Planning Appeal Statement of Case

Planning Appeal

Statement of Case

Corley Motorway Service Area (northbound)

On behalf of the Appellant:

Welcome Break Group Ltd

December 2017

(LPA ref. PAP/2017/0104)

Smith Jenkins Ltd

30A High Street, Stony Stratford, Milton Keynes, MK11 1AF

Tel: 01908 410422

Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

Contents

1 Introduction 2

2 Site and Surroundings 3

3 Appeal Scheme 5

4 Background and Chronology of Planning Application 7

5 Planning Policy 11

6 The Case on behalf of the Appellant 13

Appendix 1 Decision Notice

Appendix 2 Pre-Application Discussions

Appendix 3 Email and letter to Case Officer 4th September 2017

Appendix 4 Road Haulage Association Letter of Support September 2017

Appendix 5 Email to Council 23rd October 2017

Appendix 6 Email to Case Officer 3rd November 2017

Appendix 7 Letter from Welcome Break 6th November 2017

Appendix 8 Core Strategy Policy Extract

Appendix 9 Statement to Parliament Rt Hon John Hayes MP

Appendix 10 Committee Reports

Appendix 11 West Midlands Green Belt Review Study – Parcel KY3 extract

Appendix 12 Aerial Photographs of HGV Parking Area

Appendix 13 Article from Craig Tracey MP website

Appendix 14 Email to Case Officer 2nd October 2017

Smith Jenkins 1 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

1 Introduction

1.1 This appeal is made against the refusal of planning permission for the change of use of land for the creation of 63 HGV parking spaces adjacent to the existing Corley Motorway Service Area, M6 Motorway, North Warwickshire. The application was submitted to North Warwickshire District Council on 1st March 2017 (under Application Reference: PAP/2017/0104).

1.2 The application was refused planning permission by the Planning and Development Board and a decision notice issued on 7th November 2017 for the following single reason:

“The proposal represents inappropriate development within the Green Belt. It is considered that this causes significant harm, and that as such the considerations put forward by the applicant do not amount to the very special circumstances to clearly outweigh this harm. The proposal does not therefore accord with Policy NW3 of the North Warwickshire Core Strategy 2014, or with Section 9 of the National Planning Policy Framework 2012.”

1.3 The decision notice is contained within Appendix 1.

1.4 This Statement of Case sets out the planning case and positive merits of the scheme on behalf of the appellant, Welcome Break Group Ltd. To assist the Inspector, the appellant has set out the background to the appeal along with a chronology of events to understand how the Council came to their decision.

1.5 A request has been made to proceed with this appeal by way of written representations.

Smith Jenkins 2 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

2 Site and Surroundings

Site

2.1 The appeal site can be identified from drawing number CMSA-BWB-GEN-XX-DR-TR-106 (site location plan). This also identifies all other land in the control of the appellant.

2.2 The site lies to the south of the M6 motorway and is bordered along its western, southern and eastern edges by fields, all of which are in the ownership of Welcome Break. The MSA is an ‘online’ facility and is only accessible by the public directly from the motorway. The southbound services are linked to the northbound by means of a pedestrian footbridge. In addition to the amenity building, the MSA also accommodates a fuel filling station, segregated car park, HGV and Coach park, Days Inn hotel and Starbucks drive-thru coffee shop. The site benefits from mature landscaping.

2.3 A secondary access to the MSA is located to the west of the site, and provides a single car width access from Highfield Lane into the MSA. This is controlled by secure barrier and access is restricted to emergency services and Welcome Break employees. Welcome Break do not own the field that is located between the MSA, north of the access road and Highfield Lane.

2.4 For the avoidance of doubt, this appeal relates to the service area that is located to the south side of the M6 motorway, however this is referred to as ‘northbound’ services because it serves traffic travelling north along the motorway.

2.5 The wider area is shown on the below map for context:

Figure 1: Aerial photo of Corley MSA

2.6 The site was opened in the early 1970s and has been the subject of a number of planning applications. The operation of MSAs are strictly controlled by Highways England via a ‘signage’ agreement that grants the operator the right to sign the site from the Strategic Road Network (SRN). In order to obtain a signage agreement, a minimum level of facilities must be provided, and must be available for the public 7 days a week, 24 hours a day. The details of these facilities

Smith Jenkins 3 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

are set out in Department for Transport Circular 02/2013. This includes the provision of parking based on the amount of traffic on the motorway. This must be segregated and available at all times for each user group.

2.7 The fields immediately around the northbound MSA are used for the grazing of horses (although it must be noted that the owners do so without the consent of Welcome Break). Beyond the fields to the south is Bennetts Road North, which leads to the northern suburbs of Coventry to the south. This road has built development along the north site almost continually until it meets Keresley. The village of Corley is to the south-west of the appeal site.

2.8 There are a small number of residential dwellings that share a boundary with land owned by Welcome Break. These are set at least 25 metres back from the boundary (although this is not the boundary with the appeal site) and are all accessed via Bennetts Road North.

2.9 The appeal site is mainly rectangular in shape, although the site tapers into a point where is meets Bennetts Road North. A field access into the site is maintained from Bennetts Road North, which can be accessed by a vehicle. The site is bounded on all sides by mature hedgerows and trees. It is mainly flat. There are two sets of overhead cables that traverse the site from east to west. The site shares one long boundary with the MSA which is separated by a hedge and post and rail fence.

2.10 Careful consideration has been given to the location of the proposed development. The proposed site is located to the east of the MSA, and at the opposite end of the site to the existing HGV parking area. Operationally, a site located immediately south of the existing HGV park, and therefore connected to that parking area would be a better location for development operationally, however the appellant recognised that this location would have the greatest impact on the residents of Bennetts Road North. To balance the need for additional spaces alongside reduction in any harm that may arise as a result of the development, the appellant considered the proposed site to be better located.

Smith Jenkins 4 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

3 Appeal Scheme

3.1 The proposal is to extend HGV parking into the field to provide a further 83 HGV parking spaces. This would provide for 12 over-sized HGV parking bays and 71 standard sized bays. The site layout is provided in drawing reference CMSA-BWB-GEN-XX-DR-TR-105 revP2. The site is accessed from the existing internal circulation road. It is intended that internal signage within the MSA will guide HGVs to this parking area first as there is an operational one-way system within the site which means that should HGVs not enter this area first, there is no method of re- circulation. This is achieved through advanced signage and road markings which will direct HGVS left into the site from the main internal road. The entrance will be controlled by a barrier and actively managed to ensure that when the need for spaces is least, only the existing HGV park would be used. The appellant has suggested that the appeal site be covered by a site management plan which would include hours of operation, lighting, and CCTV provision. In the case for the appellant (section 5 of this statement), we have suggested conditions that would include provision of this should permission be granted.

3.2 The proposed layout has been tracked and shown that HGVs can successfully navigate within the site, leaving in a forward gear. The appeal scheme has been the subject of a Stage 1 Road Safety Audit which has been agreed by Warwickshire County Council.

3.3 Corley MSA is recognised as providing high quality facilities for drivers using the M6 motorway. This was confirmed in the Transport Focus Motorway Services User Survey, published in October 20171 which ranked Corley northbound as the third best services in the country. Welcome Break are committed to providing a good standard of facilities for all drivers and recognise the need for more HGV parking in this location.

3.4 The appeal scheme proposes the extension of provision of additional HGV parking to support the function of the Motorway Service Area. The appellant has identified a significant requirement for further HGV parking at this site. Parking spaces would utilise the existing on-site facilities in the amenity building, Starbucks Drive Thru and fuel filling station (FFS). As such there would be no requirement to duplicate any facilities required by drivers in taking a break.

3.5 The HGV park would be suitably lit. The appeal proposal is supported by a lighting strategy which has been given detailed consideration by the appellant. It resolves to provide a larger number of lower level lights to reduce the impact of lighting on the surrounding area. This is clearly set out by the luminenance levels that are shown in the accompanying lighting strategy and plan (drawing reference CMSA-BWB-HLG-XX-CA-C-1300). The site would also be covered by CCTV provided as part of the wider management of this site. The appeal scheme has been designed to retain all existing landscaping within the field boundaries and to enhance this. Where necessary a landscaped bund would also be provided to act as a both visual and acoustic barrier between the site and potential receptors. A fence will also be provided for acoustic and security purposes.

3.6 The surface water drainage strategy provides for a pond to the north of the site. This also provides biodiversity enhancement. Further biodiversity enhancement is proposed in the adjacent field through meadow planting. As set out in more detail in the planning chronology, additional hedgerow planting is also proposed as part of the landscaping scheme between the

1 Link to Transport Focus study published October 2017: http://d3cez36w5wymxj.cloudfront.net/wp- content/uploads/2017/10/12101741/Motorway-Services-User-Survey-Spring-2017.pdf

Smith Jenkins 5 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

rear of properties on Bennetts Road North and the application site to create a buffer zone free from development. This was designed in conjunction with Members of the Planning Board.

3.7 The existing MSA would remain as currently. HGV drivers would be able to use the facilities within the Starbucks Drive Thru (which includes a toilet) and the amenity building. A suitable pedestrian route would be provided including a pedestrian crossing. The amenity building facilities include toilets, showers, food and beverage outlets and a shop. Parking for any longer than 2 hours at the site is subject to a charge. The charge for HGV drivers includes use of the showers, a hot meal and drink. HGV drivers pay this charge (as is evidenced in the number of drivers recorded who have used the site). They either pay on an individual basis or haulage firms have an account with the Appellant. These companies pay in advance for their drivers to stop at the site.

Smith Jenkins 6 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

4 Background and Chronology of Planning Application

4.1 The documents that form the planning application were subject to a number of changes during the course of the application. In addition there were a number of changes made to the scheme as a result of discussions held with Members of the Planning Board. This section of the appellant’s Statement of Case sets out the background to the current application and a chronology of events that led to the refusal of the application at the Council’s Planning Board meeting on 6th November 2017.

Background

4.2 In 2008, the appellant applied to North Warwickshire District Council for permission for a 75 space HGV park in a similar location to the one currently proposed (planning application reference PAP/2008/0658). Planning permission was refused for three reasons, namely:

1. The site is within the designated West Midlands Green Belt. The proposals constitute inappropriate development with the Green Belt, as defined within Planning Policy Guidance Note 2 Green Belts. The proposals will cause significant harm to the Green Belt due to the inappropriate nature of the development; it will reduce the openness and will be injurious to the visual amenities of the Green Belt. The proposal is not in accord with the land use objectives identified for the appropriate use of land within the Green Belt. Guidance is clear that inappropriate development should not be approved except in very special circumstances. The need for substantial additional lorry park facilities and the proposed location adjacent to the existing service area are put forward as very special circumstances. The existing provision of parking for northbound HGVs at the Corley Motorway Services appears to be consistent with the level of provision indicated in national guidance issued relevant to the provision of such services. The applicants forecast of the growth in the number of HGVs is inconsistent with the forecast within the National Transport Model Road Transport Forecasts 2008. The need for substantial additional provision is thus considered to be questionable. Existing lorry park facilities within an appropriate distance of Corley appear to have been omitted from consideration, both in terms of the existing capacity and as possible alternative locations. Very special circumstances that would justify the grant of planning permission are not considered to exist with regard to the development proposed. The proposal is therefore contrary to policies CP4 & ENV2 of the North Warwickshire Local Plan 2006.

2. The proposed lorry park will encroach into the open countryside that lies between the existing motorway service area and nearby residential properties. This area of open countryside provides a significant zone of separation that mitigates adverse impacts arising from activities within the present area. Measures are proposed to originally mitigate potential disturbance arising from the proposed lorry park are not considered to satisfactorily address the concerns over loss of amenity for residential properties due to disturbance from noise, light and vehicular activity. Proposed improvements to these measures have not been submitted in sufficient detail to enable the proper consideration of the improved measures. The proposal is thus considered to be contrary to Policies CP2, CP11 and ENV11 of the North Warwickshire Local Plan 2006.

3. The Highways Agency have directed that the application should not be approved as insufficient information has been provided to ensure the M6 Motorway will continue to serve its purpose as part of the national system of through routes for through traffic in accordance with Section 10(2) of the Highways Act 1980 minimising disruption on the Motorway Network and in the interests of road safety. The submission of a Road Safety Audit is required. The proposal is thus considered to be contrary to Policy TPT2 of the North Warwickshire Local Plan 2006.

Smith Jenkins 7 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

4.3 The refusal was not subject to an appeal.

4.4 The Appellant considered that in part due to the passage of time, and as a result in the rise of HGV movements on the strategic road network, with a consequential increase in the need for HGV parking, that the development should be looked at again. In looking again at the site, the Appellant considered the three reasons for refusal and addressed these in their submission to the LPA. In respect of the ‘very special circumstances’, additional survey work was undertaken to establish the current usage of the site. Secondary data was collected via the pay-to-park records for HGVs. Alternative sites were assessed. Additional survey work and mitigation proposed where necessary in relation to drainage, landscape and noise. A Road Safety Audit was submitted as part of the planning application.

4.5 The Appellant therefore made a request to North Warwickshire District Council for pre-application advice in respect of a similar development (reference PRE/2016/0275). The pre-application submission was made in December 2016 (and included in Appendix 2) and a meeting held on site with Mr Ian Griffin of NWDC on 6th January 2017. No formal written report of the discussions were provided by the local planning authority however their advice was confirmed by Mr Griffin in an email dated 9th January 2017 (see Appendix 2).

4.6 The local planning authority confirmed that they agreed with the Appellant’s submission that circumstances at the site had changed sufficiently that the proposed development could be considered again and that the very special circumstances necessary to overcome the presumption against development in the Green Belt may be present.

4.7 As a result of these discussions, the Appellant prepared a planning application that addressed the previous reasons for refusal and set out the requirement for development based on up-to- date survey and other evidence.

4.8 A planning application was submitted to the LPA on 1st March 2017 and validated on 9th March. The planning application was formed of the following documents:

 Application forms;  Covering letter, dated 28th February 2017;  Site location plan, drawing reference CMSA-BWB-GEN-XX-DR-TR-106;  Blue line plan, drawing reference CMSA-BWB-GEN-XX-DR-TR-107;  Parking Extension (General Arrangement Plan), drawing reference CMSA-BWB-GEN- XX-DR-TR-105  Transport Assessment, prepared by BWB;  Flood Risk Assessment, prepared by BWB;  Sustainable Drainage Statement, prepared by BWB;  Lighting Design Report, prepared by BWB;  Lighting Drawing, drawing reference CMSA-BWB-HLG-XX-CA-C-1300;  Preliminary Ecological Assessment, prepared by Ecology by Design; and  Landscape and Visual Impact Assessment incorporating landscape design proposals and tree survey, prepared by Barry Chin Associates.

4.9 Following receipt of comments from Warwickshire County Council in their capacity as lead flood authority, further drawings were submitted on 10th April, namely:

 CMSA-BWB-HGR-XX-DR-EN-201_Surface Water Strategy; and  CMSA-BWB-HGR-XX-DR-202_Pond Cross Sections.

