December 2019 | NCO/BC | P18-1803

SOUTH STAFFORDSHIRE LOCAL PLAN REVIEW

SPATIAL HOUSING STRATEGY AND INFRASTRUCTURE DELIVERY CONSULTATION

LAND OFF STRAWMOOR LANE, CODSALL

ON BEHALF OF RICHBOROUGH ESTATES

TOWN & COUNTRY PLANNING ACT 1990 (AS AMENDED) PLANNING AND COMPULSORY PURCHASE ACT 2004

©Copyright Pegasus Planning Group Limited 2011. The contents of this document must not be copied or reproduced in whole or in part without the written consent of Pegasus Planning Group Limited

Richborough Estates Land off Strawmoor Lane, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery

CONTENTS:

Page No:

1. INTRODUCTION 1 2. CONTEXT 3 3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS 5 4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION 6 5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS 8 6. INFRASTRUCTURE DELIVERY PLAN 2019 12 7. GREEN BELT STUDY 2019 17 8. LANDSCAPE STUDY 2019 24 9. SUSTAINABILITY APPRAISAL 2019 27 10. RURAL SERVICES AND FACILITIES AUDIT 2019 29 11. HABITATS REGULATION ASSESSMENT REVIEW 2018 30 12. LAND AT STRAWMOOR LANE, CODSALL 31 13. CONCLUSION 37

APPENDIX 1: SITE LOCATION PLAN APPENDIX 2: VISION DOCUMENT

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Richborough Estates Land off Strawmoor Lane, Codsall South Staffordshire LPR, Spatial Housing Strategy & Infrastructure Delivery

1. INTRODUCTION

1.1 This representation is made by Pegasus Group on behalf of Richborough Estates to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to land off Strawmoor Lane, Codsall, which Richborough Estates is promoting for residential development.

1.2 These representations respond to the following documents, including addressing the questions set out within the Local Plan Review Consultation Document:

• Spatial Housing Strategy, October 2019

• Infrastructure Delivery Plan, 2019

• Habitats Regulations Assessment Review, 2018

• Green Belt Study, 2019

• Landscape Study 2019

• Rural Services and Facilities Audit 2019

1.3 The representations are framed in the context of the requirements of the Local Plan to be legally compliant and sound. The tests of soundness are set out in the National Planning Policy Framework (NPPF), paragraph 35. For a Plan to be sound it must be:

a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

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d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework.

1.4 The representations also give consideration to the legal and procedural requirements associated with the plan-making process.

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2. CONTEXT

Adopted Local Plan

2.1 The South Staffordshire Local Plan comprises the Core Strategy (adopted December 2012) and the recently adopted Site Allocations Document (adopted September 2018).

2.2 Policy SAD1 of the Site Allocations Document requires South Staffordshire Council to carry out an early review of the Local Plan, which must be submitted to the Secretary of State for Examination by the end of 2021. The Review must be comprehensive and consider the need for additional growth and plan appropriately for it. This Plan will review, as a minimum, the following matters:

• South Staffordshire’s own objectively assessed housing need and the potential for housing supply within the District (including existing safeguarded land identified through the Site Allocations Document) to meet this need;

• The potential role of housing supply options within the District to meet unmet cross boundary needs from the wider Greater Birmingham Housing Market Area (GBHMA), including from the Black Country;

• Employment land requirements for South Staffordshire, as identified through a comprehensive Economic Development Needs Assessment (EDNA);

• South Staffordshire’s potential role in meeting wider unmet employment needs through the Duty to Co-operate;

• The appropriateness of the existing settlement hierarchy and the strategic distribution of growth in light of new housing and employment needs;

• The need for further additional safeguarded housing and employment land for longer term development needs, and the role of safeguarded land in meeting housing shortfalls across the GBHMA, including South Staffordshire’s own needs;

• Gypsy, Traveller and Travelling Showpeople provision; and

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• A comprehensive Green Belt Review undertaken jointly with the Black Country authorities, to inform any further Green Belt release to accommodate new development within the District.

Local Plan Review

2.3 The Local Plan Review is necessary in order to respond to the increasing need for development, both within South Staffordshire, and within neighbouring authorities which form the Greater Birmingham Housing Market Area (GBHMA). South Staffordshire District Council has determined that the Local Plan Review will cover the period to 2037.

2.4 South Staffordshire District Council commenced on an Issues and Options (Regulation 18) consultation between Monday 8 October and Friday 30 November 2018.

2.5 The Spatial Housing Strategy and Infrastructure Consultation represents a second ‘Regulation 18’ consultation, prior to the publication of a ‘Preferred Options’ (‘Regulation 19’) Local Plan, anticipated to occur in Summer 2020.

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3. EVIDENCE USED TO INFORM SPATIAL HOUSING OPTIONS

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

3.1 The consultation document identifies a range of evidence relied upon by the Council to inform the preparation of the seven Spatial Housing Options.

3.2 Richborough Estates is pleased to see the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) Strategic Growth Study forms part of the Council’s evidence base, along with the Strategic Housing and Economic Land Availability Assessment (SHELAA). The SHELAA 2018 provides the most up-to- date evidence on housing land availability in the district and, as such, is a key to identifying the reasonable alternative growth strategies to be considered through the plan-making process.

3.3 Richborough Estates is also pleased that the Council has had regard to evidence that will inform an updated Infrastructure Delivery Plan, including input from key stakeholders outside the District where necessary.

3.4 Whilst the Spatial Housing Strategy will represent a significant element of an overall spatial development strategy, the distribution of housing should be considered in the round having regard to other uses that are required within the District to 2037. The distribution of other requirements, including employment and social and community infrastructure, are intrinsically linked to the delivery of homes as part of a comprehensive, sustainable strategy.

3.5 In light of the above, the evidence identified to inform the Spatial Housing Options appears to omit other relevant technical reports identified at the Issues and Options stage which, it is assumed, will be utilised by officers in formulating the Preferred Options document in Summer 2020.

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4. THE SPATIAL HOUSING OPTIONS UNDER CONSIDERATION

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

4.1 It is noted that all Spatial Housing Options take account of existing ‘potential’ sources of supply i.e. permissions, completions and current allocations. This approach, in principle, is supported. However, it is considered necessary to scrutinise the supply position for robustness.

4.2 Through the Local Plan Review it is considered essential to review all sources of housing supply, including existing commitments. Whilst it is recognised that the Site Allocations Document was only adopted in September 2018, further information or evidence may have arisen since adoption that raises questions of suitability or delivery of sites allocated.

4.3 All potential sources of supply should be scrutinised through the Local Plan Examination in Public, especially non-allocated windfall sites, and it is recommended that a site-specific housing trajectory is prepared to support the Preferred Options consultation in the Summer of next year. This should provide delivery assumptions in respect of any proposed preferred option allocation i.e. build out rates and lead in times.

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

4.4 It is noted that all Spatial Housing Options assume existing ‘safeguarded land allocations’ will be released for development. This approach, in principle, is supported. However, it is considered necessary to apply a level of further scrutiny to this potential source of future supply for robustness.

4.5 As set out above in respect of current commitments, further information or evidence may have arisen since adoption of the Site Allocations Document that raises questions of suitability or delivery of individual safeguarded land allocations.

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4.6 In respect of the safeguarded land allocations an assumption of 35dph has been utilised to determine the likely yield from this source of supply. This relates back to the recommendations of the Greater Birmingham Housing Market Area Study and is considered to represent a reasonable average assumption. However, this average density assumption should only be applied to a net developable area and not the total safeguarded area of 86.8ha established through Policy SAD3. This appears to be the case albeit the calculations utilised in arriving at the Council’s stated yield of 1,651 additional dwellings is not set out.

4.7 The safeguarded land allocations identified in Policy SAD3 are not strategic in size and there are no reasons why their delivery should be delayed. These sites are likely to provide a helpful boost to delivery in the early years of the plan period which would help to support longer-term delivery of strategic sites that may experience longer lead in times to delivery.

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

4.8 Richborough Estates considers that there are no further options that need to be considered.

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5. CONCLUSIONS ON THE SPATIAL HOUSING OPTIONS

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

5.1 Richborough Estates supports the identification of the reasonable alternative spatial housing options that have been identified by the Council. It is considered that these represent appropriate high-level options to inform a preferred spatial strategy for housing growth.

