachment on the countryside. This part of the sub- and would maintain the functions and separation of the Green Belt 3.28 Although the site relates well to the existing residential edge parcel directly adjoins the settlement of Perton. The in this location. There are opportunities for the strengthening of of Perton, development is currently contained to the east of expansion of Perton into the sub-parcel would result the boundary at the interface with the wider landscape to the west Wrottesley Park Road, meaning development would extend further in a weaker Green Belt boundary than that formed by which could provide increased physical and visual separation and west than the current situation. The area to the west of the road Wrottesley Park Road and tree cover along the golf a soft edge to development to further reinforce the edge. course boundary that forms a boundary to land released however, is not absent of development, with a number of scattered for existing development allocations. Therefore, release farm dwellings situated to the north of the site and Perton Golf 3.33 Richborough Estates therefore agrees with the conclusions of the of this part of the sub-parcel would constitute a limited Course to the south. Green Belt Study, that the site makes a ‘weak/no’ contribution to preventing neighbouring towns from merging into one another. weakening of the Green Belt. Loss of openness between 3.29 The site is bounded to the north by woodland, containing the site Perton and Nurton/Old Perton would weaken distinction both physically and visually within the wider landscape whilst To Assist in Safeguarding the Countryside from Encroachment between the two, but would not increase overall harm.” providing a strong boundary to restrict future development. It is 3.34 Whilst the site contains some characteristics of open countryside, clear that the site has defensible boundaries on all sides and would such as an absence of built development, it remains that the site form a natural extension to the existing urban area and as such, has durable defensible boundaries that are afforded clear physical the site is not required to check the unrestricted sprawl of the enclosure from the wider Green Belt. Furthermore, due to the existing built-up area. existing uses that surround the site, its development would prevent 3.30 Lastly, the provision of a country park to the western portion of the further encroachment into the countryside. Whilst these boundary site would serve to restrict the sprawl of the built up urban area hedgerows are in place, they are degraded and gappy in places. in the long-term. There are therefore opportunities for reinstating and enhancing field boundaries and providing new hedgerow, tree and woodland 3.31 It is therefore considered that the site makes a ‘moderate’ planting in this area to strengthen the landscape character and the contribution to checking the unrestricted sprawl of large built-up physical and visual boundaries to the site at the interface with the areas, rather than the ‘strong’ contribution identified within the wider landscape and Green Belt to the west. Green Belt Study. 3.35 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.
HARM RATING OVERVIEW OF LAND WITHIN SUB PARCEL | NOT TO SCALE
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 23 To Preserve the Setting and Special Character of Historic Towns SUMMARY OF GREEN BELT PURPOSES GREEN BELT HARM 3.36 Perton is not a historic town. The site is situated away from the 3.40 Overall, it is therefore considered that Land off Wrottesley Park 3.41 As such, is contented that the Green Belt harm identified within Conservation Area and there are no views towards any heritage Road, Perton, makes a reduced contribution to the five purposes the Study is also reduced, from ‘high’ to ‘low-moderate’. It is assets from within the site area. As such the removal of the site of the Green Belt than that identified within the Green Belt for the view of Richborough Estates that the site makes a moderate from the Green Belt would not affect the purpose of preserving the Green Belt Sub-Parcel ref: S54B. This contribution is summarised contribution to preventing sprawl of the West Midlands conurbation setting and special character of a historic town. in the table below: and preventing encroachment on the countryside. The expansion of Perton into the site would result serve to facilitate the delivery 3.37 Richborough Estates therefore agrees with the conclusions of the of a new country park, which would result in a stronger Green Belt Green Belt Study, that the site makes a ‘weak/no’ contribution to GB PURPOSE RATING boundary than that formed by Wrottesley Park Road. Therefore, preserving the setting and special character of historic towns. release of this site would constitute a limited weakening of the To Assist in Urban Regeneration, by Encouraging the Recycling P1: Checking the unrestricted sprawl of large Green Belt. Strong of Derelict and other Urban Land built-up areas 3.38 Whilst it is acknowledged that all Green Belt land make a contribution towards encouraging the recycling of derelict and other P2: Preventing the merging of neighbouring Weak / No urban land, the site and immediate area does not contain significant towns contribution areas of brownfield land and would therefore not prejudice the redevelopment of urban land in this area. The release of the site P3: Safeguarding the countryside from Strong from the Green Belt and allocation for residential development encroachment would therefore not significantly prevent the recycling of derelict land and other urban land. P4: Preserve the setting and special character Weak / No 3.39 It is therefore considered that the site makes a ‘moderate’ of historic towns contribution contribution to this purpose of the Green Belt, rather than the P5: Assist urban regeneration, by encouraging Strong ‘strong’ contribution identified within the Green Belt Study. recycling of derelict and other urban land GREEN BELT PURPOSES SUMMARY: LAND OFF WROTTESLEY PARK, ROAD, PERTON