Smith Jenkins 8 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

4.10 Following receipt of these drawings, WCC withdrew their objection to the scheme (letter dated 2nd May 2017).

4.11 A further submission was made on 28th May 2017 encompassing archaeology, noise assessment and additional highways information. The document references are:

 Road Safety Audit, Stage 1, prepared by BWB;  Road Safety Audit – Design Team Response, prepared by BWB;  Noise Impact Assessment, prepared by BWB; and  Archaeological geophysical survey, prepared by MOLA;

4.12 On 14th June 2017 further comments on noise from the Council’s Environmental Health team were received. A further response was submitted to the Council dated 30th June 2017.

4.13 The appellant submitted further information on 4th August 2017 as listed below:

 Update Planning Statement, prepared by Smith Jenkins Ltd;  Biodiversity Calculator, completed by Ecology by Design;  Bat survey, completed by Ecology by Design;  Proposed HGV Parking Extension, drawing reference CMSA-BWB-GEN-XX-DR-TR- 105 rev P2; and  Swept Path Analysis, 16.5m and 18.5 m Articulated Vehicles, drawing reference CMSA-BWB-GEN-XX-DR-TR-110 rev P2.

4.14 Following this last submission of information, the Appellant wrote to the LPA on 4th September via email and letter setting out the need for the development (Appendix 3).

4.15 The site was considered by the Planning and Development Board on 4th September 2017. The Planning Board agreed with the Head of Planning’s recommendation to make a site visit.

4.16 The Road Haulage Association wrote to the LPA on 25th September 2017 setting out its support for the scheme (Appendix 4).

4.17 Two site visits were made by the Board. The first on 29th September 2017 at 5pm took place and Members visited the appeal site and surrounding area. The second visit took place on 5th October 2017 at 8pm at Corley MSA. Members viewed the appeal site and HGV parking on the MSA. This visit was accompanied by officers and the Appellant.

4.18 The scheme was considered at the Planning and Development Board meeting on 9th October 2017. The planning application was recommended for approval by officers subject to conditions. Members voted to defer the decision on the application to allow a meeting to take place between Members and the Appellant to discuss Members’ outstanding concerns with the scheme.

4.19 A meeting between Members of the Planning and Development Board, the Head of Planning and the Appellant took place on 19th October 2017. A note of the meeting was sent to the Head of Planning by the Appellant’s agent on 23rd October 2017 (Appendix 5). A number of matters were agreed with Members during the course of that meeting which, the Appellant believed, met their concerns. An enhanced landscape mitigation plan was submitted (drawing reference: 1735- 17-03 revB) which included enhanced planting to the rear of properties to Bennetts Road North to provide a buffer between those properties and the MSA.

Smith Jenkins 9 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

4.20 The Agent sent a further email to the Head of Planning on 3rd November 2017 responding to objections from third parties (Appendix 6). Mr Rod McKie, Chief Executive of Welcome Break, the Appellant, wrote to the Council on 6th November (Appendix 7).

4.21 The planning application was considered at the Planning and Development Board on 6th November 2017. Members voted to refuse planning permission with 6 votes in favour of the scheme and 7 against. The Decision Notice was issued on 7th November 2017 (Appendix 1).

Smith Jenkins 10 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

5 Planning Policy

National Planning Policy Framework (NPPF)

5.1 The NPPF was published in March 2012 and sets out the Government’s planning policies for England and how they are expected to be applied. At the heart of the NPPF is a presumption in favour of sustainable development (para. 14) which should be seen as a golden thread running through both plan making and decision taking. For decision taking this means unless material considerations indicate otherwise:

 Approving development proposals that accord with the development plan without delay; and  Where the development plan is absent, silent or relevant policies are out of date, granting permission unless:

 any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or

 specific policies in this Framework indicate development should be restricted (e.g. those policies relating to sites protected under the birds and habitats directive and/or designated as SSSIs, land designated as Green Belt, Local Green Space, AONB, Heritage Coast or within a National Park, designated heritage assets, and locations at risk of flooding or coastal erosion).

5.2 Paragraph 31 of the Framework deals with roadside facilities. This states that the primary function of roadside facilities for motorists should be to support the safety and welfare of the road user.

5.3 Section 9 of the Framework deals with Protecting Green Belt Land. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. Paragraph 79 clearly states that the essential characteristics of Green Belts are their openness and permanence.

5.4 Paragraph 80 states that Green Belts serve five purposes:

 To check the unrestricted sprawl of large built up areas;

 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.

5.5 Paragraph 87 and 88 of the NPPF state:

87. As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.

Smith Jenkins 11 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

88. When considering any planning application, local planning authorities should ensure that substantial weight is give to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

Development Plan Policies

5.6 The North Warwickshire Core Strategy (2014) sets out the boundary of the Green Belt. Policy NW3 of the Plan sets out the policy in respect of Green Belts.

5.7 Relevant policy extracts and an extract from the proposals map are within Appendix 8.

Circular 02/2013

5.8 Department for Transport Circular 02/2013, The Strategic Road Network and the Delivery of Sustainable Development (September 2013) sets out Government policy for roadside facilities in England. Annex B addresses roadside facilities, and includes policy on the provision, standards and eligibility for signing of roadside facilities on the strategic road network (SRN). It re-confirms Paragraph 31 of the NPPF that the primary function of roadside facilities is to the support the safety and welfare of the road user. The Circular applies to all existing roadside facilities. Schedule 1 of the Circular sets out the parking requirements at motorway service areas (MSA).

5.9 John Hayes MP made a Statement to the House of Commons in December 2016 addressing the need for HGV parking nationally. This is included in Appendix 9 for context.

Smith Jenkins 12 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

6 The Case on behalf of the Appellant

6.1 Planning permission for the extension to Corley MSA to provide HGV parking was refused subject to a single reason, namely:

The proposal represents inappropriate development within the Green Belt. It is considered that this causes significant harm, and that as such the considerations put forward by the applicant do not amount to the very special circumstances to clearly outweigh this harm. The proposal does not therefore accord with Policy NW3 of the North Warwickshire Core Strategy 2014 or with Section 9 of the National Planning Policy Framework 2012.

6.2 Permission was refused contrary to the advice of Planning Officers of North Warwickshire Council. Officers concluded that the development is inappropriate. Harm to the Green Belt is by definition only, and that harm was assessed as ‘moderate’. Officers set out in their report to Committee that there is no highway or flooding harm; minor landscape and visual amenity harm, less than substantial harm to heritage assets and limited harm to residential amenity. Officer’s judged the case put forward by the applicant to be ‘substantial’ and that there was a ‘gap’ between the harm and benefits sufficient to demonstrate the ‘very special circumstances’ necessary to over-come the in principle objection on Green Belt grounds and for Officers to recommend planning permission being approved. The application was reported to Planning Board on three occasions, and the three reports are set out in Appendix 10 of this Statement.

6.3 The Appellant discussed the scheme directly with Members (as recorded in an email to Officers as included in Appendix 5 and in the report to Committee of 6th November (Appendix 10)) after which a number of amendments were made to the scheme (discussed in more detail in Section 4 of this Statement above). The view of Officers was that these discussions and subsequent amendments added further weight to the Appellant’s case, and added weight in favour of approving planning permission.

6.4 It is common ground with the Local Planning Authority (LPA) that there are no objections to the scheme from any Statutory Consultee. There are no other material considerations relevant to the determination of the appeal. Therefore, this appeal is subject to a single issue which is whether there are very special circumstances in this case that overcome the presumption against development in the Green Belt sufficient to allow the appeal.

6.5 Paragraph 88 of the NPPF states:

When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

6.6 The proposed development does not fall within the list of exceptions (or ‘appropriate’ development) included in Paragraph 89 or 90 of the Framework and is therefore ‘inappropriate’ development. Development in the Green Belt is by definition only, harmful. Case law has clarified that the first sentence of Paragraph 88 must not be read in isolation from the policies that sit alongside it. The decision-maker must give ‘substantial weight’ to any harm to the Green Belt properly regarded as such when policies in Paragraph 79 to 92 are read as a whole. The

Smith Jenkins 13 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

fundamental aim of the Green Belt is to keep land permanently open (Paragraph 79). Paragraph 80 sets out the five purposes of the Green Belt.

Assessment against Aims of the Green Belt

6.7 The appeal site is well contained within the existing field boundaries on each side of the site. These field boundaries are proposed to be retained and strengthened by additional planting as part of the appeal scheme. No buildings are proposed. In terms of the five purposes of Green Belts, the only purpose that the appeal scheme clearly conflicts with is purpose three, “to assist in safeguarding the countryside from encroachment”. However, the degree of encroachment is limited and contained. There is no reason that the granting of consent for this development would lead to pressure on the surrounding countryside for development as the proposed development is specific, and uniquely required to be located here. The site has already suffered a degree of encroachment in part due to the presence of the neighbouring MSA and also the pylons that are located overhead.

6.8 In terms of openness, there are two elements to the assessment of openness: physical openness (the presence or lack of buildings); and visual impact. In respect of physical openness, there are currently no buildings on the appeal site. Other than the field boundaries, and overhead power lines, the site is devoid of built features. The proposed change of use of the site will not result in the construction of buildings but will result in the laying of hardstanding, and the erection of lighting columns. Neither in themselves detract from openness. The parking of HGVs on the hardstanding is only temporary in nature and therefore would detract from openness but not permanently in the same way as a building. Therefore the impact on openness would not be constant but the Appellant acknowledges that there would be some harm. The Appellant agrees with the Planning Officer’s assessment that this harm would be moderate rather than severe because the harm would be limited.

6.9 In terms of visual impact, the Landscape and Visual Impact Assessment that forms part of the planning application assesses the degree to which the site contributes to the wider countryside (and Green Belt) and the impact that any development in this location would have on the countryside as a result. This concludes that beyond a distance of 300 metres from the site, the site is either obscured by topography, built form or intervening vegetation or becomes insignificant within the wider context of the landscape. The retention of existing vegetation provides a significant level of screening and combined with mitigation planting and increased establishment will further reduce the limited effect on short range views over time. Paragraph 4.2 of the LVIA states:

Whilst carrying out the baseline visual study it became evident that the site is relatively well contained visually with a degree of enclosure and screening provided by the landform, adjacent development such as the existing MSA, established woodland blocks and mature hedgerows. From within the site there are limited views out towards the surrounding countryside and the rear of properties on Bennetts Road North.

6.10 The site is relatively low lying in comparison to surrounding areas. The landscape is characterised in the North Warwickshire Landscape Character Assessment as:

An elevated farmed landscape of low, rounded hills, steep scarps and small incised valleys. This landform combined with extensive hilltop woodlands and tree cover creates an intricate and small scale character, punctuated by numerous scattered farms and hamlets.

Smith Jenkins 14 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

6.11 However, it is significant that the M6 motorway, MSA and the pylons located on the site are identified as major urbanising elements which detract from the character of the area. The Appellant considers that the site’s proximity to these detractors impacts upon the openness of it, and is a significant detractor for the assessment of openness. Therefore, while there would be some impact on openness, this would be limited as a result of the characteristics of the site. Any harm would be localised, and there would be limited impact on the surrounding landscape. That harm would be viewed within the context of the site which has major urbanising detractors in the form of the M6 and MSA itself. The harm caused to the visual impact would be mitigated against so that even the localised harm would be minor or neutral.

6.12 The appeal site forms part of a parcel of land known as KY3 for the purpose of assessment within the West Midlands Joint Green Belt Review Study. The KY3 Assessment is included at Appendix 11 of this Statement. This Assessment goes through each of the 5 purposes of Green Belts as set out in Paragraph 80 of the Framework. The appeal site forms a small part of the northern section of KY3. In respect of each ‘purpose’, the parcel is given a score however in respect of the appeal proposal, the commentary on each purpose is also important. In the assessment of urban sprawl, KY3 is given a score of 1 for both ribbon development and openness. However, it is noted that “The M6 follows the parcel's northern edge. Bennetts Road North emanates from the north western edge of Keresley Newlands and follows the southern edge of the parcel. A significant about of ribbon development has already occurred along the northern edge of Bennetts Road North reducing the significance of the parcels role in preventing the north eastwards sprawl of Coventry within the parcel.”

6.13 In terms of openness, it is noted that the parcel contains the south side of the M6 services at Corley, which detract from openness in this location. In respect of purpose 3, safeguarding the countryside from encroachment, the Assessment states: “The majority of the parcel is open agricultural land; however, the parcel contains some significant urbanising influences, most notably the southbound side of the Corley Services on the M6 motorway. A line of pylons cuts through the parcel. In addition, the Littlehurst Garden centre is located in the southern corner of the parcel, and there are several residential dwellings on the north side of Bennetts Road. The buildings associated with these developments urbanise the countryside and compromise the openness of the Green Belt within their immediate vicinity.”

6.14 This assessment agrees with the views of the Appellant in respect of the existing features within the immediate vicinity of the site, and the contribution the site itself makes to the Green Belt. Our assessment of the purpose of the site to the wider Green Belt is that it is limited and confined as a result of the landscaped field boundaries that form the edges of the site. The site is seen within the context of the M6, the MSA and pylons. The introduction of further planting as part of the development scheme would reduce the limited harm that would be caused. There are no proposed buildings as part of the scheme and the use of the site by HGVs would be transient and therefore would not cause permanent harm.

Very Special Circumstances

6.15 It is the Appellant’s case that very special circumstances are present in this case that would overcome the harm, by definition, of the development. The very special circumstances in this case are the need for the facility; and the lack of alternative facilities to meet that need either within or outside of the Green Belt.

Smith Jenkins 15 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

6.16 The purpose of Motorway Service Areas is to provide the public with the opportunity to stop and rest. Paragraph 31 of the Framework states that the primary function of roadside facilities for motorists should be to support the safety and welfare of road users. Paragraph B4 of DfT Circular 02/2013 states that Motorway Service Areas perform an important road safety function by providing opportunities for the travelling public to stop and take a break during the course of their journey. It states: “Drivers of commercial and public service vehicles are subject to a regime of statutory breaks and other working time restrictions and these facilities assist in compliance with such requirements.” Pages 9 and 10 of the Transport Assessment set out the current enforcement policy of the Driver and Vehicle Standards Agency (DVSA) in respect of breaks and daily driving limits. The maximum daily driving limit for HGV drivers is 9 hours. For a driver to take the maximum daily allowance, they can drive for 4.5 hours, rest for 45 minutes and then drive for a further 4.5 hours before stopping for the day.