5.2 Whilst the Spatial Housing Strategy Options have been presented as separate and distinct options, alternative strategies could be achieved through a hybrid of the options identified.

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

5.3 Spatial Housing Strategy Option G is supported by Richborough Estates and represents an amalgamation of options identified through the Issues and Options consultation published in 2018. Richborough Estates considers that this option not only assists in providing improved infrastructure but also has due regard to where housing needs exist, including within the top tier sustainable villages and locations close to the Black Country conurbation. Allowing growth in the Tier 1 and Tier 2 settlements provides an opportunity to meet locally arising housing needs and offers opportunity to deliver new services, facilities and infrastructure that would assist in addressing local issues and provide community benefit for residents.

5.4 This strategy provides the opportunity to ensure that the necessary homes, along with supporting infrastructure, would be delivered in a timely and coordinated manner, to meet both the local needs arising from within the District, alongside those arising from the wider GBBCHMA.

5.5 In addition, the accompanying Sustainability Appraisal concludes it is the best performing option on the basis it is likely to result in the greatest positive impacts in terms of sustainability. It is recognised that the emerging Local Plan is not site- specific at this stage and through the proposed site selection process

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opportunities will be present to consider ways in which any negative impacts can be reduced through good design and/or mitigation proposals. Richborough Estates considers that the presence of environmental constraints, such as historic and natural environment assets, do not necessarily preclude development, as such assets can often be positively included or considered through informed site layout and good design.

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

5.6 Richborough Estates supports the Council’s approach to continue exploring an option for the provision of a new settlement for delivering growth beyond the Plan period of the Local Plan Review. This is aligned to the recommendations of the Greater Birmingham Strategic Housing Market Area study which identifies two areas of search:

• Around Dunston

• Between Wolverhampton and Penkridge

5.7 Spatial Housing Option G only seeks to identify an ‘area of opportunity for a new settlement beyond the plan period’ recognising that, to date, no proposal has been put forward to demonstrate self-containment and deliverability. Therefore, it is clear that this potential source of supply should not be relied upon to meet the proposed housing requirement of 8,845 dwellings between 2019 and 2037.

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

5.8 The Issues and Options document highlighted the issue of ‘protecting the Green Belt’ recognising that around 80% of the South Staffordshire is designated Green Belt. In addition, it highlighted the issue of ‘protecting sensitive areas of Open Countryside beyond the Green Belt,’ recognising that much of the character of the countryside beyond the Green Belt is of high landscape quality.

5.9 In light of the emerging housing requirement, capacity within the existing urban areas and the issues and challenges associated with the natural and built environment identified by the Council, development will have implications for Green Belt or the open countryside beyond. Richborough Estates considers the

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Council’s evidence is clear and conclusive in requiring Green Belt release to deliver a sustainable and sound spatial development strategy to 2037. This evidence supports a strong case for demonstrating the necessary exceptional circumstances for such release.

5.10 Of the seven Spatial Housing Strategy options identified, only one (Option A) would negate the need to remove land from the Green Belt. The Council concludes that this option is ‘unsustainable and potentially undeliverable’ as set out in paragraph 5.11 of the consultation document. Richborough Estates supports the Council’s conclusion in respect of this option.

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

5.11 Richborough Estates broadly agrees with the site selection methodology that will inform the identification of preferred options. It is considered that the methodology provides a more appropriate basis for assessing sites than the methodology utilised through the formulation of the Site Allocations Document (SAD) that utilised a flawed scoring system.

5.12 In respect of the staged approach outlined in Appendix 6, Richborough Estates agrees it is sensible to sieve promoted sites to exclude those that are likely to yield less than 10 dwellings and to remove those that are poorly related to existing settlements or which are adversely affected by key constraints that cannot be overcome.

5.13 The methodology identifies a range of criteria to inform the Council’s judgement. It is noted that the ordering of these factors does not imply the level of weight that will be given to each criterion in the site selection process and this is supported as the correct approach.

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

5.14 Richborough Estates agrees that when selecting sites to deliver the preferred spatial housing strategy, the Council should seek to avoid allocating housing sites

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that would result in very high Green Belt harm wherever possible. Having regard to the Council’s Green Belt evidence it would appear that there are options for delivering spatial housing option G without the need to allocate very high harm Green Belt land.

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6. INFRASTRUCTURE DELIVERY PLAN 2019

6.1 South Staffordshire District Council has produced an Infrastructure Delivery Plan (2019) to identify infrastructure projects required to support growth through preparation of the Local Plan Review. This forms part of the evidence base for the Local Plan Review.

6.2 At this stage, the role of the IDP is to identify the district’s baseline infrastructure requirements as well as known requirements that have emerged through engagement with infrastructure providers to date.

6.3 Regarding Codsall, the IDP identifies the opportunity to provide a deliver additional parking close to the station through the Local Plan Review. Staffordshire County Council has also identified parking for the Station as an issue in their Integrated Transport Strategy, October 2017.

Question 1: Do you agree that the delivery of the above infrastructure opportunities should be explored further? If not, please explain why

6.4 Richborough Estates agrees that that the infrastructure projects identified in relation to Codsall should be explored further.

Question 2: Having regard to the level of growth proposed for each village and broad location (see map), are there any other infrastructure projects that you like to see delivered?

6.5 At this time, Richborough Estates has not identified any other infrastructure projects required in respect of the broad locations for growth. However, this position may change once specific sites come forward at future stages of the Local Plan Review process.

General Comments

6.6 In additional to the questions set out within the IDP, Richborough Estates would make the following general comments in relation to the IDP.

Delivery Mechanisms

6.7 Paragraph 3.1 of the IDP states:

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“New development will need to be supported by new infrastructure where there is an evidenced need, and this will need to be at the cost of the developer. Development will not be proposed through the Local Plan unless it has been robustly demonstrated that the development will provide or facilitate the necessary infrastructure.”

6.8 Whilst Richborough Estates recognises the importance of development contributions towards the funding of infrastructure, public sector funding can, and should, also play a key role in the delivery of infrastructure, particularly strategic infrastructure. Public sector funding sources include Local Enterprise Partnership (LEP), central Government, grant funding or National Lottery funding. These funding streams should not be ignored.

Strategies

6.9 A number of strategies and studies are currently being drafted which will identify existing infrastructure provision and deficiencies, with a view to guiding future requirements. It is strongly recommended that these documents are expedited in order to understand relative infrastructure requirements across the District and how these may influence the proposed spatial strategy. The documents currently being prepared include:

• Playing Pitch and Sports Facilities Audit and Strategy

• Open Space Audit and Strategy

• Strategic Flood Risk Assessment and Water Cycle Study

• Brinsford Strategic Park and Ride Feasibility Assessment

• Viability Study

6.10 Whilst all of the above documents are important in informing the Local Plan, of paramount importance is the Viability Study, which will evidence the viability of development proposals, including the costs associated with the infrastructure identified to support the delivery of development sites. Abnormal costs associated with a development site may reduce the scope to deliver identified infrastructure requirements. The Viability Study will therefore determine if identified infrastructure is feasible in financial terms and whether the proposals and polices in the Plan are deliverable. It is therefore a key piece of evidence which will

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underpin and inform all elements of the Local Plan and should be completed before, and used to inform, a draft version of the Plan.

Community Infrastructure Levy (CIL)

6.11 The IDP identifies that the Council does not have a Community Infrastructure Level (CIL) charging schedule. However, the decision on whether to implement CIL will be taken ‘as the Local Plan progresses’, following identification of preferred sites, the outcome of the stage 2 viability assessment, and once a cost- benefit analysis of introducing a CIL has been undertaken.

6.12 Richborough Estates supports the acknowledgement that ‘new settlements or urban extensions need to be CIL exempt due to their significant upfront infrastructure costs’; a CIL requirement could otherwise make such developments unviable.

6.13 Richborough Estates nevertheless recommends caution regarding CIL, following changes to the CIL Regulations which came into force on 1st September 2019. These changes included the removal of the pooling restrictions and Regulation 123 Lists, and the introduction of new reporting requirements through Infrastructure Funding Statements (IFS). CIL authorities must produce their first IFS by 31st December 2020.