24 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT LANDSCAPE AND VISUAL
LANDSCAPE CHARACTER SITE-SPECIFIC CONTEXT 3.42 The characterisation process is a non-value judgement process; 3.44 South Staffordshire District Council has produced a Landscape 3.47 The site comprises 2 individual fields separated by mature therefore, classifying landscapes into distinct areas does not Study (2019) which forms part of the Local Plan Review evidence hedgerow and tree planting. suggest that one character area is more sensitive than another base. The site falls with Landscape Parcel Reference: SL29 3.48 The northern site boundary is defined by a PRoW which runs along or valued by people more or less. S1, which itself falls within the ‘Settled Farmlands’ Landscape an access drive to a number of farmsteads to the north. Beyond Character Type. The landscape area is located west of Perton and 3.43 The landscape character appraisal process reviews the wider this a woodland block physically and visually contains the northern Wightwick (Wolverhampton), and includes a narrow strip of land landscape character type at a national level, explores more boundary. which separates the two settlements. The southern boundary is detailed character features at a district/local level and analyses formed by the A454, the eastern boundary by the settlement edge, 3.49 The site’s eastern boundary is defined by Wrottesley Park Road site-specific land use that informs local distinctiveness and and the south western boundary by Pattingham Road. Nurton and associated residential dwellings which back onto the site. sense of place. This promotion document considers the local, Brook forms the western boundary, and the northern boundary These provide an urban influence to the site which is surrounded site-specific character features and context as identified through is formed by field boundaries. The area incorporates Perton Park by countryside to the west. fieldwork. From this we can identify the relevant characteristics Golf Course. and important site features to retain. 3.50 To the south west of the site lies Perton Golf Course, which 3.45 The Study concludes that the landscape is considered to have a confirms the area is not unspoilt landscape and contains moderate overall sensitivity to residential development. The narrow urbanising features. To the south, further fields adjacent to buffer of open agricultural land between the southern settlement Wrottesley Park Road provide a small gap between the existing edge of Perton and Wightwick has a particular sensitivity due to its residential dwellings and Perton Golf Course. role in preventing coalescence between the settlements. 3.51 The hedgerow and field boundaries provide containment and
3.46 It is considered that the development of the site for residential structure to the fields and are also characteristic features within purposes represents an opportunity to strengthen existing field the surrounding local landscape. They should be retained where boundaries and provide a new country park, which would serve to possible to strengthen the locally-contained nature of the site. define the western edge of Perton.
LANDSCAPE SENSITIVITY RATING | NOT TO SCALE
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 25 1
2 VIEWS • Viewpoint 1 shows the view from the PRoW along the northern site • Viewpoint 2 shows the view from the long distance route, boundary facing south. The lack of boundary vegetation along the Monarch’s Way, which runs north to south in close proximity to southern side of the track allows for clear views across the site. the western site boundary. The rising topography almost entirely In the distance, residential properties off Wrottesley Park Road screens views towards the site to the east. Glimpses are possible are visible, showing that the frontage to the east will need to be of Perton Golf Course to the right, which is situated to the south considered to reflect the current built-edge. west of the site and will allow for limited intervisibility through boundary vegetation.
26 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 3
4
• Viewpoint 3 shows the view further along the track off Wrottesley • Viewpoint 4 shows the view facing west from the central gated Park Road as it approaches Monarch’s Way. This view represents access off Wrottesley Park Road. This view represents transient recreational users of the long distance footpath where users users of the road and local residents. The managed hedgerow will be travelling at low speeds along pedestrian routes. Existing allows for clear views across the site, with sparse tree planting properties off Wrottesley Park Road are visible in the distance, filtering some views along the eastern boundary. Additional tree identifying the site in the foreground. This highlights the planting along the frontage will assist with providing a positive requirement for enhancements to the existing western boundary frontage along Wrottesley Park Road. vegetation to assist with filtering views from this route.