6.17 A vehicle’s tachograph records the vehicle and therefore driver’s travel time. It is a legal requirement to use a tachograph and the rules concerning driver standards are set out in GV262. Once a driver reaches the daily driving allowance, they must stop and rest. They can only exceed this limit in an emergency or unforeseen event (such as mechanical breakdown) but must not plan to exceed the daily driving limit. Drivers normally plan their breaks at suitable stopping points however events such as traffic congestion may force a driver to stop at an unplanned location. It is normal driver preference to stop as close to the strategic road network as possible to ensure that driving time is maximised. Deviation from the route to find a place to stop causes delay and uses up driving time from the daily allowance. It is Highways England’s preference to locate service areas ‘on-line’ (rather than at junctions or further off the motorway). This is set out in Paragraph B13 of Circular 02/2013: “On-line service areas are considered to be more accessible to road users and as a result are more attractive and conducive to encouraging drivers to stop and take a break.”

6.18 The legal requirement for commercial drivers to take a break reinforces the importance of having sufficient capacity at service areas to allow drivers to safely stop and rest. MSAs provide an important highway safety function in this regard.

6.19 It is important to note that HGV drivers take two types of break: a 45 minute rest break, and a longer 12 hour break. It is normally assumed that the 45 minute break is taken during the day and a longer break taken over night (when the driver would sleep in his cab). However, it is increasingly the case that HGV drivers will drive over night and rest during the day therefore it cannot be guaranteed that all parking at night will be for the longer break and a shorter break during the day. There must therefore be sufficient capacity at the MSA for drivers to be able to take their break. The consequences of not taking a break are to impact on road safety – the enforced driver break is to ensure the safety of both the HGV driver and other road users. Providing a safe, convenient place to stop (both for the driver and also not causing a road safety hazard for other road users) is the purpose of the MSA and also the proposed extension put forward in the appeal. The consequences of a lack of HGV parking spaces are parking in inappropriate locations (such as housing estates) or using the hard shoulder of the motorway. A lack of facilities including toilets, leads to anti-social behaviour. HGV drivers also feel unsafe, and the safety of their cargo is also put at risk (this is outlined further in the letter for support for the application from the Road Haulage Association Appendix 4).

6.20 At Corley MSA there is currently capacity for 60 HGVs to stop, along with one abnormal load bay. The abnormal load bay is frequently used for up to 4 HGVs to park in rather than remaining free

Smith Jenkins 16 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

for an oversized vehicle. However, the site regularly experiences HGV numbers in excess of 60 vehicles. This causes HGVs to try and find alternative space within the site; dangerous parking (and the risk of collision); and for HGVs to enter the site, not find a parking space and then leave.

6.21 Corley MSA was opened in the early 1970s. It was designed in an era when there were fewer vehicles on the SRN, and commercial vehicles were smaller than those currently using the network. It is expected that any vehicle larger than a small van would be required to park in the HGV park (although there is segregated parking for caravans and coaches). The average size of an HGV is 16.1 metres. The Government has however extended a trial to licence up to 1000 vehicles which are ‘over-sized’ and are 18.1 metres long. The current capacity of the site is for 60, 16.1 metre vehicles. The aerial photographs contained in Appendix 12 show how the HGV parking area is commonly used (and also demonstrates the degree to which the site is used to capacity2). Figure 14 of the Transport Assessment shows how the 60 spaces within the HGV park can be used. It is acknowledged that space F7 is largely unusable (thereby reducing the number of spaces to 59). In addition, if an HGV parks in space F1 then this largely blocks entrance into the HGV parking area. Figure 13 of the Transport Assessment shows alternative locations where HGVs also park. These are not within the HGV designated areas at the site. Figure 14 also identifies spaces within the coach and caravan park which HGVs utilise3. In total there are 60 marked spaces within the HGV parking area, 4 spaces within the abnormal load bay, 54 potential other locations around the site where HGVs park opportunistically and 11 spaces within the coach/caravan park.

6.22 Circular 02/2013 includes a calculation at Schedule 1 to determine the number of spaces required to park each transport mode at an MSA. For Corley in 2016, the HGV parking requirement was calculated as 99 spaces. Updated using 2017 traffic date, there is a requirement for 100 spaces. On pages 29 and 30 of the Transport Assessment, the requirement for parking to 2027 is calculated using a reasoned growth scenario. It is estimated that the Circular 02/2013 requirement will grow to 111 spaces by 2027. This means, that there is a calculated shortage against the current requirement of 40 official spaces. To 2027 the gap between the requirement and current provision will grow to 51 spaces. Paragraph B28 of Circular 02/2013 allows providers to increase the number of spaces beyond the requirement of Schedule 1 if it can be demonstrated that any departure from the requirement is appropriate. During the course of the planning application, Highways England were consulted on the planning application. This is reported in the planning officer’s report to the Planning Board, which states:

Highways England – no objection to the technical detail of the proposal. It also considers that the proposed development would alleviate HGV parking pressures at the Service Area. The findings of the applicant’s Transport Assessment show that the proposed development would alleviate HGV parking pressures at this Service Area and that the current provision is below that advocated by Government guidance.

6.23 There are 54 unofficial/opportunistic spaces within Corley MSA however the use of these blocks the internal road both as a result of parking itself but also during the manoeuvring of vehicles into these spaces. Parking in these locations cause a road safety hazard. During survey work of the site, 22 instances of hazardous parking was reported on the Wednesday and 26 incidents on the

2 Images in Appendix 12 are taken from Google in 2016 and 2017 and not taken specifically to support the appeal. 3 Circular 02/2013 requires that segregated parking areas are maintained for cars, coaches/caravans and HGVs. This is in the interest of safety for pedestrians/passengers within the MSA site.

Smith Jenkins 17 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

Thursday. It is BWB’s view that such parking is a significant safety risk to road users. The long- term use of these spaces is not appropriate and a safe solution needs to be provided. Welcome Break have most recently reported that HGV drivers are parking in the fuel filling station (FFS) when there are no other spaces within the MSA to park. HGV drivers stop in this way because they have to take a break in respect of the driving time directive and often cannot be moved on because to do so would breach the directive and therefore the law. Stopping in the FFS prevents other drivers from obtaining fuel. This is also a hazard and also a road safety issue in its own right. If drivers are not able to re-fuel and break down on the motorway, this is a road safety hazard. During their site visit, Members of the Planning and Development Board advised Welcome Break to call the Police if such incidents occurred. Members were keen to advise the Appellant that the Police would move HGVs on if they caused such a blockage. However, the Police have declined to intervene and consider that this is an operational issue for the Appellant. Due to the lack of space, the Police are not prepared to intervene and therefore the problem of HGV parking at the site escalates.

6.24 The problem of the numbers of vehicles using the site is clear from the survey work set out in the Transport Assessment. Table 8 of the TA shows the number of HGVs that paid to park at the site for a 3 year period (average weekday). HGVs only pay if they stay for longer than 2 hours, and these numbers therefore do not include those drivers stopping for a 45 minute break. Thursday is the busiest day of the week, and the number of drivers paying to park averages at 59. This effectively means that the site is 100% occupied on a Thursday. Monday to Wednesday the numbers paying to part were 53 or 55 (88% or 91% occupied).

6.25 The Appellant has provided the most up-to-date figures for HGVs paying to park at Corley. These are for the period 1st May 2017 to 31st October 2017. These are set out in the table below:

Total HGVs Average HGVs

Monday 1405 52

Tuesday 1566 58

Wednesday 1526 59

Thursday 1619 63

Friday 947 36

6.26 If the Monday is adjusted to take account of the bank holidays, the average number on a Monday rises to 54.

6.27 The average occupancy of the HGV park on a Tuesday (96%), Wednesday (98%) and Thursday (105%) far exceeds the critical utilisation level which is set above 85% occupied. The average weekday occupancy is 89%. As these figures only report the number of drivers paying to park (generally overnight) this does not report those drivers who are also attempting to take their 45

Smith Jenkins 18 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

minute break at the site during the night time, and therefore under reports the number of drivers at the site at any one time.

6.28 This was demonstrated on the night that Members of the Planning Board visited the site and reported it to be busy. On that evening, 65 drivers had paid to park at the site. A number of HGVs were observed to enter the site, and unable to park, re-joined the motorway without stopping. On Pages 26 and 27 of the Transport Assessment, the instances of drivers being unable to park were recorded as part of the survey work. When a driver was seen entering the site, looking for a space, unable to park and then leaving the site, this was recorded separately to those drivers who stopped simply for fuel. Table 9 of the TA provides an hour by hour summary of the non-refuelling HGVs passing through the site. In total, this number was 162 vehicles on the Wednesday and 272 on the Thursday. Between the hours of 20:00 and 06:00 when HGV parking is considered most ‘at stress’, 53 HGVs on the Wednesday and 70 HGVs on the Thursday circulated the site unable to find suitable parking and left the site. This indicates the degree of shortage of spaces on each occasion.

6.29 The Appellant is unable to record where HGV drivers then go in order to stop and take their break. However, Councillor Farrell, who spoke in favour of the provision of additional HGV spaces at the site at the Planning Board meeting, set out that HGV parking on residential streets is a particular problem in Coleshill, located at the next motorway junction west from Corley MSA. The LPA has no specific survey data to support this however, an article on Craig Tracey MP’s website (included in our Appendix 13) supports Cllr Farrell’s speech concerning the impact on the residential amenity of unauthorised lorry parking in Coleshill, and particularly issues of litter and other waste that is left behind by drivers.

6.30 The lack of parking in the locality is supported by the Department for Transport’s Lorry Parking Study published in 20114. It reported that 75% of HGV spaces at Corley MSA were full. More generally it reported that the West Midlands had the highest levels of utilisation of vehicle parking in England after the North West. Regionally, there was a shortage of 121 HGV parking spaces. Figure 4.22 of the Report showed that in 2011, North Warwickshire had fewer spaces than demand, and therefore there was no spare capacity in any HGV parks in the district. A symptom of this, as shown on the accompanying maps, is the high number of HGVs that sought parking in lay-bys or as reported by Cllr Farrell in residential areas in the district.

6.31 The Government have commissioned an update to this report, and the survey work has been completed by AECOM. However, the final report has not been published. The Appellant will submit this information to the Inspector should it become available during the course of the Appeal.

6.32 The provision of additional spaces at Corley would meet the need identified both in the survey work undertaken on site, but also identified as a need that is arising more generally in the region. The 2011 study is now likely to under-report the need for HGV parking. There has been a significant growth in HGV traffic since 2011. This is set out clearly in the annual average daily flow figures on the M6 included in Table 3 of the Transport Assessment. Since 2011, there has been an increase in all traffic on the M6 in the vicinity of the site of 16,700 vehicles daily, and of HGVs/bus/coach of 6,200 vehicles daily. The Appellant considers that the need for HGV parking

4 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/3845/chap4-west- midlands.pdf

Smith Jenkins 19 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

outlined in the 2011 AECOM report will have increased. This is certainly their own experience from the operation of Corley MSA, and the 26 other MSAs that they operate nationally.

6.33 The provision of 83 additional spaces at Corley would address the issue of hazardous parking within the existing site; provide parking in accordance with Schedule 1 of Circular 02/2013; would meet the needs of drivers who currently circulate within the site and leave without finding space to park; and provide additional parking on the SRN more generally where it is acknowledged there is a regional requirement for additional HGV parking.

6.34 While the regional need supports the under-provision of spaces more generally, it is the Appellant’s view that the spaces provided at Corley MSA would meet the specific need identified through survey work at this site. There are a number of reasons why the need for HGV parking at Corley is high. First, the M6 is a major long distance route which carries a high number of HGVs. The numbers of HGVS as a percentage of overall motorway traffic are set out in the Appellant’s email to the case officer of 2nd October 2017 (Appendix 14). The M6 to the east of the site has junctions with both the M1 and A14. Both routes provide access to the ports at Felixstowe and Dover/Folkestone, and together are a core part of the Trans-European Transport Network. The importance of the location is set out in Chrys Rampley’s letter to Jeff Brown of 25th September 2017 (Appendix 4). While it is a matter of driver choice to stop at Corley, it is also a function of a lack of alternative sites both east and west of Corley MSA; ability to easily access the site from the SRN; the high potential to encounter traffic congestion travelling through Birmingham (which delay drivers from stopping at the next available MSA); and the high volumes of traffic on the M6.

6.35 Corley forms part of a network of MSAs providing HGV parking immediately accessible from the SRN. These include Hopwood Park (M42), Tamworth (M42); Hilton Park (M6), Watford Gap (M1) and Norton Canes (M6 toll). Each of these sites were surveyed as part of the Transport Assessment. In respect of Hopwood Park (also operated by Welcome Break), a current planning application also seeks additional HGV parking at this site due to a shortage of spaces. Tamworth is on the proposed route of HS2, and the published route maps show the line removing the HGV parking area at the site. Hilton Park is particularly constrained in terms of the number of spaces as is Watford Gap. Watford Gap is approximately 30 minutes travel time from Corley and not in the correct position for drivers to take their break at the optimal location in respect of driving time (see Appendix 4). The M6 toll road is not as heavily trafficked as the M6 motorway. The average daily traffic reported for April to June 2017 was 49,700 vehicles, with ‘commercial’ traffic at 6,193 vehicles (commercial traffic being all vans, coaches and HGVs)5. This is the total usage of the toll road (2 way flow figures). By comparison, the 2016 average daily flow on the north bound M6 only (immediately west of Corley MSA) was 63,962. The peak daily flow was 79,702 vehicles (northbound only). As an average figure, the number of vehicles exceeding 6.6m was 24.1% or 15,414 vehicles daily. In the peak month, larger vehicles were 26.4% of all traffic6. Significantly more commercial vehicles use the main M6 rather than the toll road as a result of the charges for HGVs, which are currently £11 for 06:00 to 23:00 and £8.60 for 23:00 to 06:00. As a result, HGVs generally do not stop at Norton Canes MSA because they do not use the toll road.

6.36 Planning permission was approved in November 2017 for a new MSA at Rugby (Junction 1, M6). This is approximately 14 miles to the east of Corley MSA. Circular 02/2013 set out that the

5 Source: https://www.m6toll.co.uk/about-us/traffic-figures/latest-reports/april-june-2017/ 6 Source: http://webtris.highwaysengland.co.uk/

Smith Jenkins 20 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

minimum requirement for HGV spaces at this site was 88 spaces. The applicant’s Transport Assessment surveyed layby parking in the vicinity of the site. It concluded that there was significant use of the laybys in the vicinity of the proposed Rugby MSA site by HGVs. The TA also referred to the 2011 Department for Transport Lorry Parking Study, as follows:

The survey revealed the existing laybys are well used and there is significant parking overnight of vehicles on the industrial estate roads such as Central Park Drive and Castle Mound Way situated off the A426 to the south of Junction 1. This endorsed the findings of the Department of Transport’s Lorry Parking Study published in November 2011. Chapter 4 dealing with the Regional Analysis states Rugby is located in the ‘West Midlands’ region and the ‘key facts’ for the region identified there was significant ‘off site’ parking at Rugby. Of the 30 local authority areas in the Region, Rugby displayed the greatest demand for spaces at around 300 with around 220 provided ‘on site’ spaces leaving the remainder dependent on lay-bys and on-street parking.