6.14 Although the new IFS will include information on how much money authorities have collected in developer contributions and how it has been spent, it is unclear how authorities will ensure effective monitoring, regulation and control of the relationship between CIL and Section 106 obligations.

6.15 With the removal of statutory Regulation 123 lists and the restriction on ‘double- dipping’ previously contained in Regulation 123, the only means of addressing the potential risk of ‘double-dipping’ between CIL payments and section 106 obligations will be through the limitations on the use of Section 106 obligations set out in Regulation 122 i.e. that the contribution is necessary to make the development acceptable in planning terms; is directly related to the development; and is fairly and reasonably related in scale and kind to the development.

6.16 Regulation 122 assumes that the infrastructure to be secured through CIL will be identifiable and fixed for the whole development programme and that when

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entering into a section 106 agreement there is this certainty that the identified developer contributions will not be replicated in CIL payments.

6.17 However, with the removal of Regulation 123 lists, authorities will no longer be restricted in the application of anticipated CIL payments for any specific purpose. Authorities will be able to allocate CIL funds as they see fit and to re-direct such funds should the need arise.

6.18 As such, there is the potential for an authority to secure a S106 contribution to a certain infrastructure project, then subsequently divert CIL funds to ‘top up’ this funding in the future, effectively resulting in ‘double dipping’.

6.19 The absence of Regulation 123 lists accordingly places a significant emphasis on the importance of producing detailed IFS, which are then regularly kept up to date, to ensure that ‘double dipping’ does not occur.

Highways

6.20 Paragraph 5.20 of the IDP states:

“SCC confirmed that they are unable to determine the cumulative effect that the proposed level of growth (circa 9000 dwellings) for the plan period will have on the local highway network without knowing site specific locations. Once preferred sites are identified these will be provided to SCC who will then be able to consider traffic flows at specific junctions and identify where further assessment may be required.”

6.21 Whilst it is accepted that detailed highways modelling cannot be undertaken without considering traffic flows at specific junctions, it nevertheless remains a concern that this modelling will only take place once preferred sites are identified. It is plausible that sites may be identified in a ‘preferred options’ version of the Local Plan, which are subsequently demonstrated to be undeliverable in highways terms, or the cost of highways mitigation is so significant so as to render a site unviable.

6.22 Ideally, detailed highways modelling would be undertaken after the identification of preferred sites, but prior to the publication of the ‘preferred options’ version of the Local Plan, so that this modelling forms part of the evidence base at this stage.

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Baseline Infrastructure Projects

6.23 Appendix 1 of the IDP identifies upwards of 80 specific infrastructure projects which are anticipated to be delivered during the plan period. A number of these are identified as being funded either entirely by private developers, or as a combination of public and private sector funding. However, in the vast majority of cases, the estimated cost of these projects is identified as being ‘unknown’.

6.24 If a planning application was to come forward on a development site which SSDC considered eligible to contribute towards an identified infrastructure project, SSDC would not be able to request a Section 106 contribution towards the project, as the total cost of that project, and therefore the necessary proportional contribution, would be unknown. Therefore, there would be no way of assessing whether the request for a S106 contribution met the tests set out in Regulation 122 i.e. that the contribution is necessary to make the development acceptable in planning terms; is directly related to the development; and is fairly and reasonably related in scale and kind to the development.

6.25 It is therefore of paramount importance that SSDC works with relevant parties to assess and cost specific infrastructure projects as soon as possible, particularly as these costings may have implications for the viability of certain sites and, by extension, the viability of the Local Plan.

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7. GREEN BELT STUDY 2019

7.1 South Staffordshire District Council has commissioned a Green Belt Assessment, alongside the City of Wolverhampton, Dudley, Sandwell and Walsall, (together comprising the Black Country authorities). The Study forms an important piece of evidence for the partial review of the Black Country Core Strategy (the Black Country Plan) and the strategic site allocations and individual development plans of the Black Country Authorities, as well as South Staffordshire District.

7.2 The Green Belt Study has two stages; the first is to assess ‘strategic variations’ between the contribution of land to the five purposes of the Green Belt, whilst the second includes a more focused assessment of the potential ‘harm’ of removing land from the Green Belt. Alongside the Green Belt Study, a Stage 3 assessment involved undertaking a landscape sensitivity assessment in order to assess the sensitivity of land within the South Staffordshire to housing and employment development. Whilst there is a relationship between landscape sensitivity and Green Belt contribution/harm in that physical elements which play a role in determining landscape character, there are fundamental distinctions in the purposes of the two assessments. As such, the findings of the Stage 3 landscape sensitivity assessment for South Staffordshire and the Black Country are presented in a separate document (Landscape Study 2019) and is considered later is this representation.

Green Belt Purposes

7.3 The National Planning Policy Framework (NPPF) states that the Green Belt should serve the five following purposes:

• To check the unrestricted sprawl of large built-up area;

• To prevent neighbouring towns merging into one another;

• To assist in safeguarding the countryside from encroachment;

• To preserve the setting and special character of historic towns; and

• To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

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West Midlands Conurbation

7.4 Paragraph 3.15 of the Green Belt study describes the area that has been identified as ‘the West Midlands conurbation’, which is defined as the main ‘large built-up area’ against which Purpose 1 of the Green Belt is considered.

7.5 The Study identifies that Codsall (contiguous with Billbrook) is considered to have sufficient separation from the main built-up area of Wolverhampton in order to be distinctly separate from the West Midlands conurbation.

7.6 Richborough Estates agrees with this assessment. Sites which separate Codsall and Billbrook from the West Midlands Conurbation1 therefore play an important role in their contribution towards Green Belt Purpose 1.

Land off Strawmoor Lane, Codsall; Contributions to Green Belt Purposes

7.7 The Green Belt Study shows Land off Strawmoor Lane, Codsall, as falling within Green Belt Sub-Parcel Ref S51B – ‘Northwest of Codsall’, which is identified as making the following contribution to the five purposes of the Green Belt:

GB Purpose Assessment Rating Land contains no or very limited urban P1: Checking the development, and has strong openness. It is unrestricted sprawl of close enough to the large built-up area to have Moderate large built-up areas some association with it, but also retains some distinction Land lies between the West Midlands conurbation P2: Preventing the and Albrighton. However there is sufficient merging of Moderate distance between the two for each town to retain neighbouring towns its own distinct landscape setting. Land contains the characteristics of open P3: Safeguarding the countryside (ie an absence of built or otherwise countryside from urbanising uses in Green Belt terms) and does Strong encroachment not have a stronger relationship with the urban area than with the wider countryside. P4: Preserve the setting and special Land does not contribute to the setting or special Weak / No character of historic character of a historic town contribution towns P5: Assist urban regeneration, by All parcels are considered to make an equal encouraging recycling Strong contribution to this purpose. of derelict and other urban land

Table 7.1: Land Parcel S51B Contribution Towards Green Belt Purposes

1 Site Refs: 221, 210 and 503.

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7.8 The Study goes on to identify that, should Green Belt Sub-Parcel ref: S51B (within which Land off Strawmoor Lane falls) be released for development, the resulting harm would be ‘moderate-high’, stating:

“The sub-parcel makes a strong contribution to preventing encroachment of the countryside and a moderate contribution to checking the sprawl of the West Midlands conurbation and preventing the merger of towns. Land to the north of the railway line and south of Moatbrook Lane has a higher degree of containment by urban edges than land to the south, but the Moat Brook and its associated flood zone and tree cover also create a distinction from the inset area to the east. Strawmoor Lane would form a clear alternative Green Belt boundary to the west but the existing inset edges are also clearly defined, and expansion to the north of Wood Road would constitute a weakening of the existing inset edge. Although the houses between Moatbrook Lane and Wood Road represent some expansion beyond Moat Brook the watercourse still represents some distinction in terms of the relationship between settlement and countryside to the north and west of Bilbrook and Codsall.”

Figure 7.1: Harm Ratings for Land Parcel S51B

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7.9 Whilst the conclusions of the above assessment are noted, it remains that Land off Strawmoor Lane serves a reduced function against the five purposes of the Green Belt, as assessed below.