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 27 28 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT ECOLOGY
DESIGNATIONS BIODIVERSITY PROTECTION & ENHANCEMENT 3.52 There are no statutory sites of nature conservation importance at 3.58 The site affords considerable opportunities for biodiversity • Ponds and Lakes –Sustainable Drainage System (SuDS) features an international (e.g. Special Areas of Conservation) or national enhancement through habitat creation through the provision of a within the site could be designed to maximise biodiversity value. (e.g. Sites of Special Scientific Interest) scale located within a 5km significant area of open space both within the development area SuDS have the advantage of providing flood amelioration, visual amenity and biodiversity and therefore are a good example of radius of the site. and through an opportunity to create a new Country Park. The multi-functional green infrastructure; 3.53 There is one statutory nature conservation site within 5km creation of new habitats should be designed to contribute towards • Reedbeds – can be created around the margins of the ponds, lakes designated at a local level, Smestow Valley Local Nature targets set within the UK and Staffordshire Biodiversity Action Plan. and swales by encouraging shallow areas of periodically inundated Reserve (LNR), a mosaic of woodland/scrub/grassland situated 3.59 The scheme has the opportunity to contribute to the targets for land. Reedbeds (and other tall emergent aquatic vegetation approximately 2.6km to the southeast of the site within the the following BAP habitats: communities such as rushes and sedges) can be encouraged to Wolverhampton City Council area. establish through natural colonisation or preferably by introducing • Lowland Wood Pasture and Parkland – within a proposed Country plants through coir mats and/or plug planting; HABITATS Park and through retention and management of the existing mature trees and the planting of locally native broadleaf trees • Wildflower meadows – could be created within the areas of 3.54 The site consists predominantly of arable land with a network of and shrubs. This would also contribute to the parkland landscape grassland and open space. In order to maximise their botanical hedgerows and occasional hedgerow and field boundary trees. character of the Sandstone Estatelands; value, a variety of seed mixtures and cutting regimes should be There is a low overall diversity of habitats on the site and those employed. Meadows could be combined with short mown amenity • Lowland acid grassland – the site is underlain by sandstone grass areas by creating informal paths and larger areas for that it does support are common and widespread within the local and the free-draining slope within the western section of the recreation; and landscape. Therefore, it is considered that the ecological value of site represents a possible location for acid grassland creation. the site is limited. This is a rapidly declining habitat type of significant biodiversity • Biodiverse Architecture – consideration should be given to importance and its potential on the site should be investigated by constructing the buildings to incorporate features on their exterior 3.55 Nonetheless, it has potential to support protected species including soil analysis to determine feasibility. If achievable, this is likely to that can be used by roosting bats and nesting birds. great crested newts and bats, and also species of conservation require stripping of the O-horizon to remove the fertile topsoil rich concern such farmlands birds. in weedseeds to expose the underlying sandy substrate;
PROTECTED SPECIES 3.56 The site offers potential for protected species, notably: bats, badger, breeding birds, wintering birds and reptiles. Dedicated surveys for these species will be undertaken to identify their presence and inform the scale of any required mitigation.
3.57 It is anticipated that the site provides significant scope to deliver any required mitigation in respect of protected species through the provision of the significant Green Infrastructure proposals within the site.
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 29 FLOOD RISK & DRAINAGE
3.60 According to the Environment Agency Flood Map for Planning, 3.66 Any potential connections to this surface water network would the application site is located entirely within Flood Zone 1 (Low require crossing 3rd party land, subject to the necessary Probability), which is land defined as having less than a 1 in agreements. A potential connection may be viable to the asset 1000 annual probability of river or sea flooding. The watercourse within Hoylake Road, through an undeveloped plot. However, this is the River Penk (an ordinary watercourse), which is located would remain subject to further investigation into the existing approximately 275m east of the site. network invert levels, and confirmation of land ownership. Additionally, the network at this location is likely to be of small 3.61 The existing site is entirely greenfield in nature, with minor area diameter and would be subject to capacity assessment by Severn of hardstanding to the north eastern corner. LiDAR data suggests Trent Water. that the site is peaked within the central region, which falls away to both the eastern and western boundaries. The overall lowest 3.67 Owing to the constraints present to connect to surrounding point of the site is located to the within the north eastern corner. drainage ditches, minor watercourses and public surface water sewers, drainage via infiltration remains the preferred method of 3.62 An appropriate Surface Water Management Strategy which surface water disposal. complies with the latest local and national advice will be implemented on the site to attenuate the increase in surface 3.68 The rate at which the runoff is discharged into either an existing water runoff caused by development. As a first option, infiltration drainage ditch network or existing sewer network would be should be considered for the disposal of surface water due to restricted to the equivalent greenfield runoff rate, preventing the expected favourable ground conditions of Sandstone bedrock an increase in flows leaving the site and thus ensuring that the geology with superficial deposits of sand and clay. It is therefore development does not have a detrimental impact upon flood risk strongly recommended that infiltration testing is carried out at elsewhere.