6.37 The 2011 Study sets out that there was a specific need for 80 spaces at Rugby to meet existing demand. This is likely to have increased in line with HGV road usage. The provision of additional spaces at Rugby MSA is therefore likely to meet the need arising specifically at Rugby and not meet the need that is also present at Corley. Therefore the construction of a new MSA at Rugby is unlikely to make any difference to the parking requirement at Corley.

6.38 Either in the existing Core Strategy or the emerging Local Plan for North Warwickshire there is no provision for additional HGV parking in the locality. The Appellant is not aware of any extant planning permissions that would provide alternative HGV parking to meet the need outlined at Corley. There are however significant levels of new employment land allocated in the emerging Local Plan. The West Midlands more generally has a strong history of attracting logistics based companies as a result of the location in the middle of the country, along with the confluence of motorways, rail and airport that all bring goods into and through the area. The construction of HS2, the development of ‘UK Central’ (around junction 6, M42, Birmingham airport and the HS2 interchange) and other proposals for the Birmingham area are likely to involve a significant increase in the amount of HGVs in the area during the course of construction, as well as the on- going servicing of all these facilities.

6.39 As acknowledged by Members at the Planning Board on 6th November, there is no North Warwickshire strategy for the management of HGVs. The need for HGV parking at Corley MSA is clearly a feature of the need for HGV parking more generally, and specifically the location of the site in respect of the SRN. This results in drivers wanting to stop at Corley either as a result of the location of the site on their route; the location of the site before Birmingham (where there is often traffic congestion and therefore delay in reaching the next MSA); the proximity of the site to the motorway, and the ability to access parking without deviating from the motorway; the distance of the site almost exactly 4.5 hours from the main UK ports to the east; and because of the availability of facilities at Corley in terms of driver welfare, fuel and secure parking.

6.40 It is all of these matters that result in Corley being the preferred location for drivers to stop, which results in the need for additional spaces to be meet the requirement. Drivers legally have to stop and take a break. These breaks are enforced as a matter of highway safety. Motorway Service Areas are designed to fulfil a highway safety function. By providing sufficient, safe space for HGVs to stop and for drivers to rest, the site is able to fully fulfil this function. More space at Corley is also likely to prevent HGV drivers seeking space to park in unofficial areas, such as at Coleshill which is often reported as causing residential amenity issues on a wide scale.

Smith Jenkins 21 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

Other Harm

6.41 The ‘other harm’ that might occur as a result of the development relates to traffic, archaeology, flooding, ecology, landscape, noise and the impact on residential amenity. These matters are covered at length in the Officer’s report to the Planning Board (as contained in Appendix 10). The Appellant does not disagree with the Officer’s assessment of each of these areas of harm. In summary, there is no harm caused more generally in respect of traffic. The HGVs using the facility are already using the SRN and therefore the development will not result in an increase in traffic generally. This is agreed by both Warwickshire County Council as Highway Authority and Highways England.

6.42 In terms of archaeology, the County Archaeologist agrees with the findings of the Appellant’s initial archaeological surveys. Any harm causes is likely to be limited. Likewise, any impact on nearby heritage assets is limited. In accordance with Paragraph 134 of the NPPF, where a development causes less than substantial harm, this harm should be weighed against the public benefits of the proposal. In this case, the public benefit is the provision of safe parking for HGVs which forms a significant highway safety benefit. The Appellant considers that this significant public benefit outweighs the very limited harm caused as a result of the development.

6.43 In respect of flooding and drainage, the proposal is accompanied by a drainage strategy which is agreed with the Lead Local Flood Authority. It is agreed that any surface water runoff from the site can be discharged at a green field run off rate and that as a result of the development, there would be no harm caused in respect of flooding.

6.44 The County Wildlife Officer requested that the Appellant provide a positive calculation in respect of biodiversity. This has been done as a result of migratory planting proposed on land also owned by Welcome Break. The site has minimal ecological value – the majority of the value lies within the hedgerows which are to be retained and expanded as part of the landscape proposals for the site. There are no protected species on the site.

6.45 Landscaping has been discussed at length in respect of the impact of the scheme on the openness of the Green Belt above, however the harm caused in landscape terms is limited, as set out in the accompanying Landscape and Visual Impact Assessment. The harm is limited to views into the site from within 300 metres of the boundary and any impact from within this zone is minor/negligible. Within 15 years as a result of planting, this is likely to remain as negligible or improve. The development is adjacent to the existing MSA, M6 motorway and the powerlines that cross the site, all seen as being major urbanising elements and significant detractors.

6.46 The accompanying noise report sets out that the noise levels as a result of the development fall within the WHO’s guidelines. In part this is as a result of the background noise levels at the site. It was agreed with the Council’s Environmental Health department to provide an acoustic fence between the houses of Bennetts Road North and the site. There was no objection as a result. Any harm therefore is determined to be limited and is able to be mitigated. Officer’s determined that any harm to residential amenity as a result of light, or noise was low, and that sufficient mitigation could be provided. Discussions between the Appellant and Members of the Council’s Planning Board resulted in additional planting, including a hedge and fence behind the properties which back onto the adjacent field north of Bennetts Road North. This additional planting is shown on the plan submitted to the Council on 23rd October (Appendix 5).

Smith Jenkins 22 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

Other Considerations

6.47 The planning application was subject to around 20 objections from local residents and the Parish Council. The Appellant understands that these objections were local to the site. The application was supported by the Road Haulage Association, and acknowledged by Highways England as meeting the need for additional parking at the site.

6.48 The objections related mainly to the impact on residential amenity and also the lack of need for the extension. Objectors put forward alternative arrangements within the existing MSA that they considered would provide additional parking without utilising the appeal site. These have been addressed at length in the Planning Statement and also correspondence included within the Appendices to this Statement. The re-arrangement of the existing site has been considered by the Appellant but simply re-arranging the existing HGV parking area or swapping the HGV and car parks on the site would not generate sufficient parking to meet the need (in fact swapping the HGV and car parks would reduce the number of spaces to around 48).

6.49 Objectors have also stated that any need would be met by the new Rugby MSA but as demonstrated here, the provision of additional spaces at Rugby will meet an identified need within Rugby itself, and not the additional need specific to Corley MSA. They have also suggested that a site should be found elsewhere to accommodate HGV parking, however no site has been identified and the Council have no strategic plan for HGV parking. No provision is made in the emerging Local Plan. Another site could quite possibly be in the Green Belt or would result in Green Belt release next to an existing industrial area. Any harm is likely to be similar in terms of the harm caused to the purpose of the Green Belt as a result. However, the harm is likely to be greater than that caused by providing HGV parking adjacent to an existing MSA. Facilities for drivers are already provided at Corley MSA. These include showers, toilets, catering facilities and fuel. If a site were to be provided elsewhere, these facilities would need to be duplicated. The proposal subject to this appeal uses a minimal amount of land because facilities can be shared and therefore it is only the parking area that needs to be provided. This is a positive benefit of the development and should be considered alongside the other positive benefits of this scheme.

Summary

6.50 The appeal site is located within the Green Belt where development is inappropriate unless it is included within Paragraph 89 or 90 of the NPPF. In this case, the proposed development is not included in those lists, and therefore it is deemed to be ‘inappropriate development’. The National Planning Policy Framework sets out that substantial weight is to be given to the harm caused to the Green Belt as a result of inappropriate development. Very special circumstances to overcome the presumption against inappropriate development will only exist unless the potential harm and any other harm is clearly outweighed by other considerations.

6.51 The appeal proposes the creation of 83 HGV spaces adjacent to the existing Motorway Service Area (MSA) at Corley northbound MSA. MSAs provide a highway safety function, through the provision of a safe place to stop and rest for all drivers when travelling on the strategic road network (SRN). Corley MSA experiences significant difficulties in fulfilling this function as a result of high volumes of HGVs that use the site. HGVs use the site because it is located at a critical junction on the SRN; it is easily accessible from the SRN; there are a lack of alternative facilities in the locality; and there are high numbers (and increasing numbers) of HGVs using the SRN

Smith Jenkins 23 Appeal Statement: Corley Motorway Service Area, M6 Motorway, North Warwickshire

which require parking. Corley MSA provides high quality facilities for drivers that are rated highly. Hauliers are increasingly concerned about the safety of their drivers and cargo, and require a secure place to stop, particularly overnight.

6.52 High volumes of HGVs stop at the site both during the day and at night to take the short and long rest breaks required by drivers by Law. The site is constrained both in terms of the numbers of HGVs that can stop, but also the size of vehicles. This has led to unauthorised parking around the site, which causes a road safety hazard. It has also been demonstrated that a significant number of vehicles enter the site in search of a parking space, and unable to park, leave. The Appellant cannot be sure of where these vehicles then park but it is likely to either be on the hard shoulder of the motorway or off the motorway at the next junction, in unofficial or unauthorised parking areas. Parking in this way is unsafe, and causes a road safety hazard.

6.53 The proposed development would cause harm to the Green Belt by definition. The purpose of the Green Belt against which there would be a genuine conflict would be purpose 3, encroachment into the countryside. However, the site suffers from significant urbanising influences which significantly detract from the site. This also impacts on openness. The site has little value in terms of visual impact and openness. Planning Officers concluded that any harm caused by the development would be ‘moderate’, and the Appellant agrees that harm would be limited and highly localised.

6.54 There are very special circumstances in this case in respect of the need for the development and a lack of alternative sites. There is also significant development in the locality that will require additional HGV parking, while one of the alternatives (Tamworth MSA) is likely to be demolished to make way for HS2. The Appellant considers that these very special circumstances are substantial, and outweigh the moderate or limited and localised harm caused to the Green Belt as a result. The Appellant also considers that due to the specific need that is being met, if this appeal is allowed then it is unlikely to put pressure on surrounding land because a) this still fulfils a Green Belt function and b) any development would have to demonstrate a need to be located in the Green Belt and would be subject to the normal Development Management considerations.

6.55 We therefore respectfully request that the appeal is allowed. If the Inspector decides to allow that appeal, the conditions put forward by the LPA in reports to Committee of 9th October and 6th November are common ground between the LPA and Appellant.

Smith Jenkins 24

Appendix 1 Decision Notice

Appendix 2 Pre-Application Discussions

30A High Street, Stony Stratford, Milton Keynes, MK11 1AF Telephone: 01908 502436 Email: [email protected]

October 2016

Development Control North Warwickshire Borough Council South Street Atherstone Warwickshire CV9 1DE

Private and Confidential

Dear Sir

Request for Pre-Application Discussions Extension to HGV Parking Area Corley Motorway Service Area, Smorrall Lane, Corley CV7 8NR

We act on behalf of Welcome Break Holdings Ltd.

Welcome Break operate the Motorway Service Area (MSA) at Corley on both sides of the motorway.

Along with this letter, we are submitting the following information in order to facilitate pre- application discussions with the Council:

 Application forms, duly completed;  Site location plan;  Proposed layout plan (indicative);  Aerial photograph of existing HGV park;  Data setting out occupancy data of HGV park (September 2015-August 2016);  Plan showing location of adjacent truck stops; and  Transport Focus – Take A Break, Road Users’ Views About Roadside Facilities.

Corley Motorway Service Area (MSA) is located between junctions 3 and 3A/4 of the M6. It is an ‘online’ MSA and is accessed directly via dedicated slip roads from the motorway. Services are located both north and south of the motorway, and are linked by a pedestrian bridge over the motorway. They provide a variety of facilities for drivers using the motorway. The purpose of an MSA is to provide drivers with an opportunity to stop and rest. The Government’s policy on MSAs is set out in Circular 02/2013, The Strategic Road Network and the Delivery of Sustainable Development.

The MSA serves recreational, business and commercial drivers, including provision for coach parking and HGVs. Circular 02/2013 sets out the minimum requirements for signing of MSAs from the strategic road network. Table B1 sets out that the minimum requirement is for shower and washing facilities for HGV drivers. Schedule 1 of the Circular includes the parking requirements for MSAs.

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

Parking requirements are normally based on the peak monthly flow of traffic for the opening year of the MSA. If there is a major development at the MSA, Highways England would also require parking on the site to be increased.

There have been a number of proposals for minor development at the MSA in the last 2 years, including extension to the amenity building to provide enhanced wash room facilities and the provision of a Starbucks Drive Thru. The fuel filling station has also been refurbished.

All of these developments have formed part of the on-going investment and commitment that Welcome Break have to this site, and supporting local jobs.

In 2008, Welcome Break applied for planning permission to extend the HGV parking area from the current provision of 60 spaces to provide a further 75 spaces in an area of paddock to the south of the main MSA site (planning application reference PAP/2008/0658). The proposed description of development as set out on the decision notice was:

“Proposed extension to Motorway Service Area to create additional HGV parking facilities including amenity block and associated landscape proposals.”

Planning permission was refused for three reasons, namely:

1. The site is within the designated West Midlands Green Belt. The proposals constitute inappropriate development with the Green Belt, as defined within Planning Policy Guidance Note 2 Green Belts. The proposals will cause significant harm to the Green Belt due to the inappropriate nature of the development; it will reduce the openness and will be injurious to the visual amenities of the Green Belt. The proposal is not in accord with the land use objectives identified for the appropriate use of land within the Green Belt. Guidance is clear that inappropriate development should not be approved except in very special circumstances. The need to substantial additional lorry park facilities and the proposed location adjacent to the existing service area are put forward as very special circumstances. The existing provision of parking for northbound HGVs at the Corley Motorway Services appears to be consistent with the level of provision indicated in national guidance issued relevant to the provision of such services. The applicants forecast of the growth in the number of HGVs is inconsistent with the forecast within the National Transport Model Road Transport Forecasts 2008. The need for substantial additional provision is thus considered to be questionable. Existing lorry park facilities within an appropriate distance of Corley appear to have been omitted from consideration, both in terms of the existing capacity and as possible alternative locations. Very special circumstances that would justify the grant of planning permission are not considered to exist with regard to the development proposed. The proposal is therefore contrary to policies CP4 & ENV2 of the North Warwickshire Local Plan 2006.

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

the improved measures. The proposal is thus considered to be contrary to Policies CP2, CP11 and ENV11 of the North Warwickshire Local Plan 2006.

Current Proposal

At this stage, Welcome Break would like to discuss the principle of development with the LPA concerning additional HGV parking at Corley MSA. There is a pressing need for this development (discussed in more detail below) which has triggered the company to re-assess the requirement for parking across the site. The current HGV parking area accommodates 60 HGVs or any other vehicle which is larger than a standard car or small van that would otherwise park in the main car park.

At this stage, we have enclosed the plans that were considered in 2008 however these are for discussion only, and we hope that by discussing them with you, we will achieve a development that meets the needs of HGV drivers but also is agreeable to you. These plans form the starting point for a discussion about what could be achieved.