To Check the Unrestricted Sprawl of Large Built-Up Areas

7.10 The harm assessment for Green Belt sub-parcel S51B indicates that the parcel makes a ‘moderate’ contribution to preventing the sprawl of the West Midlands conurbation. However, as set out above, paragraph 3.15 of the Green Belt indicates that Codsall/Billbrook is not considered to form part of the West Midlands conurbation. It is therefore not understood how the Green Belt parcel can make a moderate contribution in preventing its sprawl, particularly when the parcel is located on the western side of Codsall i.e the side furthest away from the conurbation.

7.11 The majority of the site is located to the south of a number of existing dwellings, located between Wood Road and Moatbrook Lane. Furthermore, a number of agricultural buildings exist between Moatbrook Lane and Wood Road, as well as adjacent to Chillington Lane and Slate Lane. The identified site boundary aligns with these existing features and, as such, its development would not result in sprawl away from Codsall. Indeed, the Concept Plan illustrated later within this representation only shows limited development beyond Slate Lane, in line with the existing agricultural buildings at Chillington Lane. Development in this manner would accordingly serve to ‘round off’ the settlement and not result in the sprawl of Codsall beyond its current extent.

7.12 It is therefore considered that the parcel makes a ‘weak/no’ contribution to the checking the unrestricted sprawl of large built-up areas, rather than the ‘moderate’ contribution identified within the Green Belt Study.

To Prevent Neighbouring Towns from Merging into One Another

7.13 The removal of the site from the Green Belt would amount to a negligible reduction to the separation distances between the built-up area of Codsall/Billbrook and the nearest neighbouring town.

7.14 As set out above, the identified site boundary aligns with existing urbanising features to the western edge of Codsall. The site accordingly does not serve a purpose in terms of maintaining separation between Codsall and the nearest

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neighbouring town. Furthermore, the site’s western boundary is currently defined by a mixture of features, including; hedgerow, sporadic trees and Strawmoor Lane. The development of the site for residential purposes accordingly represents an opportunity to strengthen this boundary to provide one which would endure in the long-term.

7.15 Richborough Estates therefore agrees with the conclusions of the Green Belt Study, that the site makes a ‘weak/no’ contribution to preventing neighbouring towns from merging into one another.

To Assist in Safeguarding the Countryside from Encroachment

7.16 By definition, development of any greenfield site beyond the boundary of a settlement results in encroachment into the countryside. Nevertheless, as set out above, the identified site boundaries align with existing residential or agricultural buildings to the western edge of Codsall. There are, therefore, clear urbanising features surrounding the site, reducing the extent to which the site encroaches into the open countryside.

7.17 Again, as set out above, the site’s western boundary is currently defined by a mixture of features. The development of the site for residential purposes represents an opportunity to strengthen this boundary to provide one which would endure in the long-term, creating a clear transitional arrangement between the urban area and the countryside.

7.18 Lastly, the site is currently in private ownership and no public rights of way exist across it. As such, the site does not offer any opportunities for recreation. The Concept Plan illustrated later within this representation includes significant areas of open space, particularly to the south-east of the site, increasing opportunities for recreation and promoting access into the countryside.

7.19 It is therefore considered that the site makes a ‘moderate’ contribution to assisting in safeguarding the countryside from encroachment, rather than the ‘strong’ contribution identified within the Green Belt Study.

To Preserve the Setting and Special Character of Historic Towns

7.20 There are no listed buildings or other heritage assets within the vicinity of the site. Similarly, Codsall as a settlement has a limited number of listed buildings,

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located to the centre of the settlement and around St Nicholas C of E Church. Codsall is accordingly not considered to constitute an ‘historic town’ in the context of the NPPF. As such, the development of the site for residential purposes would not compromise the setting or special character of an historic town.

7.21 Richborough Estates therefore agrees with the conclusions of the Green Belt Study, that the site makes a ‘weak/no’ contribution to preserving the setting and special character of historic towns.

To Assist in Urban Regeneration, by Encouraging the Recycling of Derelict and other Urban Land

7.22 Whilst it is acknowledged that all Green Belt land makes a contribution towards encouraging the recycling of derelict and other urban land, the site and immediate area does not contain significant areas of brownfield land and would therefore not prejudice the redevelopment of urban land in this area. The release of the site from the Green Belt and allocation for residential development would therefore not significantly prevent the recycling of derelict land and other urban land.

7.23 It is therefore considered that the site makes a ‘moderate’ contribution to this purpose of the Green Belt, rather than the ‘strong’ contribution identified within the Green Belt Study.

Summary of Green Belt Purposes

7.24 Overall, it is therefore considered that Land off Strawmoor Lane, Codsall, makes a reduced contribution to the five purposes of the Green Belt than that identified within the Green Belt for Green Belt Sub-Parcel ref: S51B. This contribution is summarised in the table below:

Previous Revised GB Purpose Rating Rating P1: Checking the unrestricted sprawl of large built-up Weak / No Moderate areas contribution Weak / No P2: Preventing the merging of neighbouring towns Moderate contribution P3: Safeguarding the countryside from encroachment Strong Moderate P4: Preserve the setting and special character of Weak / No Weak / No historic towns contribution contribution P5: Assist urban regeneration, by encouraging recycling Strong Moderate of derelict and other urban land

Table 7.2: Land off Strawmoor Lane, Green Belt Assessment

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Green Belt Harm

7.25 Given the reduced impact upon the five purposes of the Green Belt as set out above, is contented that the Green Belt harm identified within the Study should be reduced from ‘moderate-high to ‘low-moderate’.

7.26 It is the view of Richborough Estates that the site makes a weak/no contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. The site would form a logical location for the expansion of the settlement edge, with the existing site boundaries representing strong defensible boundaries for the Green Belt edge in the future.

7.27 Therefore, release of this site would constitute a limited weakening of the Green Belt.

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8. LANDSCAPE STUDY 2019

8.1 South Staffordshire District Council has produced a Landscape Study (2019) which forms part of the Local Plan Review evidence base. Land off Strawmoor Lane falls with Landscape Parcel Reference: SL36S2. These two landscape parcels subsequently fall within the ‘Ancient Clay Farmlands’ Landscape Character Type. The area is located north west of Wolverhampton, on the western outskirts of Codsall and extends to the village of Oaken.

8.2 An extract of the Council’s Appraisal of Landscape Sensitivity is included below:

Characteristic / Lower Sensitivity to Moderate Sensitivity Higher Sensitivity Attribute Development to Development to Development Generally small pastoral fields well defined by Fields to the north of hedgerows, with Scale the railway are larger in frequent mature field scale. and hedgerow trees which increase the sense of intimacy. Sloping landform which rises sharply Landform to the north from the edge of Landform of the railway line is Codsall at 115m more gently undulating. AOD, to the village of Oaken at 140m AOD. The landscape south of the railway line is characterised by 19th century parkland associated with country houses built for local industrialists and small pastoral fields (identified as post-1880s replanned enclosure). Larger 18th/19th century Landscape pattern planned enclosure and time depth are found north of the railway line and a small area of irregular post- medieval enclosure either side of Wood Lane. The landscape pattern has remained largely unchanged from the 1880s edition OS, resulting in strong time depth. Areas of semi-natural habitats include Priority Habitat deciduous 'Natural' woodland on the edge

character of Oaken and along stream corridors. Valued natural features include the

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predominance of mature parkland trees, intact hedgerows and hedgerow trees. The parkland landscape to the south of the railway Two overhead electiricity Built features within the line within the routes cut through the landscape area include Codsall Billbrook and north western corner and residential properties on Oaken Conservation Built character the railway line runs the settlment edge of Area is associated east-west through the Oaken and Codsall and with two unlisted centre of the area. a few farms. 19th century country houses, The Terrace at Oaken and Springfield House. The parkland to the south has open Recreational The north of the area is access and is crossed

character not publicly accessible. by the Staffordshire Way Long Distance Recreational Route. The area has a Two overhead electricity strong rural routes introduce an character, extending urbanising element, Perceptual from the parkland to whilst noise from passing aspects the south to the trains may also detract working agricultural from the perceptual landscape to the qualities of the area. north. Although ribbon development along The area provides a Wood Road and rural setting for Moatbrook Lane present Codstall and Oaken, a weaker edge to the particularly within the Settlement settlment, strong Codsall Billbrook and

setting hedgerows and Oaken Conservation woodland belts along Area, which provides these roads and around an important rural Moatbrook Playing gap between the two Fields provide a strong settlements. barrier feature. The slopes surrounding Oaken Visual prominence are visually prominent within the local landscape. Inter-visibility with adjacent There is no inter-visibility designated with adjacent sensitive

landscapes or landscapes or marked promoted view viewpoints. points Areas north of the railway line have moderate-high Landscape sensitivity to residential development, as land here Sensitivity is larger in scale, less visually prominent and locally Moderate-High Judgement (SL36 influenced by the intersecting pylon route. However, S2) this is counterbalanced by strong landscape pattern and strongly vegetated settlement edge.