the earliest opportunity, to confirm if drainage via soakaway is 3.69 Through the application of Sustainable Urban Drainage Systems achievable and ascertain a suitable rate of infiltration. (SuDS), the additional surface water will be stored within the 3.63 In the event that infiltration is not viable, alternative surface water site and subjected to multiple stages of treatment to guarantee outfall locations should be investigated. A network of drainage that the water quality in the wider drainage network is protected. ditches appears to be present beyond the northern site boundary, Wherever possible SuDS features will be above ground to enhance to the north of the private access road. However, any connection the aesthetic amenity of the development and provide valuable SURFACE WATER FLOODING | NOT TO SCALE would be subject to proving onward connectivity and existing habitats for the local wildlife.
condition, through survey works. 3.70 The attenuation provided will be appropriately sized to include an 3.64 Furthermore, any connections would be reliant on agreements to allowance for climate change. Example SuDS features that will connect through 3rd party land. be incorporated into the development wherever possible include attenuation basins, permeable paving and swales. 3.65 There are no public surface water or combined sewers located within the adjacent Wrottesley Park Road. Surface water sewers 3.71 Principles within the previous concept plan iteration should be are present within the neighbouring residential development to the maintained, specifically the allocation of space for a ‘blue corridor’ east, which discharge directly to the River Penk. which serves the proposed attenuation pond.
30 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT INDICATIVE SURFACE WATER DRAINAGE APPRAISAL | NOT TO SCALE
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 31
4 VISION 4 VISION
VISION • To produce a living environment of the highest standard, with a • To provide a locally inspired and meaningful new green space clear and recognisable identity which reflects the local vernacular network which enhances the character of the site and the natural of Perton and contextual views; and historic environment and creates a robust and enduring new • To provide a sustainable development comprising a range of Green Belt boundary; and houses, including family homes and smaller properties and • To create a development that will enhance the attraction of Perton significant new areas of publicly accessible open space, including as a place to live and work, incorporating valued aspects of local a new Country Park to serve the village of Perton; character, heritage, landscape, visual amenity and biodiversity. • To create a safe, attractive and secure neighbourhood, streets and places which promote social interaction which will afford access and movement priority to pedestrians and cyclists, including connectivity with the existing network of footpaths to local services and facilities;
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5 INDICATIVE MASTERPLAN AND DESIGN PRINCIPLES 38 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 5 INDICATIVE MASTERPLAN & DESIGN PRINCIPLES
KEY ELEMENTS OF THE PROPOSAL • Delivery of up to 300 dwellings to include market and affordable homes and a mix of property types aligned to local needs; • Strong Green Belt boundary provided utilising existing trees and hedgerows; • New residential links provided to wider residential areas and Perton Centre to maximise connectivity and encourage sustainable trips; • Provision of a network of green links and corridors and provision of equipped play; • Delivery of a new Country Park to serve Perton that connects into the Staffordshire Way; • Retention of existing field pattern. • Provision of a new visitor centre/café ancillary to the Country Park. • Increased biodiversity and wildlife habitats, including incorpoation of Sustainable Drainage Systems (SuDS). • Creation of new, enduring Green Belt boundary and provide opportunity to provide recreational access, enhanced landscapes and increased biodiversity
Emerging Adjacent Proposals
INDICATIVE MASTERPLAN | NOT TO SCALE
LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT 39
Emerging Adjacent Proposals
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WEST PERTON 42 LAND OFF WROTTESLEY PARK ROAD, PERTON PROMOTIONAL DOCUMENT