The plans show a new HGV park located to the south east of the existing MSA boundary. This area is owned by Welcome Break. It is used as paddock land. This area is seen as an area most suitable for the provision of additional parking, partly in respect of the geography of the site and also in relation to the practical working of the MSA. The use of a long thin strip of land also reduces the encroachment of the site into the countryside, and contains development against the current MSA boundary. HGVs entering the site would be directed into this area, which if full, could then move onto the existing HGV parking area to find space. Drivers are more likely to find a space using directional signage and within the existing one-way operation of the MSA.

The plans show 75 additional spaces in mainly echelon parking arrangement. The tracking diagram shows that this allows vehicles to navigate around the site easily.

The proposal would be suitably landscaped, including the provision of an acoustic fence. Lighting would be provided at as low a level as practicable given the HGV use to ensure that light spill would be reduced to the surrounding area (if we proceeded to a planning application, the application would be accompanied by a lighting plan including lux levels). A planning application would be accompanied by a Road Safety Audit, thereby dealing with the third reason for refusal on the 2008 application.

Welcome Break are also suggesting that the scheme would be subject to a management arrangement, which could be a condition on a planning permission. This would allow for active management of the HGV park. It would only be open at times of peak demand and not at all at weekends (when the historic data suggests that the existing HGV parking area has capacity for vehicles). This would provide reduce any impact on local residents that might occur from HGV movements.

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

Planning Policy

The site is located within the West Midlands Green Belt. The previous application was considered against PPG2, which has now been replaced by the NPPF (March 2012), however the NPPF does not change the Government’s policy on Green Belts, and in many places the NPPF simply repeats the provisions of PPG2. Decisions in the Courts have determined that the relevant paragraphs should be read with the same emphasis and interpretation as the previous guidance.

Paragraphs 87 and 88 state:

87. As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.

88. When considering any planning applications, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.

‘Need’ is considered to be a very special circumstance.

Consideration of these proposals

When presenting the 2008 planning application, consultants on behalf of Welcome Break presented data to the LPA setting out the levels of occupancy at the site which they stated represented a need for additional HGV parking at the site. The accompanying Transport Statement set out that average overnight occupancy at the MSA for the preceding four years had been 105% (2007), 115% (2006), 121% (2005) and 111% (2004).

This situation of over occupation of the site has persisted since 2008.

Data collected by Welcome Break for the 2 years preceding August 2016 show that the site is consistently over occupied by HGVs. The annual average weekday occupancy from September 2015 to August 2016 was 118%. This figure does not take into account seasonal variations in parking. This data is obtained from HGV drivers paying to stay overnight at the site. It will not record those that park on the slip road, or those who have not paid and are subsequently fined.

The figures are therefore likely to under represent the actual levels of occupancy and therefore demand for spaces at Corley MSA.

The table below (Table 1) sets out the average occupancy (weekday) for the site:

Month Average Occupancy (%) September 2015 127% October 2015 132% November 2015 134% December 2015 101% January 2016 110% February 2016 116% March 2016 113% April 2016 118% May 2016 119%

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

June 2016 125% July 2016 114% August 2016 108% Table 1: MSA average weekday occupancy

Table 2 (below) shows the number of week days in each month when the HGV park is over 100% capacity:

Month No of Week Days Days at 100% Capacity Days at 80% Capacity September 2015 22 21 (95%) 22 (100%) October 2015 22 18 (82%) 21 (95%) November 2015 21 19 (90%) 20 (95%) December 2015 23 13 (56%) 18 (78%) January 2016 21 17 (81%) 18 (86%) February 2016 21 15 (71%) 19 (90%) March 2016 23 18 (78%) 20 (78%) April 2016 22 18 (82%) 19 (86%) May 2016 22 15 (68%) 19 (86%) June 2016 22 20 (91%) 22 (100%) July 2016 21 16 (76%) 20 (95%) August 2016 23 18 (78%) 19 (83%) Table 2: Weekday occupancy

We attach the raw data upon which this analysis is based. This shows clearly the large volumes of HGVs that are recorded paying to park and use the facilities at the site.

Welcome Break’s figures are for overnight occupancy of the HGV park based on those vehicles that have paid to park. These include account holders and those vehicles that turn up, park and pay. This is likely to under present the ‘need’ for spaces. The number of vehicles requiring parking is likely to be suppressed due to the lack of space at the MSA. If a HGV leaves the M6 to find a space and is unable to park, the driver will need to re-join the motorway and find alternative parking. In recent months this has resulted in vehicles parking on the hard shoulder on the exit slip road to the MSA. This is a hazard but those vehicles are not captured in the above parking numbers because they are outside of the MSA, and are not required to pay to park their vehicles.

Other issues arise from HGVs parking in spaces other than the designated HGV area. The attached aerial photograph taken in the summer of 2016 shows the HGV park being substantially full. Drivers have sought out other areas to park in the site including on the exit road to the MSA (but within the site) and also within the caravan and coach park. There are safety issues associated with mixing these uses but HGV parking outside of the designated HGV park reduces the spaces available to other road users.

It is clear from the photograph that there are circa 56 vehicles parked in the HGV park itself, with a further 10 HGVs parked on the side of the road, and in the coach and caravan parks. In addition to safety issues, the parking of HGVs in these locations causes considerable damage to the site. HGVs are regularly found parking on the kerbs and in landscaped areas, all causing damage to the environment of the MSA.

Circular 02/2013 (Schedule 1) sets out parking requirement for the site based on main line traffic flows. At the time of preparing this letter, the most up to date AADT information was not available

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

from Highways England. We understand that the recording loops on the M6 do not work. We will send this to you as soon as it is available.

The current number of spaces on the site is 60. The average weekday occupancy is 118% on the basis of the data we have available. This is likely to understate the actual need for HGV spaces.

In considering the 2008 planning application, the Council determined that the applicant’s requirement for spaces did not consider the National Transport Model Road Transport Forecasts for growth in HGV traffic. The 2015 Report (March 2015) is the most up to date version of this report. This report looks at 5 potential growth scenarios for HGV traffic from 2010 to 2040. It forecasts growth in traffic on the strategic road network of between 29% and 60% upto 2040.

When looking at types of traffic, light goods vehicles are forecast to grow by a minimum of 42% and as much as 115% to 2040. HGV growth is expected to be somewhere between flat growth and 58% to 2040. It is important to consider growth of both LGV and HGV vehicles – but under either scenario it is anticipated that there will be growth in both sectors to 2040.

I also attach for your information, research produced in July 2016 by Transport Focus – Take A Break, Road Users’ Views About Roadside Facilities. This provides a helpful summary on the behaviour of HGV drivers: roadside facilities are of greater significance to lorry drivers because they are legally required to stop driving after a certain number of hours. Their compliance with the law is monitored and when their driving time is up they have to stop and rest, or face prosecution. This means they try and plan their stops in advance, but are forced to change their plans according to traffic, lack of parking spaces or hold ups on the road.

This research confirmed a key concern of the industry is inadequacy of parking capacity for lorries which can lead to lorries stopping in unsuitable places. The Report recommends that Highways England develops a strategy, working with local authorities, to ensure there is sufficient capacity for lorries to park in the right places and with facilities to meet drivers’ needs.

The very high levels of occupancy at Corley MSA suggests that drivers consider that Corley is the right place to stop. We enclose a plan showing the relevant nearest HGV/truck stops. Looking at these, the closest is 11 miles from Corley, but involves HGVs leaving the strategic road network and finding the stop. Corley is a convenient place to stop for drivers.

The high demand for HGV parking at Corley is probably a result of a number of factors:

 It is easily accessible from the motorway and does not cause drivers to divert from the SRN to find space to stop;  Driving through Birmingham on the M6, most HGVs use the M6 rather than the toll road due to the cost of the toll. There are no truck parks in Birmingham, and the next easy location to stop is at Hilton Park, some 33 miles to the north. Hilton Park MSA has less than 40 HGV spaces. The low number of spaces at Hilton Park, and the distance to the next available stop may result in drivers stopping before they travel through Birmingham, rather than risking getting to Hilton Park at the limit of their legal drive time, and then being unable to stop due to a lack of capacity;  HGV drivers generally plan their stops in advance however, traffic congestion may change those plans. Advance driver information notification boards on the M6 will inform drivers about traffic delays on the M6. If drivers are unable to stop within their required times (see below), they are likely to divert to Corley in the knowledge that they are able to stop within the legal limits.

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

The Law requires commercial drivers to break regularly. The requirement is to break for at least 30 minutes after driving 5 hours and 30 minutes, or 45 minutes within any 8 hour and 30 minute period.

The parking numbers provided in this letter in respect of vehicles stopping at Corley relate to those that have paid to park at the MSA (their stop being over 2 hours, and therefore part of their ‘over night’ stop – although that may not be at night time).

It is for these reasons that Corley is at an important location on the M6 for HGVs to stop and rest. It is regularly the case that the HGV park is full, and drivers try to find alternative locations around the site but also on the slip roads to the motorway. Welcome Break have a pressing need to find somewhere to park these drivers. They have explored the possibility of re-arranging the existing HGV park however this does not deliver sufficient spaces to meet the need. We are therefore looking to the enclosed site as a solution.

There are a number of options for this site:

 To actively manage the parking area, and only have it open at peak demand times. Reviewing the data, this may mean not having it open at all at weekends, unless the existing HGV park was at capacity;  To approve a phased extension to the HGV park based on monitoring of the demand and need for spaces within the wider site. If key trigger points are met in terms of traffic flows (measured via AADT data or occupation) then this may allow the release of a further phase of development for example.

We would like to discuss these with you. There is a national problem with HGV parking. Having discussed this with Highways England at a strategic level, they are aware that there is a shortage and want operators to actively provide solutions through extensions of sites like Corley. Corley offers a number of advantages as set out here.

Conclusions

HGV parking at Corley MSA is consistently in excess of the 60 number spaces provided for these vehicles. This is leading to HGVs parking unsafely within the MSA, causing damage to the environment, but also to HGVs parking on the exit slip road hard shoulder to the MSA. The average weekday occupancy for 2015/16 not allowing for seasonal adjustments was 118%. This average occupancy is likely to suppress actual demand for spaces.

The National Transport Model Road Forecasts for 2015 also predict growth in HGV vehicles to 2040 of upto 58%. National surveys have also addressed the issue of the shortage of HGV parking.

To meet that need, Welcome Break are proposing an extension to the site to provide upto 75 spaces – either to be constructed in one or two phases with suitable management arrangements to be put in place.

It is the actual and compelling need at Corley for HGV parking that we argue would amount to the very special circumstances that would allow permission to be granted for development in this location.

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

Welcome Break wish to submit a planning application for an extension to the MSA to provide these HGV spaces, and the accompanying plans provide a starting point for finding a solution to a very real and pressing problem. We note the issues raised previously by Environmental Health in respect of noise and light, and would hope that through discussion we could determine an appropriate design that would ameliorate those concerns.

I would be grateful if you could confirm receipt of this information, and confirm who the planning officer is who will deal with this matter. We look forward to meeting with you soon to discuss this matter.

In the meantime, if you have any questions, please do not hesitate to contact me.

Yours faithfully

Jennifer Smith MRTPI Director

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

SPECIMEN TREES

Norway maple Acer platanoides 18-20cmg Silver birch Betula pendula 18-20cmg English oak Quercus robur 18-20cmg Plants as solitary specimens double stubTCBs staked with crossbar in specially prepared pits to area M. Station to be ﬁtted with irrigation, drainage and pest protection. Fit strimmer guards when installed in grass. TCB (RAC) A1 M6 Motorway WOODLAND Trees approx. 20% of total plants, shrubs approx. 80% of total plants. Mast

Silver birch Betula pendulaLB 1+1 40-60 BR 15% English oak** Quercus robur 1+1 40-60 BR 5% Field maple** Acer campestre 1+1 40-60 BR 5% DogwoodTCBs Cornus sanguinea 1+1 40-60 BR 5% Hawthorn** Crataegus monogyna 1+1 40-60 BR 30% A1 1901 Broom* Cytissus scoparius 3L CG 5% MH 115.88 CL CONFIRMED) 113.94 IL BE Holly** IlexPlay aquifolium 3L CG 10% (TO Goat willow Salix capraea 0/1 40-60 BR 10% Area Woodland plants to be planted generally on a 2m square grid. Plants in species groups of Section A2 5-10. Each plant to be pit planted with 3kg compost and provided with individual pest protection as necessary and appropriate to species. (* denotes woodland edge species.) (** denotes hedging species planted at 4/Lm). H3 C B

225Ø AQUATIC AND MARGINAL SPECIES Service Area A Brooklime Veronica beccabunga BR Giant reedmace Typha latifolia BR Yellow ﬂag Iris pseudacorus BR J1 MH Common sedge Carex nigra BR Purple loosestrife Lythium salicaria BR El A1 PRoW M327 SEEDING MIX Sub British Seed Houses A4 Mix, to amenity areas. British Seed Houses A25Sta Mix, Meadow Ley, to wider landscape areas. British Seed Houses GS 5, 7, 11 Mixes to wetland areas. G F

L B2b PRoW M330

BE 1801 (TO B2a MH 116.03 CL 114.88 IL M1 CONFIRMED) M2

ARTIC (UK) 9 8 FTA B J2 PRoW M327

COMBINED

FMH1 225Ø

EXISTING

FTA ARTIC

9 8 (UK)

(UK) ARTIC 9 8 Path (um) FTA PRoW M327 M1 H LANDSCAPE PATTERN 1802 MH A2 B1 Locally the landscape pattern is typical of the 'Ancient LC Arden' landscape described in the Warwickshire

FTA Landscape Guidelines, with small, strongly enclosed ARTIC

9 8

(UK) grazing meadows (H1, H2, H3) and occasional larger, ARTIC (UK) FTA 9 8 Acoustic fencing 20.0m more open arable ﬁelds (H4). Field boundaries are COMBINED predominantly hedged, with some gaps, and hawthorn D2 225Ø ARTIC FTA 9 8 (UK) EXISTING and holly the predominant species. 150Ø

(UK) K WOODLAND PLANTING ARTIC N A 9 8 FTA New woodland plnating, incorporating a woodland edge mix rich in holly and oak to reﬂect local vegetation (UK) ARTIC 9 8 FTA composition. Woodland is set in from the existing hedge Section to allow deﬁnition and access for continued hedgerow

0701 MH J3 maintenance. Levels are raised in this area to assist Section screening. Acoustic fencing B J HEDGEROWS J5 The existing hedgerows, with mature hedgerow trees around the site are retained, with small gaps ﬁlled in SEWER

H1 COMBINED where these occur, to provide maximum screening effect 225Ø EXISTING H4 and ecological connectivity. Hedgerow trees, especially D1 English oak, are introduced and less appropriate species, H2 such as poplar, removed. At J1 the existing overgrown hawthorn hedge is laid in the Midlands manner. L SUDS + WET WOODLAND At the northern, lower lying end of the site the existing hedge is supplemented with damp woodland planting including a high proportion of willows. The woodland has J5 a 'ragged' southern edge to encourage wildlife and a new 9701 MH SUDS wetland basin is provided. J4 M INTERMEDIATE PLANTING G Existing blocks of birch and thorn woodland are retained, 225Ø with removal to admit access road and Amenity Building. New tree and shrub planting, with some specimen trees (M1 and M2) for 'instant' effect and a thicker understorey, ﬁlls gaps to provide visual separation between lorry park and road, and a setting for the public footpath M327.