8.3 The Study concludes that Landscape Parcel SL36S2 (which encompasses Land at Strawmoor Lane) is considered to have a ‘moderate-high’ overall sensitivity to residential development, as identified on Figure 8.1 overleaf.

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Figure 8.1: Landscape Sensitivity Rating Parcel SL36

8.4 The findings of the Landscape Study for the wider parcel are not necessarily disputed by Richborough Estates. Nevertheless, the site itself relates physically and visually to the existing settlement edge of Codsall, in conjunction with the presence of features such as the railway line to the south, which collectively detract from the overall landscape sensitivity of the site.

8.5 Matters relating to site-specific landscape sensitivity are considered further in Chapter 11 of this Representation.

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9. SUSTAINABILITY APPRAISAL 2019

9.1 Lepus Consulting has produced a Sustainability Appraisal of the South Staffordshire Local Plan Review: Spatial Housing Strategy and Infrastructure Delivery (‘the SA’), on behalf of the Council.

9.2 The SA assesses the sustainability effects of the seven growth options identified within the South Staffordshire Local Plan Review and does not assess the sustainability of individual sites or land parcels at this stage.

9.3 A summary of the findings of the SA is included below at Figure 9.1.

Figure 9.1: Summary of SA Appraisal Findings for Each Growth Option

9.4 Whilst it is acknowledged that the SA is ‘high level’ at this stage, it remains that the Council has commissioned a number of pieces of evidence to inform the Local Plan Review at this stage, including a Landscape Sensitivity Study (prepared by LUC, 2019).

9.5 This Study assesses the landscape sensitivity of 96 broad parcels of land and the subsequent degree of harm that would result if these parcels were to be developed. The Study concludes that these parcels demonstrate five degrees of varying sensitivity, from ‘low’ to ‘high’.

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9.6 Given the varying nature of these landscape parcels and their attributed sensitivity ratings, coupled with the varying typologies of the growth options presented in the Local Plan Review, it is illogical that all seven growth options should score the same (a ‘double negative’) in respect of Landscape and Townscape. Such a conclusion effectively renders the findings of the Landscape Study irrelevant in informing the preferred spatial strategy for growth.

9.7 It is therefore considered that more could be done to differentiate between the sustainability benefits of the seven growth options identified within the plan.

9.8 Nonetheless, Richborough Estates agrees with the overall conclusion of the SA at this stage, that Option G – ‘Infrastructure-led development with a garden village area of search beyond the plan period’ represents the most sustainable growth option available.

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10. RURAL SERVICES AND FACILITIES AUDIT 2019

10.1 South Staffordshire District Council has prepared a Rural Services and Facilities Audit (2019) (‘the RSFA’) which presents evidence on the relative level of services and facilities present in settlements within South Staffordshire.

10.2 The RSFA identifies five key indicators to compare the relative sustainability of settlements within the District as follows:

• Access to food stores;

• Diversity of accessible community facilities/services;

• Access to employment locations;

• Access to education facilities; and

• Public transport access to higher order services outside of the village.

10.3 Codsall is identified as falling within ‘Tier 1 Settlements’ which are described as:

“These settlements typically have food stores, a wider range of services and facilities than other villages, a range of education establishments, access to a train station and good access to employment and wider facilities outside the village via public transport.”

10.4 The overall settlement hierarchy scoring for Codsall is presented below.

Access to convenience stores/ supermarkets Diversity of other accessible community facilities/ services Access to employment locations Access to primary/ first school within settlement Access to secondary/ high school within settlement Access to 6th form/college within settlement Public transport access to higher order services outside of the village

Figure 10.1: Settlement Hierarchy Scoring for Codsall, RSFA (2019)

10.5 Richborough Estates supports the findings of the RSFA in relation to Codsall.

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11. HABITATS REGULATION ASSESSMENT REVIEW 2018

11.1 South Staffordshire District Council has produced a Habitat Regulations Appraisal (HRA) Review to support the Issues and Options consultation document. The report aims to identify and collect information in relation to designated European Nature Conservation sites which could be affected by proposals promoted through the Local Plan Review process. The report also provides an initial overview of the potential effects on European sites of the policy and growth options contained within the Local Plan Review Document.

11.2 However, the HRA Review has not been updated to consider or reflect the spatial options for growth presented within this latest consultation. The Review should be updated as soon as possible to consider the potential impact and necessary mitigation of preferred Housing Option G.

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12. LAND AT STRAWMOOR LANE, CODSALL

12.1 This Chapter sets out a brief description of the site, followed by an assessment of the site against each of the Council’s site selection criteria, as defined within the Site Selection Methodology for Preferred Options document (Appendix 6 of Spatial Housing Strategy & Infrastructure Delivery consultation).

Site Description

12.2 Richborough Estates has current land interests in land at Strawmoor Lane, Codsall, as shown on the Site Location Plan appended to this representation (see Appendix 1).

12.3 The site comprises approximately 19 hectares of land, made up of four field parcels, located to either side of Moatbrook Lane and to the east of Strawmoor Lane. This land represents a logical and sustainable extension to the existing Category 1 settlement of Codsall and has the capacity to deliver approximately 200-250 dwellings and supporting infrastructure.

12.4 The majority of the site is located within Flood Zone 1 (land having less than 1 in 1,000 probability of annual flooding). However, the Moat Brook runs through the southern section of the site, resulting in some of the site being classified as falling within Flood Zone 2 (land having between a 1 in 100 and 1 in 1,000 probability of annual flooding) and Flood Zone 3 (land having greater than 1 in 100 probability of annual flooding). The proposed development area does not encroach on areas at risk of flooding.

12.5 The site is located within the West Midlands Green Belt, but immediately adjacent to the built-up area of Codsall.

12.6 Natural England’s Land Classification Map for the West Midlands Region (ALC004) shows that the site comprises a mix of undefined Grade 3 ‘Good to Moderate’ quality agricultural land and Grade 4 ‘poor’ quality agricultural land.

12.7 The site has no other environmental or historical designations.

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Concept Layout

12.8 A Concept Layout has been prepared which takes into consideration the sites’ opportunities and constraints, including the Moat Brook and overhead powerlines to the west of the site.

12.9 This Layout demonstrates how the site may come forward for development in five parcels, with areas of open space provided to the north, centre and south of the site.

12.10 This Concept Layout is included at Appendix 2 to this Representation.

APPENDIX 2 – CONCEPT LAYOUT

Illustrative Masterplan

12.11 An illustrative masterplan (Appendix 3) has been prepared to introduce an initial proposal, providing an indication of how the site could be delivered and function as a natural sustainable, extension to Codsall.

APPENDIX 3 – ILLUSTRATIVE MASTERPLAN

12.12 The Illustrative Masterplan identifies the following key features:

• Approximately 230 dwellings, including a policy compliant level of affordable housing and a mixture of sizes and tenures;

• Provision of approximately 7 hectares of public open space, including proposed attenuation areas;

• Creation of a new road, connecting Wood Road with Moatbrook Lane and Strawmoor Lane;

• Provision of access from Strawmoor Lane;

• Significant provision of Green Infrastructure to include a landscape mitigation strategy and footpath links to the wider open space areas;

• Provision of SuDS through the delivery of new attenuation features; and

• A new enduring Green Belt boundary to the western edge of the site.

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Green Belt Harm

12.13 As set out in Chapter 7, it is contented that the Green Belt harm identified within the Study should be reduced from ‘moderate-high to ‘low-moderate’.

12.14 It is the view of Richborough Estates that the site makes a weak/no contribution to preventing sprawl of the West Midlands conurbation and preventing encroachment on the countryside. The site would form a logical location for the expansion of the settlement edge, with the existing site boundaries representing strong defensible boundaries for the Green Belt edge in the future.

12.15 Therefore, release of this site would constitute a limited weakening of the Green Belt.

Landscape Sensitivity

12.16 Again, Chapter 8 of this Representation sets out how South Staffordshire District Council’s Landscape Study (2019) concludes that Landscape Parcel SL36S2 (which encompasses Land at Strawmoor Lane) is considered to have a ‘moderate- high’ overall sensitivity to residential development.

12.17 Nevertheless, Richborough Estates remains of the view that land off Strawmoor Lane performs better in landscape terms than Landscape Parcel SL36S2. The site relates physically and visually to the existing settlement edge of Codsall. The proposed development will not result in the addition of uncharacteristic or incongruous features. Views of the site are limited and localised and all feature urban influences, with the railway line and associated vegetation to the south further restricting distant views. These features detract from the overall landscape sensitivity of the site.

The submitted Concept Plan for the site (see Appendix 2) offers a significant opportunity to enhance the landscape fabric and character of the site through the retention of the existing trees and hedgerows and the creation of new public open space.

Sustainability

12.18 The Council’s Sustainability Appraisal (2019) does not consider site-specific details at this stage. Nevertheless, the site is located adjacent to the current built up area of Codsall, which is identified as a Tier 1 settlement within the Council’s

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Rural Services and Facilities Audit. The site accordingly benefits from good access to services and facilities the village centre. The also site benefits from good access to Codsall Railway Station, which provides regular rail services between Birmingham and Shrewsbury.

12.19 The site is therefore sustainably located.

Impact on the Historic Environment

12.20 There are no listed buildings or conservation areas located in the immediately vicinity of the site. However, the Codsall and Oaken Conservation Area ‘Buffer Zone’ is located immediately beyond the southern boundary of the site.

12.21 The Illustrative Layout Plan included as part of this representation demonstrates how, due to flood risk and drainage constraints, development will be located in the northern and central areas of the site. This will result in the provision of an additional buffer adjacent to the Conservation Area Buffer Zone, further preserving the setting of the Conservation Area.

12.22 There are therefore no heritage constraints to the allocation of the site for residential development.

Surface Water Flooding

12.23 The majority of the site is located within Flood Zone 1 (the area at least risk from flooding). A smaller area of the site to the south is located within Flood Zones 2 and 3. These areas are not proposed to be developed and would be retained as public open space. The SuDS proposed for the site would also be located beyond these areas.

12.24 A water course enters the site from the west, flowing eastwards, exiting through the eastern boundary. Anecdotal evidence suggests areas adjacent to this water course are seasonally wet. However, again, development is not proposed in these areas.

12.25 The topography of the site supports the use of gravity storm drainage, with the site gently falling towards existing water courses. It is anticipated that a pumping station will be required on the site to accommodate foul drainage, the location of which will be determined at planning application stage.

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Highways (Accessibility to the Site)

12.26 It is proposed to extend Strawmoor Lane northwards to serve the northern parcel of land, meeting Wood Lane at a priority junction and providing a more attractive route to Wood Lane for traffic, rather than along Slate Lane, from the development proposal and elsewhere.

12.27 The main vehicle access to the main body of the development will be from Strawmoor Lane in the form of a priority junction, with Moatbrook Lane forming a priority crossroads junction with Strawmoor Lane and on through the northern development parcel to Wood Lane. A separate pedestrian access is provided to Moatbrook Lane in the northeast corner of the site.

12.28 The site access points can accommodate a refuse lorry, which is typically the largest vehicle that might be expected to access the site on a weekly basis.

12.29 A development of around 230 dwellings would be expected to generate around 120 two-way peak-hour vehicle trips, i.e two trips per minute. The majority of traffic is expected to head north along Strawmoor Lane. The site access strategy can easily accommodate such levels of traffic and the impact of the development traffic is such that it will not be unduly perceptible to existing road users on the wider highway network.

Suitability

12.30 The information set out above demonstrate that the Strawmoor Lane site is a suitable site for development.

12.31 It is submitted that the site serves a reduced function against the five purposes of the Green Belt and that many of the potential impacts of development can be suitably mitigated.

Deliverability

12.32 There is an agreement in place between eh relevant landowners and Richborough Estates to facilitate the development of the site.

12.33 A considerable amount of technical work has been undertaken to consider deliverability of this site. Richborough Estates can confirm that this work

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demonstrates that there are no constraints likely to render the site undeliverable in the plan period. The site is available now.

12.34 There are no existing uses that would require relocation and no issues of contamination that would require remediation. The impacts of development can be mitigated and, in many cases, a positive outcome can be achieved.

12.35 The site is deliverable and immediately available and, subject to allocation, could deliver homes within the next 5 years.

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13. CONCLUSION

13.1 This representation is made by Pegasus Group on behalf of Richborough Estates UK Limited to the South Staffordshire Local Plan Review, Spatial Housing Strategy and Infrastructure Delivery (Regulation 18) consultation. This representation relates to land off Strawmoor Lane, Codsall, which Richborough Estates is promoting for residential development.

13.2 The information contained within this representation, read in conjunction with the appended illustrative masterplan, demonstrates that land off Strawmoor Lane is a suitable and deliverable site for residential development, subject to its release from the Green Belt.

13.3 There are no existing uses that would require relocation and no issues of contamination that would require remediation. Many of the potential impacts of the development of the site can be mitigated through design and in many cases a positive outcome can be achieved.

13.4 It is therefore submitted that land of Strawmoor Lane should be allocated for development through the Local Plan Review.

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APPENDIX 1 Development Site

Not to Scale Land off Strawmoor Lane Codsall Reproduced by permission of Ordnance Survey on behalf of HMSO. T18571 - Figure 1.1 © Crown copyright and database right 2018. All rights reserved. Ordnance Survey Licence number 100046404. Site Location Plan APPENDIX 2 LLAAANNNDD AATT SSTTTRRRAAAWWWMMMOOOOOORR LLAAANNNEE CODSALL

SSSISIIITTTTEEEE PPPRPRRROOOMMMOOOTTTTIIIIOOONN DDOOOCCCUUUMMMEEEENNNTTTT

PREPARED ON BEHALF OF RICHBOROUGH ESTATES LTD BY

JULY 2019 “Good design is a key aspect of sustainable development, creates better places in which to live and work and helps make development acceptable to communities”

Para 124, NPPF 2019 CONTENTS

INTRODUCTION & 010101 DOCUMENT PURPOSE

PLANNING POLICY CONTEXT 020202 SUMMARY OF PLANNING POLICY AND GUIDANCE HOUSING AND EMPLOYMENT NEED CASE FOR GREEN BELT RELEASE FIVE PURPOSES OF GREEN BELT

030303 SITE & SURROUNDINGS OVERVIEW

ENVIRONMENTAL CONSIDERATIONS 04 LOCAL FACILITIES ACCESS AND MOVEMENT HERITAGE AND ARCHAEOLOGY LANDSCAPE AND VISUAL VIEWS FLOOD RISK AND DRAINAGE ECOLOGY SUMMARY OF ANALYSIS