6904 MH

Allandale Highcote Thorn 225Ø N EARTHWORKS Noise bunds with fencing are provided and planted along the southern and south western boundaries to further Apollo reduce visual impact. C Cedar

Croft Elspeth

Grove

Farm 120.6m

Rocksight LB Berry

TCB Holling Clovelly Ashleigh Ashcroft

Coombe Haven

Peace

Metlaw PRoW M327 Cambria

Dovedale Amberley Aylesmere

Kirkstone A MOTORWAY SERVICE AREA Deansway The existing MSA and parking areas lie to the south of the M6 Motorway, at around 120mAOD, and are strongly screened with belts of tree and shrub planting, including hawthorn, birch and scots pine especially on northern side (A1). Extensive areas of amenity grass and some well-established specimen tree planting provide screening along the southern side (A2). Penrith Bungalow REVISIONS: B PROPOSED EXTENSION View Rook A 5 November 2008/ds. Acoustic fencing and notation added. Section B added. The proposed lorry park lies to the southern side of the MSA, accessed via a combined entrance and exit. A new amenity B 17 November 2008/ds. Section B extended. Section C added. Planting to MSA island M2 added. block (B1) is proposed. Dedicated footway access to existing MSA is via pedestrian crossings (B2).

Holmﬁeld C SETTLEMENT NOTES: Buildings forming part of Corley village lie on Bennett's Road North, some 100m to the south of the site. Buildings mainly consist of two storey detached and semi-detached dwellings with some larger farm buildings towards the south east. 1. Based on THDA layout. THDA drawing 007-0340-104 REV J. 2. Contextural data from OS base shown indicatively only. 3. For details of fencing, lighting, levels and drainage please refer to appropriate THDA drawings. D TRANSMISSION LINES 4. Levels and slope gradients shown indicatively. A major electricity power line (D1), on pylons, and smaller local distribution line (D2) cross the site. 5. For Photolocations please see DSA 0752 003. 6. For sections Oakdenesee 0752 004, 0752 005. E PUBLIC RIGHTS OF WAY Several Warwickshire public rights of way lie close to the site. M327 skirts the southern boundary of the MSA and connects with M330 and M331 to the east. M328 connects M327 with Bennetts Road North to the west of the site. Cottage CORLEY SERVICESThe WESTBOUND F WATERCOURSE An existing ﬁeld ditch and stream drains the north eastern end of the site to the Breach Brook, a tributary of the River Sowe, beyond the M6. BUCKINGHAM LANDSCAPE PROPOSALS G SEWER GROUP An existing combined surface and foul water sewer runs south to north through the southern edge of the site, and underneath the M6 to the east of the MSA. drawn/checked date scale drawing number DS/ds NOVEMBER 2008 1:1000 @A2 0752 002 B DSA NOTTINGHAM Holly Farm Corley Motorway Service Area – HGV Parking Aerial Views 2016

Truck Stop Distances from Corley Motorway Service Area

List of Truck Stops

a. Lincoln Farm Truck Stop – 11.5 miles b. PJM Group Limited – 11.0 miles c. Rugby Truck Stop – 18.4 miles

Paid Parking Account Holders Total % Occupancy 01/08/2016 Monday 48 24 72 120.0 02/08/2016 Tuesday 36 26 62 103.3 03/08/2016 Wednesday 46 21 67 111.7 04/08/2016 Thursday 64 16 80 133.3 05/08/2016 Friday 23 19 42 70.0 06/08/2016 Saturday 43 11 54 90.0 07/08/2016 Sunday 31 13 44 73.3 08/08/2016 Monday 43 19 62 103.3 09/08/2016 Tuesday 46 21 67 111.7 10/08/2016 Wednesday 56 22 78 130.0 11/08/2016 Thursday 54 15 69 115.0 12/08/2016 Friday 22 15 37 61.7 13/08/2016 Saturday 28 10 38 63.3 14/08/2016 Sunday 21 6 27 45.0 15/08/2016 Monday 48 25 73 121.7 16/08/2016 Tuesday 58 18 76 126.7 17/08/2016 Wednesday 50 21 71 118.3 18/08/2016 Thursday 49 23 72 120.0 19/08/2016 Friday 35 23 58 96.7 20/08/2016 Saturday 33 6 39 65.0 21/08/2016 Sunday 14 4 18 30.0 22/08/2016 Monday 54 23 77 128.3 23/08/2016 Tuesday 50 20 70 116.7 24/08/2016 Wednesday 54 20 74 123.3 25/08/2016 Thursday 51 14 65 108.3 26/08/2016 Friday 28 8 36 60.0 27/08/2016 Saturday 11 11 22 36.7 28/08/2016 Sunday 20 6 26 43.3 29/08/2016 Monday 35 13 48 80.0 30/08/2016 Tuesday 52 19 71 118.3 31/08/2016 Wednesday 51 23 74 123.3 Paid Parking Account Holders Total % Occupancy 01/09/2015 Tuesday 46 43 89 148.3 02/09/2015 Wednesday 57 24 81 135.0 03/09/2015 Thursday 64 22 86 143.3 04/09/2015 Friday 48 26 74 123.3 05/09/2015 Saturday 32 1 33 55.0 06/09/2015 Sunday 23 2 25 41.7 07/09/2015 Monday 57 14 71 118.3 08/09/2015 Tuesday 43 20 63 105.0 09/09/2015 Wednesday 64 27 91 151.7 10/09/2015 Thursday 59 17 76 126.7 11/09/2015 Friday 44 17 61 101.7 12/09/2015 Saturday 38 7 45 75.0 13/09/2015 Sunday 28 6 34 56.7 14/09/2015 Monday 49 16 65 108.3 15/09/2015 Tuesday 52 26 78 130.0 16/09/2015 Wednesday 56 13 69 115.0 17/09/2015 Thursday 73 21 94 156.7 18/09/2015 Friday 43 19 62 103.3 19/09/2015 Saturday 55 12 67 111.7 20/09/2015 Sunday 25 2 27 45.0 21/09/2015 Monday 51 19 70 116.7 22/09/2015 Tuesday 62 28 90 150.0 23/09/2015 Wednesday 61 22 83 138.3 24/09/2015 Thursday 60 26 86 143.3 25/09/2015 Friday 40 19 59 98.3 26/09/2015 Saturday 39 6 45 75.0 27/09/2015 Sunday 40 4 44 73.3 28/09/2015 Monday 56 26 82 136.7 29/09/2015 Tuesday 58 17 75 125.0 30/09/2015 Wednesday 51 22 73 121.7 Paid Parking Account Holders Total % Occupancy 01/10/2015 Thursday 60 23 83 138.3 02/10/2015 Friday 26 17 43 71.7 03/10/2015 Saturday 48 6 54 90.0 04/10/2015 Sunday 27 6 33 55.0 05/10/2015 Monday 64 21 85 141.7 06/10/2015 Tuesday 64 24 88 146.7 07/10/2015 Wednesday 56 34 90 150.0 08/10/2015 Thursday 73 25 98 163.3 09/10/2015 Friday 28 30 58 96.7 10/10/2015 Saturday 29 8 37 61.7 11/10/2015 Sunday 33 11 44 73.3 12/10/2015 Monday 53 25 78 130.0 13/10/2015 Tuesday 43 21 64 106.7 14/10/2015 Wednesday 60 25 85 141.7 15/10/2015 Thursday 66 26 92 153.3 16/10/2015 Friday 47 12 59 98.3 17/10/2015 Saturday 36 7 43 71.7 18/10/2015 Sunday 33 4 37 61.7 19/10/2015 Monday 57 42 99 165.0 20/10/2015 Tuesday 50 33 83 138.3 21/10/2015 Wednesday 61 31 92 153.3 22/10/2015 Thursday 63 29 92 153.3 23/10/2015 Friday 41 17 58 96.7 24/10/2015 Saturday 32 13 45 75.0 25/10/2015 Sunday 38 9 47 78.3 26/10/2015 Monday 49 29 78 130.0 27/10/2015 Tuesday 67 19 86 143.3 28/10/2015 Wednesday 64 35 99 165.0 29/10/2015 Thursday 57 14 71 118.3 30/10/2015 Friday 43 26 69 115.0 31/10/2015 Saturday 36 10 46 76.7 Paid Parking Account Holders Total % Occupancy 01/11/2015 Sunday 35 8 43 71.7 02/11/2015 Monday 66 27 93 155.0 03/11/2015 Tuesday 58 28 86 143.3 04/11/2015 Wednesday 68 24 92 153.3 05/11/2015 Thursday 52 34 86 143.3 06/11/2015 Friday 37 20 57 95.0 07/11/2015 Saturday 33 10 43 71.7 08/11/2015 Sunday 28 8 36 60.0 09/11/2015 Monday 49 25 74 123.3 10/11/2015 Tuesday 56 24 80 133.3 11/11/2015 Wednesday 58 30 88 146.7 12/11/2015 Thursday 75 18 93 155.0 13/11/2015 Friday 47 26 73 121.7 14/11/2015 Saturday 44 9 53 88.3 15/11/2015 Sunday 28 3 31 51.7 16/11/2015 Monday 50 28 78 130.0 17/11/2015 Tuesday 59 21 80 133.3 18/11/2015 Wednesday 56 20 76 126.7 19/11/2015 Thursday 64 21 85 141.7 20/11/2015 Friday 51 21 72 120.0 21/11/2015 Saturday 54 13 67 111.7 22/11/2015 Sunday 25 6 31 51.7 23/11/2015 Monday 61 32 93 155.0 24/11/2015 Tuesday 45 25 70 116.7 25/11/2015 Wednesday 59 25 84 140.0 26/11/2015 Thursday 67 24 91 151.7 27/11/2015 Friday 26 21 47 78.3 28/11/2015 Saturday 26 12 38 63.3 29/11/2015 Sunday 24 5 29 48.3 30/11/2015 Monday 66 29 95 158.3 Paid Parking Account Holders Total % Occupancy 01/12/2015 Tuesday 57 17 74 123.3 02/12/2015 Wednesday 63 33 96 160.0 03/12/2015 Thursday 63 27 90 150.0 04/12/2015 Friday 45 20 65 108.3 05/12/2015 Saturday 62 6 68 113.3 06/12/2015 Sunday 20 6 26 43.3 07/12/2015 Monday 57 24 81 135.0 08/12/2015 Tuesday 55 16 71 118.3 09/12/2015 Wednesday 64 28 92 153.3 10/12/2015 Thursday 57 23 80 133.3 11/12/2015 Friday 35 24 59 98.3 12/12/2015 Saturday 36 6 42 70.0 13/12/2015 Sunday 28 9 37 61.7 14/12/2015 Monday 54 21 75 125.0 15/12/2015 Tuesday 74 21 95 158.3 16/12/2015 Wednesday 52 16 68 113.3 17/12/2015 Thursday 60 7 67 111.7 18/12/2015 Friday 32 22 54 90.0 19/12/2015 Saturday 37 9 46 76.7 20/12/2015 Sunday 30 11 41 68.3 21/12/2015 Monday 56 23 79 131.7 22/12/2015 Tuesday 39 14 53 88.3 23/12/2015 Wednesday 34 16 50 83.3 24/12/2015 Thursday 2 3 5 8.3 25/12/2015 Friday 0 0.0 26/12/2015 Saturday 4 2 6 10.0 27/12/2015 Sunday 15 6 21 35.0 28/12/2015 Monday 7 10 17 28.3 29/12/2015 Tuesday 29 25 54 90.0 30/12/2015 Wednesday 28 20 48 80.0 31/12/2015 Thursday 17 9 26 43.3 Paid Parking Account Holders Total % Occupancy 01/01/2016 Friday 10 5 15 25.0 02/01/2016 Saturday 16 5 21 35.0 03/01/2016 Sunday 15 2 17 28.3 04/01/2016 Monday 46 28 74 123.3 05/01/2016 Tuesday 45 18 63 105.0 06/01/2016 Wednesday 41 26 67 111.7 07/01/2016 Thursday 58 17 75 125.0 08/01/2016 Friday 22 19 41 68.3 09/01/2016 Saturday 23 12 35 58.3 10/01/2016 Sunday 28 5 33 55.0 11/01/2016 Monday 48 21 69 115.0 12/01/2016 Tuesday 58 19 77 128.3 13/01/2016 Wednesday 61 17 78 130.0 14/01/2016 Thursday 52 21 73 121.7 15/01/2016 Friday 22 15 37 61.7 16/01/2016 Saturday 45 9 54 90.0 17/01/2016 Sunday 29 4 33 55.0 18/01/2016 Monday 47 31 78 130.0 19/01/2016 Tuesday 53 21 74 123.3 20/01/2016 Wednesday 61 21 82 136.7 21/01/2016 Thursday 58 9 67 111.7 22/01/2016 Friday 31 19 50 83.3 23/01/2016 Saturday 53 6 59 98.3 24/01/2016 Sunday 25 6 31 51.7 25/01/2016 Monday 58 17 75 125.0 26/01/2016 Tuesday 48 22 70 116.7 27/01/2016 Wednesday 53 26 79 131.7 28/01/2016 Thursday 57 25 82 136.7 29/01/2016 Friday 40 21 61 101.7 30/01/2016 Saturday 36 7 43 71.7 31/01/2016 Sunday 18 11 29 48.3 Paid Parkin Account HoTotal % Occupancy 01/02/2016 Monday 48 43 91 151.7 02/02/2016 Tuesday 54 19 73 121.7 03/02/2016 Wednesday 47 23 70 116.7 04/02/2016 Thursday 60 16 76 126.7 05/02/2016 Friday 30 16 46 76.7 06/02/2016 Saturday 34 11 45 75.0 07/02/2016 Sunday 42 11 53 88.3 08/02/2016 Monday 37 15 52 86.7 09/02/2016 Tuesday 42 18 60 100.0 10/02/2016 Wednesday 54 22 76 126.7 11/02/2016 Thursday 58 25 83 138.3 12/02/2016 Friday 39 15 54 90.0 13/02/2016 Saturday 32 5 37 61.7 14/02/2016 Sunday 31 6 37 61.7 15/02/2016 Monday 50 16 66 110.0 16/02/2016 Tuesday 58 22 80 133.3 17/02/2016 Wednesday 63 18 81 135.0 18/02/2016 Thursday 65 17 82 136.7 19/02/2016 Friday 35 14 49 81.7 20/02/2016 Saturday 43 12 55 91.7 21/02/2016 Sunday 33 10 43 71.7 22/02/2016 Monday 55 23 78 130.0 23/02/2016 Tuesday 60 20 80 133.3 24/02/2016 Wednesday 62 16 78 130.0 25/02/2016 Thursday 64 19 83 138.3 26/02/2016 Friday 25 18 43 71.7 27/02/2016 Saturday 45 4 49 81.7 28/02/2016 Sunday 25 7 32 53.3 29/02/2016 Monday 44 26 70 116.7 Paid Parkin Account HoTotal % Occupancy 01/03/2016 Tuesday 61 23 84 140.0 02/03/2016 Wednesday 55 35 90 150.0 03/03/2016 Thursday 64 17 81 135.0 04/03/2016 Friday 33 27 60 100.0 05/03/2016 Saturday 50 10 60 100.0 06/03/2016 Sunday 21 7 28 46.7 07/03/2016 Monday 52 21 73 121.7 08/03/2016 Tuesday 52 26 78 130.0 09/03/2016 Wednesday 51 18 69 115.0 10/03/2016 Thursday 54 24 78 130.0 11/03/2016 Friday 44 22 66 110.0 12/03/2016 Saturday 44 9 53 88.3 13/03/2016 Sunday 26 6 32 53.3 14/03/2016 Monday 39 31 70 116.7 15/03/2016 Tuesday 47 17 64 106.7 16/03/2016 Wednesday 59 21 80 133.3 17/03/2016 Thursday 53 19 72 120.0 18/03/2016 Friday 28 20 48 80.0 19/03/2016 Saturday 59 10 69 115.0 20/03/2016 Sunday 34 9 43 71.7 21/03/2016 Monday 48 21 69 115.0 22/03/2016 Tuesday 47 25 72 120.0 23/03/2016 Wednesday 57 24 81 135.0 24/03/2016 Thursday 40 20 60 100.0 25/03/2016 Friday 13 13 26 43.3 26/03/2016 Saturday 27 3 30 50.0 27/03/2016 Sunday 14 7 21 35.0 28/03/2016 Monday 28 10 38 63.3 29/03/2016 Tuesday 47 26 73 121.7 30/03/2016 Wednesday 44 21 65 108.3 31/03/2016 Thursday 47 23 70 116.7 Paid Parking Account Holders Total % Occupancy 01/04/2016 Friday 19 12 31 51.7 02/04/2016 Saturday 37 14 51 85.0 03/04/2016 Sunday 28 12 40 66.7 04/04/2016 Monday 48 18 66 110.0 05/04/2016 Tuesday 61 17 78 130.0 06/04/2016 Wednesday 52 23 75 125.0 07/04/2016 Thursday 62 22 84 140.0 08/04/2016 Friday 41 15 56 93.3 09/04/2016 Saturday 42 13 55 91.7 10/04/2016 Sunday 39 7 46 76.7 11/04/2016 Monday 53 20 73 121.7 12/04/2016 Tuesday 54 18 72 120.0 13/04/2016 Wednesday 60 19 79 131.7 14/04/2016 Thursday 67 23 90 150.0 15/04/2016 Friday 42 19 61 101.7 16/04/2016 Saturday 44 11 55 91.7 17/04/2016 Sunday 26 5 31 51.7 18/04/2016 Monday 58 20 78 130.0 19/04/2016 Tuesday 42 27 69 115.0 20/04/2016 Wednesday 63 22 85 141.7 21/04/2016 Thursday 67 17 84 140.0 22/04/2016 Friday 26 16 42 70.0 23/04/2016 Saturday 44 5 49 81.7 24/04/2016 Sunday 29 7 36 60.0 25/04/2016 Monday 56 20 76 126.7 26/04/2016 Tuesday 62 24 86 143.3 27/04/2016 Wednesday 52 21 73 121.7 28/04/2016 Thursday 57 18 75 125.0 29/04/2016 Friday 42 21 63 105.0 30/04/2016 Saturday 8 15 23 38.3 Paid Parking Account Holders Total % Occupancy 01/05/2016 Sunday 15 10 25 41.7 02/05/2016 Monday 44 11 55 91.7 03/05/2016 Tuesday 59 24 83 138.3 04/05/2016 Wednesday 65 19 84 140.0 05/05/2016 Thursday 67 23 90 150.0 06/05/2016 Friday 25 17 42 70.0 07/05/2016 Saturday 25 8 33 55.0 08/05/2016 Sunday 26 7 33 55.0 09/05/2016 Monday 57 34 91 151.7 10/05/2016 Tuesday 57 25 82 136.7 11/05/2016 Wednesday 55 26 81 135.0 12/05/2016 Thursday 59 20 79 131.7 13/05/2016 Friday 37 16 53 88.3 14/05/2016 Saturday 56 12 68 113.3 15/05/2016 Sunday 30 15 45 75.0 16/05/2016 Monday 55 24 79 131.7 17/05/2016 Tuesday 41 19 60 100.0 18/05/2016 Wednesday 53 27 80 133.3 19/05/2016 Thursday 57 26 83 138.3 20/05/2016 Friday 32 14 46 76.7 21/05/2016 Saturday 44 14 58 96.7 22/05/2016 Sunday 28 10 38 63.3 23/05/2016 Monday 93 19 112 186.7 24/05/2016 Tuesday 44 26 70 116.7 25/05/2016 Wednesday 57 22 79 131.7 26/05/2016 Thursday 52 24 76 126.7 27/05/2016 Friday 26 27 53 88.3 28/05/2016 Saturday 22 14 36 60.0 29/05/2016 Sunday 19 7 26 43.3 30/05/2016 Monday 27 10 37 61.7 31/05/2016 Tuesday 44 19 63 105.0 Paid Parking Account Holders Total % Occupancy 01/06/2016 Wednesday 62 15 77 128.3 02/06/2016 Thursday 61 19 80 133.3 03/06/2016 Friday 44 19 63 105.0 04/06/2016 Saturday 40 10 50 83.3 05/06/2016 Sunday 37 9 46 76.7 06/06/2016 Monday 64 23 87 145.0 07/06/2016 Tuesday 52 20 72 120.0 08/06/2016 Wednesday 57 32 89 148.3 09/06/2016 Thursday 68 28 96 160.0 10/06/2016 Friday 46 18 64 106.7 11/06/2016 Saturday 30 10 40 66.7 12/06/2016 Sunday 29 8 37 61.7 13/06/2016 Monday 46 25 71 118.3 14/06/2016 Tuesday 47 19 66 110.0 15/06/2016 Wednesday 58 30 88 146.7 16/06/2016 Thursday 59 21 80 133.3 17/06/2016 Friday 35 14 49 81.7 18/06/2016 Saturday 40 8 48 80.0 19/06/2016 Sunday 38 7 45 75.0 20/06/2016 Monday 54 21 75 125.0 21/06/2016 Tuesday 55 27 82 136.7 22/06/2016 Wednesday 58 12 70 116.7 23/06/2016 Thursday 51 32 83 138.3 24/06/2016 Friday 41 18 59 98.3 25/06/2016 Saturday 49 8 57 95.0 26/06/2016 Sunday 30 11 41 68.3 27/06/2016 Monday 51 31 82 136.7 28/06/2016 Tuesday 51 23 74 123.3 29/06/2016 Wednesday 49 22 71 118.3 30/06/2016 Thursday 60 17 77 128.3 Paid Parking Account Holders Total % Occupancy 01/07/2016 Friday 36 16 52 86.7 02/07/2016 Saturday 38 5 43 71.7 03/07/2016 Sunday 18 7 25 41.7 04/07/2016 Monday 46 22 68 113.3 05/07/2016 Tuesday 59 26 85 141.7 06/07/2016 Wednesday 55 20 75 125.0 07/07/2016 Thursday 68 20 88 146.7 08/07/2016 Friday 28 18 46 76.7 09/07/2016 Saturday 22 9 31 51.7 10/07/2016 Sunday 29 13 42 70.0 11/07/2016 Monday 48 26 74 123.3 12/07/2016 Tuesday 46 29 75 125.0 13/07/2016 Wednesday 45 22 67 111.7 14/07/2016 Thursday 57 20 77 128.3 15/07/2016 Friday 29 25 54 90.0 16/07/2016 Saturday 27 6 33 55.0 17/07/2016 Sunday 28 6 34 56.7 18/07/2016 Monday 51 24 75 125.0 19/07/2016 Tuesday 39 25 64 106.7 20/07/2016 Wednesday 59 21 80 133.3 21/07/2016 Thursday 60 20 80 133.3 22/07/2016 Friday 32 18 50 83.3 23/07/2016 Saturday 23 16 39 65.0 24/07/2016 Sunday 32 9 41 68.3 25/07/2016 Monday 46 23 69 115.0 26/07/2016 Tuesday 46 16 62 103.3 27/07/2016 Wednesday 59 14 73 121.7 28/07/2016 Thursday 63 17 80 133.3 29/07/2016 Friday 35 19 54 90.0 30/07/2016 Saturday 26 8 34 56.7 31/07/2016 Sunday 25 5 30 50.0 PRE/2016/0275; Corley Service Station, North bound. 1 message