VISION, CONCEPT PLAN AND DESIGN PRINCIPLES 050505 ACCESS AND MOVEMENT

060606 SUMMARY AND CONCLUSION

THE SITE

NEIGHBOURHOOD CENTRE

CODSALL TRAIN STATION

SITE LOCATION PLAN

2 LAND AT STRAWMOOR LANE | CODSALL

01 INTRODUCTION & DOCUMENT PURPOSE

INTRODUCTION DOCUMENT PURPOSE

1.1 The land at Strawmoor Lane represents a logical and 1.5 South Staffordshire Council is currently in the process of 1.8 This document has been prepared with input from the appropriate extension to the top tier settlement of reviewing their Local Plan to identify and direct growth following Consultant team: Codsall. The site is sustainable, is well located to a wide within the District to 2037. This will include

range of existing services and facilities, and offers an consideration of an appropriate housing requirement opportunity to deliver new homes alongside supporting and a spatial strategy for distributing growth, informed PLANNING community infrastructure. by an updated settlement hierarchy. This Promotional Pegasus Group Document demonstrates that the site at Strawmoor RICHBOROUGH ESTATES Lane will form a logical extension to Codsall and that URBAN DESIGN exceptional circumstances exist to justify its removal Woods Hardwick Ltd 1.2 Richborough Estates is a responsible and specialist from the Green Belt. strategic land promotion business founded with the aim LANDSCAPE of working in partnership with landowners. Our projects 1.6 This Promotional Document presents an analysis of the Tyler Grange are located throughout the country ranging from site and its surroundings and sets out in detail the case residential schemes of around 50 dwellings to large for the removal of the site from the Green Belt. This ECOLOGY urban extensions (including sites within the Green Belt), includes a review of the current and emerging planning RammSanderson Retail, Commercial and Extra Care facilities. policy position and an assessment of the site against ACCESS & MOVEMENT the five purposes of the Green Belt contained in the 1.3 Richborough Estates oversees the entire planning Hub Transport Planning National Planning Policy Framework (“The Framework”). process from start to finish and works closely with local communities, Planning Officers and key 1.7 The document also sets out the Vision for the site, FLOOD RISK AND DRAINAGE stakeholders, to create mutually beneficial schemes. informed by a consideration of the constraints and BWB Richborough is seeking to apply this approach to the opportunities and an Indicative Masterplan HERITAGE proposed development which is the subject of this demonstrating how the Vision can be achieved through CgMs Promotional Document. a well-designed scheme. The document concludes with

a concise summary of the site, the proposed 1.4 Richborough Estates has an interest in the land at development and its key benefits. Strawmoor Lane. The extent of land controlled by LAND PROMOTER Richborough is shown edged red on the Site Location Richborough Estates Plan on page 2.

LAND AT STRAWMOOR LANE | CODSALL 333 “Planning policies and decisions should ensure that developments will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development”

Para 127(a), NPPF 2019 02 PLANNING POLICY CONTEXT

M54

KEY

THE SITE

BUILT UP AREAS

SETTLEMENTS WITHIN CLOSE PROXIMITY OF ONE ANOTHER THE SITE RAILWAY LINE

M54 MOTORWAY

CODSALL DEVELOPMENT POLICIES

SOUTH STAFFORDSHIRE GREEN BELT

CONSERVATION AREA

HISTORIC LANDSCAPE AREA

ANCIENT WOODLAND

SAFEGUARDED LAND

HOUSING ALLOCATION SITES

VILLAGE/NEIGHBOURHOOD CENTRE

EXISTING EMPLOYMENT SITE

BIOLOGICAL ALERT SITE

SITES OF BIOLOGICAL INTEREST

ANCIENT MONUMENTS WOLVERHAMPTON

SHELLA 2018

SITES CONSIDERED UNSUITABLE FOR DEVELOPMENT PLAN ILLUSTRATING SITE LOCATION, CONTEXT AND SOUTH STAFFORDSHIRE DEVELOPMENT PLAN DESIGNATIONS

6 LAND AT STRAWMOOR LANE | CODSALL

02 PLANNING CONTEXT

INTRODUCTION 2.4 Furthermore, paragraph 8 of the Framework sets out 2.8 The policies map identifies the following designation that sustainable development has three overarching for the site: 2.1 There is an exceptionally strong case to support objectives: economic, social and environmental. The amendments to the Codsall and Bilbrook Green Belt proposed development accords with each of these • Green Belt (Policy GB1) boundary and for releasing the site for residential objectives, contributing to building a strong, responsive

development. and competitive economy, supporting strong, vibrant and healthy communities and continuing to protect and PLANNING POLICY CONTEXT 2.9 Codsall does not lie within a Neighbourhood Area enhance the natural, built and historic environment. Designation and therefore a Neighbourhood Plan has National Planning Guidance 2.5 Chapter 5 of the NPPF sets out how local authorities not been progressed to date.

2.2 In February 2019, the Government published a revised should boost significantly the supply of housing in National Planning Policy Framework (“Framework”) order to deliver sufficient supply of homes. The land at Emerging Local Plan which replaces the previous guidance published in 2018 Strawmoor Lane, Codsall, represents a deliverable site and provides the overarching planning framework for that is available, achievable and viable and the 2.10 South Staffordshire District Council has commenced England. Central to the Framework is a presumption in provision of housing on the wider site would boost the work on a review of the adopted Local Plan which is favour of sustainable development which is the golden supply of housing in the District. essential to respond to unmet housing needs within the District and those confirmed within the wider Greater thread running through both plan-making and decision -taking (paragraph 11). The Framework also seeks to Birmingham and Black Country Housing Market Area Existing Development Plan boost the supply of housing and requires local (GBBCHMA). The Local Plan Review provides an authorities to plan positively fir objectivity assessed 2.6 The Development Plan for South Staffordshire currently opportunity for the Council to establish a robust needs and maintain a sufficient supply of housing land. comprises: housing requirement, having regard to local housing needs and cross boundary requirements and • 2.3 Paragraph 136 of the Framework states that once the Adopted Core Strategy (adopted 11th comprehensively review the vision, strategic objectives, general extent of a Green Belt has been approved, it December 2012) spatial development strategy and policies for shaping should only be altered in ‘exceptional circumstances’ • detailed development proposals. The review process Site Allocations Document (SAD) (adopted 11th through the plan-making process and that the September 2018) will also ensure consistency with the new National amended Green Belt boundary should be “capable of Planning Policy Framework (NPPF), which seeks a enduring beyond the plan period”. There are 2.7 The Core Strategy establishes the strategic policies for requirement for local planning authorities to keep their exceptional circumstances which justify alteration to the the District, notably the housing requirement and Local Plan up to date by undertaking a review at least Green Belt boundary in South Staffordshire District and distribution of housing (Core Policy 1 and Core Policy every five years. the site offers an opportunity to release Green Belt in a 6), whilst the Site Allocations Document provides a sensitive manner, without harming its purposes and range of allocations to deliver the requirements set out functions, as set out in paragraph 134 of the within the Core Strategy. Framework.

LAND AT STRAWMOOR LANE | CCCOCOOODDDDSSSSAAAALLLLLL 777

2.11 The Issues and Options consultation document 2.14 Tier 1 settlements are considered the most identifies an objectively assessed housing need of 5,130 sustainable of the District’s villages, with the greatest dwellings for South Staffordshire District to 2037, access to services and facilities. It is concluded that: utilising the Government’s standard method. In “These settlements typically have food stores, a w ider addition, it highlights a range of growth options for range of facilities than other villages, a range o f contributing towards meeting the housing shortfall education establishments, access to a train statio n and within the wider GBBCHMA and commits to testing the good access to employment and wider facilities out side delivery of a minimum of 4,000 additional dwellings. the village via public transport.” This would provide a minimum requirement of 9,130 dwellings between 2018 and 2037; representing a 2.15 Approximately 80% of South Staffordshire lies within significant uplift compared with past delivery rates the West Midlands Green Belt. The Council experienced within the District. acknowledges that it may be necessary to consider Green Belt boundaries in some locations to 2.12 The Issues and Options document also identifies a accommodate the necessary levels of growth in a range of spatial distribution options to be tested, sustainable manner. The combined requirements of an including an option to focus development to the increased OAN and the potential for meeting an District’s larger and better connected villages, such as element of the overspill requirement is likely to increase Codsall. A revised Settlement Hierarchy has informed pressures for Green Belt releases, given the lack of these options, which highlights Codsall as a “Tier 1” urban capacity and the small proportion of the district settlement. that lies outside the current Green Belt designation. A ROADS 2.13 The Tiers are set out in the new Rural Services and 2.16 Codsall is completely constrained by Green Belt, with RAILWAY Facilities Audit (2018), which assessed the sustainability TIER 1 SETTLEMENT the exception of an area of Safeguarded Land to the of the district’s settlements relative to one another. This TIER 2 SETTLEMENT south of the village. In the context set out above it is TIER 3 SETTLEMENT has involved a high level assessment of the services and clear that further release of Green Belt land is required TIER 4 SETTLEMENT facilities in each rural settlement, as well as sustainable to assist in the delivery of the housing requirement in RAILWAY STATION transport links to higher order services, such as MOTORWAYS sustainable locations such as Codsall. In addition, employment, retail centres and hospitals. URBAN AREA further housing growth within the village will be GREEN BELT required in the longer term, beyond the proposed plan OPEN COUNTRYSIDE period and therefore further safeguarded land should STRATEGIC EMPLOYMENT SITES be identified within Codsall to allow for future needs to be met. SOUTH STAFFORDSHIRE PLAN SHOWING SETTLEMENT TIRES (FROM ISSUES AND OPTIONS OCTOBER 2018)