Griffin, Ian 9 January 2017 at 16:48 To: Jenni

Dear Madam,

I am writing with regards to the above site, and further to our site meeting.

I was very good to meet you, discuss the proposal and view the site. The covering letter you provided has set out that since the 2008 refusal for a similar scheme, that there is now a need for an additional 75 HGV parking spaces on the land to the south of the existing service station. Data has been provided which shows that during peak times the existing HGV area is over occupied, and capacity is high for a large part of each month as set out in the information provided. The peak hours are during the week, and it is noted that over weekends the proposal area would be closed, given it is not in peak demand of the existing site. As discussed on site, there could be special circumstances where the site is opened over weekends, such as the run up to Christmas.

It was noted on our site meeting that the existing HGV parking area was almost full and a large number of HGV’s were using the site, with some parked outside of the HGV area.

Having read the 2008 refusal reasons, and future application will need to address these. I have noted that the Circular 02/2013 is now a consideration in any determination.

Having review the information provided, it is considered in my opinion that in principle a HGV parking area on the north bound services can be acceptable, subject to objections and planning policy issues being overcome;

· Impact upon the Green Belt, and paragraphs 89 and 90, with regards to impact upon openness and if it is inappropriate development, are most relevant as part of the 2012 National Planning Policy Framework. Weblink below

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

· Impact upon the highway network, and you have set out you are in discussion with Highways England.

· You will need to set out a need for the proposal, based upon the figures provided as part of the pre application letter you have provided. You may also wish to consider alternative sites nearby, used for HGV use.

· Impact upon the nearby residential properties, which are to the south, and as you are aware objected to the 2008 application, and any scheme will have an impact.

· With regards to neighbour impact and amenity issues, the existing field boundary treatment should be retained and increased and a relevant acoustic fence would help reduce the impact.

· Lighting would need to be careful set out and considered, and a light spillage plan and lighting report will need to be provided.

· Noise impact upon neighbours would also need to be considered.

· In order to access the site, an opening is required in the hedge and tree boundary, and an ecology report will be required, as you have indicated you will provide. Bat, birds and other animals could be affected.

· A site management document should be provided, setting out how the site will be run and operated, and you have indicated you will provide this.

· A planning statement will be required. · If you wish to provide any draft planning conditions related to the scheme, that would be welcome.

· You are advised to talk to the Warwickshire County Council Flood Risk Management Team, given the size of the site, and a weblink is set out below. http://www.warwickshire.gov.uk/contactusflooding http://www.warwickshire.gov.uk/lfrms

· You may to contact the local Corley Parish Council, and the email address is: [email protected]

· The local borough Councillors for the area are for the Fillongley Ward and can be found through the weblink below: https://www.northwarks.gov.uk/councillors/specificWard/11/fillongley

· The boundary of the service station and the field, contains a public footpath, having viewed the office map, and you should discuss the proposal with the County Footpath Team;

· http://www.warwickshire.gov.uk/definitivemap, or http://www.warwickshire.gov.uk/contactusrightsofway; the footpath map can be viewed - http://maps.warwickshire.gov.uk/rightsofway/

· Policies NW1, 2, 3, 9, 10, 11, 12, 13, 15 and 20 of the 2014 Core Strategy are relevant. Below is a weblink to the document: https://www.northwarks.gov.uk/downloads/file/5892/core_strategy_adopted_2014

Any policies or guidance referred to above can be viewed on the Council’s planning website at www.northwarks.gov.uk/planning along with additional guidance on sustainable design.

The Council encourages the submission of applications on line, via the Planning Portal’s Planning Application Service at www.planningportal.gov.uk. We accept electronic payment for application fees and this is our preferred payment method. Alternatively, you can print copies of application forms from the Council’s own website www.northwarks.gov.uk/planning and submit them in person or by post, where you can also find details on fees and necessary documentation required with your application.

This email does not constitute a Certificate of Lawfulness of Proposed Development. I would advise you to check the deeds to your property, to ensure that no other constraints have been placed on your property. I hope the above is of use but you will appreciate that my views are informal and without prejudice to the outcome of any subsequent planning applications.

Also as discussed on the site the petrol station contains signage, and relevant photos are attached and given it appears to be illuminated and above the size and number of sign a advert consent application is required.

I have informed Shelia in my office about the bollard access to Bennetts Road North, and it was noted it was closed as I drove past.

Regards

Ian Griffin

BSc(Hons), MA, MRTPI

Senior Planning Control Officer North Warwickshire Borough Council

Tel: 01827 719446

Direct Email: [email protected]

Office Email: [email protected]

Internet Links

Website: www.northwarks.gov.uk

Planning Homepage: www.northwarks.gov.uk/planning

Planning Public Access: http://planning.northwarks.gov.uk/portal/

P Please consider the environment before printing this email Advice is given at officer level only and does not prejudice any formal decision the Council makes in the future.

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Any opinions expressed in the E-mail are those of the individual and not necessarily those of North Warwickshire Borough Council. Promotional content is in support of Council priorities or current initiatives. This E-mail and any files with it are confidential and solely for the use of the intended recipient. If you are not the intended recipient or the person responsible for delivering to the intended recipient, please be advised that you have received this E-mail in error and that any use is strictly prohibited.

2 attachments IMG_0941.pdf 681K IMG_0942.pdf 691K

Appendix 3 Email and letter to Case Officer 4th September 2017

Jennifer Smith MRTPI Director

------Forwarded m

To: "Griffin, Ian"

Dear Ian

I have responded to each of your questions below.

I also note that you have sent me a photograph and commentary on parking at Birchanger MSA from the bank holiday weekend. This was accompanied by comments surrounding the over night usage of the car park at Corley, and why this could not be used for HGVs overnight when it was not required for cars.

Starting with the situation at Birchanger; Corley and Birchanger MSAs are very different sites. Whereas Corley is largely a long distance stop, Birchanger is much more of a seasonal site and suffers heavily from congestion at holiday times and particularly at bank holidays. It has a close association with Stansted airport and it is acknowledged that car drivers wait in the services before collecting passengers from the airport.

Birchanger is also an 'off line' MSA whereby traffic must access the site from the junction roundabout. This causes considerable congestion within the MSA, with long queues of traffic that are actively managed during peak periods. This includes active management of the car parks. Corley however is an 'on line' MSA where traffic enters and leaves the site from the mainline motorway. Traffic entering and leaving the site is controlled by the traffic flow on the motorway. It does not experience the same levels of congestion as Birchanger for car travellers, although both sites experience high levels of HGVs (Corley's HGV usage is higher). There is a current planning application at Birchanger to relieve this congestion by creation of a second exit from the MSA site.

Therefore on the August bank holiday weekend, the site was very heavily used by car drivers when little freight was on the road. As such, the site took an operational decision to ease congestion in the car park, to park cars in the HGV park. This was done in specific areas, and in a controlled manner (it was supervised, and all traffic was directed by Welcome Break staff). However, this was an extreme event, and is not done on a daily basis.

You will also note that cars were parking in the HGV car park and not HGVs parking in the car park. Operationally, this is significant and also relevant to Corley.

This was done at a time when there was less demand for HGV parking spaces and peak demand for cars. The cars were able to easily enter the HGV park where there is space to manoeuvre and to leave again without causing any damage to the site's infrastructure.

All MSAs are required by Circular 02/2013 to maintain separate parking areas for different types of traffic. These are segregated in the interests of highway safety between vehicle types, but they must be available to all types of vehicles 24 hours a day. This is a condition of their signage agreement with Highways England.

At Corley, the objector is asking for the car park to be made available to HGVs. The car park entrances are narrow to prevent HGVs entering the car park to ensure that cars and larger vehicles are segregated. If HGVs were allowed into the car park at night time, and these barriers were removed during the night, it is likely that HGVs would then use the car park during the day when there is also a shortage of space in the HGV park. This would cause a highway safety concern as it would be unmanaged (unlike the exceptional event at Birchanger).

Given there is also a shortage of HGV spaces during the day, not just at night time, this would not meet the day time requirements of the site when the car park is busy.

Therefore, Welcome Break do not consider this to be a viable alternative to the proposed scheme.

We also note the comments from the Wildlife Trust. I understand that there are 2 available options here: for us to increase the positive benefits or to make a payment to off site improvements. Can you confirm how much the Wildlife Trust is seeking if that is the case?

I hope the above (and below) is sufficient but if you could let me know if you have any further questions, I would be happy to answer them. I will be attending the committee meeting this evening, and happy to answer further questions then.

Kind regards

Jennifer

Jennifer Smith MRTPI Director

On 30 August 2017 at 14:45, Griffin, Ian wrote:

Dear Madam,

With regards to the above site, I am requesting additional info9rmation in order to aid future questions and issue that may arise:

· What is the Lux level of the lighting on the existing HGV Car Park? I cannot confirm definitely what the level of lighting is in the existing HGV car park but the lights will be older than the ones installed in the HGV park extension. New lights would be focused down to ensure reduced light spill (as set out in the accompanying plans) and would be highly efficient in terms of casting sufficient light within the required area but preventing the light bulb itself from being seen.

· Would you consider removing the two lights, to the over sized HGV parking area, so to reduce any impact upon nearby neighbouring properties?. Could you confirm which two lights you refer to please? We would certainly consider this however we also need to balance the competing issues of safety, the requirements from your designing out crime partners, and the light spill to residents. Modern lights are significantly less 'invasive' than old lights. They are white, covered (in order that the light source cannot be seen) and can be directed where required. The attached image is a good example of this and shows how the areas immediately away from the new, white lights are in darkness, compared with the yellow glow from a traditional light. From having recently reviewed the appeal decision that granted Hopwood Park MSA, I note that the Inspector there placed a planning condition on the height of the lights, and required them to be low impact, directional, down lit lights to prevent impact on adjacent residents. That was deemed to be satisfactory in relation to the issue of permission for a new MSA on the M42.

· How will the car park operate?, barriers?. Will the lights only work when the HGV parking area is open and lighting is required?. The HGV park entrance can either be controlled by barriers or through cones. Barriers would be the preferred choice. This would be open from Monday to Friday and closed at weekends unless there was an exceptional event (Christmas deliveries or an exceptionally bad accident on the motorway that forced drivers to stop).

In terms of lighting, this is something that we would need to determine in accordance with your crime officers - while the lights out might benefit residents, this may not be beneficial in terms of policing the site. It may be that reduced lighting could be used, or a low level system when the site is not in use. My client would certainly be willing to discuss this further and determine a lighting plan with your officers.

· Your statement sets out drivers have a choice when coming up to Corley, and if they stop or carry on along the M6. Is this based on fact / driver survey or assumed?. It is informed common sense. There are two types of driver stop - planned and unplanned. In most cases drivers plan their routes and chose where to stop in advance. Some drivers plan to stop at Corley, and Welcome Break know this because they have account holders who pay to park at the site overnight. There are then unplanned stops which are as a result of breakdown (the HGV itself) or an incident on the motorway. If there is an incident on the motorway, this can force drivers to stop not at their planned break point simply because they are forced to stop due to the legal driving time. Travelling north from Corley there are a number of motorway intersections and therefore a number of route choices. Drivers can travel north on the M6, north on the M6 toll (although most HGV drivers avoid the toll road because of the charge), and M42 (east and west) which then intersects with the M1, M40 and M5. There are an acknowledged lack of services on the M42 to the south/west. Due to large amounts of traffic on these roads and very heavy congestion, it is clear that drivers stop at Corley. If the advanced signage warns of delays, we believe that drivers are likely to take a break before continuing, rather than trying to find somewhere to stop on the M6 between Corley and Hilton Park (there is little choice once past Corley). Welcome Break know that the site is heavily used by HGVs compared with other sites that it operates which is reflected in the amount of traffic entering the site as a % of all journeys, but also compared with the % of HGVs on the motorway more generally.

· What happens is a lorry is left in the HGV parking area after closing hours?. This would be an operational matter for Welcome Break however, both signage and management could deal with this. The site is likely to be open on a Thursday night, and then mid-morning the entrance can be shut, which would allow other traffic to use the existing HGV park, and for all traffic in the extension to exit by the end of the day. Experience shows that daytime traffic generally leaves within 2 hours, and that overnight traffic arrives in the late afternoon. The site would shut the inbound barriers at a point when all overnight traffic had left. Signage would let drivers know not to park there for overnight on Fridays.

Kind Regards

Ian Griffin

BSc(Hons), MA, MRTPI

Senior Planning Control Officer

North Warwickshire Borough Council

Tel: 01827 719446

Direct Email: [email protected]

Office Email: [email protected]

Internet Links

Website: www.northwarks.gov.uk

Planning Homepage: www.northwarks.gov.uk/planning

30A High Street, Stony Stratford, Milton Keynes, MK11 1AF Telephone: 01908 410422 Email: [email protected]

4 September 2017

Mr Jeff Brown Development Control North Warwickshire Borough Council South Street Atherstone Warwickshire CV9 1DE

Dear Sir

Planning Application Reference PAP/2017/0104 Extension to HGV Parking Area Corley Motorway Service Area, Smorrall Lane, Corley CV7 8NR

We act on behalf of Welcome Break.

Welcome Break submitted a planning application in February 2017 for an extension to the HGV parking area at Corley Motorway Service Area (MSA) to form 83 additional HGV spaces. In the documents that form the planning application, Welcome Break through their consultants set out the case for the development.

The application site is located in the Green Belt. Both the adopted Local Plan and National Planning Policy Framework clearly set out that there is a presumption against development in the Green Belt unless the applicant can demonstrate ‘very special circumstances’ that would overcome this, and any other harm. The applicant’s case is set out in the Planning Statement and Supplementary Statement that forms part of the application.

To summarise, the applicant considers that the need for the development in this case constitutes the very special circumstances that would overcome the normal presumption against development in the Green Belt. The case for need is two-fold: first the site specific short fall of HGV parking spaces required to meet current demand alongside future growth forecasts for traffic on the motorway; and secondly in respect of the site specific circumstances that means that route choice and traffic delays result in HGVs needing to stop at Corley MSA.

In respect of the short fall in spaces, this occurs both during the day and overnight. There are two types of HGVs that use the site, drivers that are taking a shorter 45 minute break during the day, and those that use the services for an overnight break. The applicant has provided survey data using ATC counts and CCTV recordings that show that the site cannot accommodate the level of HGVs that require a place to stop. The site regularly exceeds the number of spaces that are provided within the existing HGV parking area. This leads to unauthorised parking both within and outside of the site. It also results in hazardous incidents, of which more than 20 a day were recorded during the CCTV monitoring of the site. All of these were as a result of parking outside the official marked HGV spaces.

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

In relation to site specific circumstances, Corley is located 190 miles from Dover and 140 miles from Felixstow. Under normal driving conditions, both are within 4 and a half hours of Corley, which means that it is a place that is convenient for drivers to stop if travelling onward on the M6. Driving north past the site, there is a network of motorways and route choices, giving access north on the M6 or M6 (toll); north east on the M42; south west on the M42 and onward to the M40 or M5. There are high levels of traffic congestion on all routes. This is combined with a lack of opportunities to stop and rest for HGV drivers on the motorway network. Choices north and west of Corley are Hopwood Park (M42), Hilton Park (M6), Norton Canes (M6 (toll)) and Tamworth (M42). However due to the distance to these or traffic congestion, Welcome Break believe that drivers make a choice when they reach Corley MSA on whether to stop and rest before or after Birmingham.

The ATC figures collected in February 2017 confirm this. Daily figures were recorded that presented the number of vehicles turning into the site from the M6. On weekdays this ranges from 30% of total traffic turning into the MSA, up to 47% on the busiest day. This compares with a DfT count of annual average daily traffic flow which shows that 18.8% of vehicles on this section of the M6 are HGVs, buses or coaches. This is supported by Highways England link data from December 2016 which recorded an annual average weekday count of 17.5% vehicles over 11.6 metres long. The number of HGVs turning into the site as a percentage of the overall traffic flow is far higher than the percentage on the motorway. This shows that there is a specific requirement for vehicles to stop at Corley MSA. Welcome Break consider this is as a result of lack of convenient alternatives on the strategic road network; congestion on the network leading to increased journey times; and journey times being dictated by driving time regulations which forces specific break stops.

It is for these reasons that Welcome Break consider that the very special circumstances exist in this case.

The National Planning Policy Framework however states that “very special circumstances will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations”. In this case, matters that could also be considered to cause ‘harm’ have been assessed by the Council’s statutory consultees, who raise no objections to the scheme. Other harm is either marginal or limited at best, and where it is limited, can be mitigated against. As such, the applicant considers the test in the NPPF has been met.

We therefore respectfully request that planning permission is issued in this case. In the meantime, if you have any questions, please do not hesitate to contact me.

Yours faithfully

Jennifer Smith MRTPI Director

Smith Jenkins Ltd is a registered company (No. 8129229). Registered address: 30A High Street, Stony Stratford, Milton Keynes, MK11 1AF VAT number 186 9643 49

Truck Stop Distances from Corley Motorway Service Area

List of Truck Stops

a. Lincoln Farm Truck Stop – 11.5 miles b. PJM Group Limited – 11.0 miles c. Rugby Truck Stop – 18.4 miles

Appendix 4 Road Haulage Association Letter of Support September 2017

Mr Jeff Brown Head of Development Control Service North Warwickshire Borough Council The Council House South Street Atherstone CV9 1DE

25 September 2017

Dear Mr Brown

Reference: PLANNING APPLICATION PAP/2017/0104 Proposed extension to HGV parking area at Corley Motorway Service Area

The Road Haulage Association is the trade association that works on behalf of the UK road transport operators, currently supporting in excess of 7,000 members who operate 100,000 Heavy Goods Vehicles (HGVs). We liaise with the profession and represent its interests to Government, lobbying on issues that impact on the safe and efficient movement of goods by road across the UK.

I write in connection with the above planning application. This development would provide much needed additional safe truck parking spaces with associated infrastructure and facilities in a location where there is high demand for such a development. I wish to offer my support to the proposal, for the reasons outlined below.

 Corley northbound service area is located at a critical point on the motorway network. It is located at a point where drivers must make a decision in relation to their route choice using the M6, M42/M40, or the M6 toll road. The majority of drivers do not use the Toll road because of the cost. Drivers during the day will assess the traffic situation on the main routes against their remaining legal driving time and assess where to stop. Congestion on the M6 and M42 mean that Corley is a safe and convenient place to stop when faced with significant traffic delays that are often present on these routes.  Corley Services is located approximately 4 hours from Dover / Folkestone and Felixstowe and presents a logical place to stop when travelling north from the ports. It is a legal requirement for drivers to take their statutory rest breaks as stipulated by the Road Transport Working Time Regulations and Drivers’ Hours Rules.  The location of the site is on a high volume traffic route, with many hauliers passing on their route from London to the North and as well as those driving to Ireland via Holyhead or Liverpool.  The additional spaces proposed at Corley would provide drivers with peace of mind when parking up. Truck drivers are becoming more concerned about their own safety and the security of their vehicles, particularly after the terrorist attacks in Nice & Berlin with the use of trucks.  Lorry drivers need a variety of refreshments as well as well-maintained facilities such as showers and bathroom facilities at their stops, all of which would be available within this development.  Almost three-quarters of goods movements are carried by road rather than by rail or water. We need to maximise the use of rail and water freight as part of making the UK’s supply chain as efficient, clean and safe as possible, but they can never replace road.

The provision of safe and secure off-road parking facilities for HGVs on key transport corridors, alongside the provision of hygienic catering and bathroom facilities for HGV drivers is a major issue within the industry. The legislation relating to driver rest periods, combined with a proven lack of adequate rest facilities, creates safety and welfare issues for HGV drivers, where stops often have to be made inappropriate locations. This also creates issues for local authorities across the country, particularly in areas of high road freight activity in and around the main motorways corridors and markets, such as Warwickshire. Local Authorities often have to deal with the consequences of HGVs parking within residential areas, industrial estates and in lay-bys, which include crime and security arising from theft from the vehicles, but also community complaints and in some circumstances environmental issues.

The RHA works hard with Government to highlight these issues and influence policy to address it. The Lorry Parking Audit and Demand Study, undertaken by the Department of Transport in 2011, highlighted the key issues and lack of parking in this regard, concluding that the public sector should favourably view planning applications from the private sector for new or expanded truck stop and service facilities. This proposal is a positive step towards addressing the demand for higher quality facilities in Warwickshire from our members, and will assist the local authorities in addressing some of the issues you are facing from inappropriate overnight parking. The RHA fully supports this proposed investment at Corley, which is located on a strategic transport corridor and international E-road network (E24) (E13); a location heavily used by HGVs supporting the logistics and storage/distribution sectors in the area. If the RHA can offer any further assistance to the local authority in its determination of this planning application then please do contact us.

Yours sincerely

Chrys Rampley Manager Infrastructure, Security & Business Affairs

Appendix 5 Email to Council 23rd October 2017