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CASE FOR GREEN BELT RELEASE

2.17 Paragraph 136 of the NPPF confirms that:

“Once established, Green Belt boundaries should on ly

be altered where exceptional circumstances are ful ly evidenced and justified, through the preparation o r TO ASSIST IN SAFEGUARDING THE COUNTRYSIDE TO PREESRVE THE SETTING AND SPECIAL updating of plans.” FROM ENCROACHMENT CHARACTER OF HISTORIC TOWNS

2.18 Given the need to accommodate an increased amount 2.21 By definition, development of any greenfield site 2.24 There are no listed buildings or other heritage assets of housing and employment land, South Staffordshire beyond the boundary of a settlement results in within the vicinity of the site. Similarly, Codsall as a District Council concluded there were exceptional encroachment into the countryside. Nevertheless, as set settlement has a limited number of listed buildings, circumstances to release land from the Green Belt out above, the identified site boundaries align with located to the centre of the settlement and around St through the adoption of the Site Allocations Document existing residential or agricultural buildings to the Nicholas C of E Church. Codsall is accordingly not in September 2018. However, as part of undertaking the western edge of Codsall. There are therefore clear considered to constitute an ‘historic town’ in the context Local Plan Review, it remains that there is the need to urbanising features surrounding the site, reducing the of the NPPF. As such, the development of the site for consider the further release of Green Belt land, partly extent to which the site encroaches into the open residential purposes would not compromise the setting or countryside. special character of an historic town. due to South Staffordshire District Council’s obligations under the Duty-to-Cooperate with neighbouring Black 2.22 As set out above, the site’s western boundary is currently Country authorities. As such, in the context of defined by a mixture of features. The development of the TO ASSIST IN URBAN REGENERATION BY significant unmet development needs, exceptional site for residential purposes represents an opportunity to ENCOURAGING THE RECYCLING OF DERELICT AND circumstances exist to justify further release of Green strengthen this boundary to provide one which would Belt land. endure in the long-term, creating a clear transitional OTHER URBAN LAND arrangement between the urban area and the countryside. 2.19 The Local Plan Review Issues and Options document 2.25 Whilst the intention of this purpose is recognised, the confirms that a joint Green Belt review covering both 2.23 Lastly, the site is currently in private ownership and no Local Plan Review Issues and Options document acknowledges that there is insufficient brownfield land the Black Country and South Staffordshire is currently public rights of way exist across it. As such, the site does within South Staffordshire (and Codsall) to accommodate being prepared. This is anticipated to be published in not offer any opportunities for recreation. The Concept Plan illustrated later within this Vision Document includes identified development needs. As such, the development ‘early 2019’, to inform the Preferred Options version of significant areas of open space, particularly to the south- of the site would not prejudice the redevelopment of the Local Plan Review. east of the site, increasing opportunities for recreation and derelict or other urban land. 2.20 An assessment of Land at Strawmoor Lane against the promoting access into the countryside. purposes of the Green Belt (as defined at Paragraph 134 of the NPPF) is included below, to assist the Council with their consideration of the site:

LAND AT STRAWMOOR LANE | CODSALL 999 “Planning policies and decisions should ensure that developments are visually attractive as a result of good architecture, layout and appropriate and effective landscaping ”

Para 127(b), NPPF 2019 `

03 THE SITE AND ITS SURROUNDING CONTEXT

Pre 1900/c. 1900

c.1920

c.1960

c.1970

c.1985

1990 onwards

1

THE SITE

2

PATTERN OF SURROUNDING BUILT ENVIRONMENT

IMAGES

1 Post office, shops and café on Station Road 3 2 The Crown Joules pub, Wood Road 3 Shopping parade, The Square

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03 THE SITE AND ITS SURROUNDING CONTEXT

THE SITE

3.1 Land at Strawmoor Lane adjoins the western edge of and two–storey development, and a mixture of 3.11 Codsall is close to significant new high quality job the urban area of the settlement, immediately north of detached, semi-detached and terraced dwellings. opportunities that continue to be created at i54 and the the Birmingham to Shrewsbury railway line; to the west Generally, the frontages are landscaped, with va r ying railway station provides frequent services to and south of a residential area lying between Wood set-backs. Birmingham and Shrewsbury. Road; and Moatbrook Lane. The site extends to 3.6 The existing development to the east of the main part 3.12 Codsall is well-placed geographically and through good approximately 17.7 hectares and comprises three pieces of the site comprises 1960s and ‘70s residential transport links to provide an appropriate location for of land managed as arable fields and pasture. development. meeting cross boundary pressures. Direct train links to

3.2 The site is generally flat with the lowest point located 3.7 The 1960s development (shaded green) comprises semi Birmingham and good links to the M54 and within the south of the site. -detached two– and single-storey dwellings with front Wolverhampton suggest a strong functional gardens enclosed by low brick walls, hedges and relationship exists between Codsall and the

SURROUNDING BUILT FORM shrubs. Dwellings are constructed in red facing brick conurbation, where current housing pressures are evidenced. 3.3 The main development parcel is surrounded by with red/brown plain tiles. existing dwellings to the north and to the east, while 3.8 The c.1970s development (shaded blue) comprises 3.13 Land at Strawmoor Lane, Codsall, is in a sustainable the smaller northern development parcel is bounded by detached two-storey dwellings; materials are a mixture location within close proximity to the village centre and existing residential development to the east, along Slate of red brick, pale red/buff brick and cream render, with Codsall railway station. The site is very well located to Lane. brown pantiles. Set backs are consistent, and gardens take advantage of local facilities within the centre that are typically used on a day-to-day/weekly basis, such 3.4 On the south-side of Moatbrook Lane, adjoining the are left open, with no boundary treatment. Parking is as convenience stores, post office, bank, dining and northern site boundary of the main parcel is a accommodated on plot. coffee facilities, surgery, dental practice and a range of scattering of existing dwellings comprising two pairs of 3.9 The later developments are less compactly built than schools. All of these services can be reached easily and semi-detached houses built c. 1960, (highlighted in the existing dwellings along Moatbrook Lane. quickly by foot from the site. green on the image to the left) and several older dwellings dating back to around the turn of the SURROUNDING AREA 3.14 The site provides an opportunity to deliver much century, including Moatbrook House (highlighted pink). needed housing, together with all necessary supporting 3.10 Codsall provides a good range of shops, including infrastructure. 3.5 The parcel of existing dwellings between Moatbrook supermarket, and community and health care facilities. Lane and Wood Road has developed gradually over South Staffordshire Council offices are based in Codsall, time. This gradual development has resulted in a and there are both middle and high schools and a piecemeal character. Existing dwellings fronting leisure centre. Codsall has a frequent bus service to Moatbrook Lane (north side), comprise a mixture of one Wolverhampton and has good access to the M54 motorway.

LAND AT STRAWMOOR LANE | CODSALL 11131333 “Planning policies and decisions should ensure that developments are sympathetic to local character and history, including the surrounding built environment and landscaping setting, while not preventing or discouraging appropriate innovation or change”

Para 127(c), NPPF 2019 04 ENVIRONMENTAL CONSIDERATIONS

LOCAL FACILITIES AND AMENITIES IN CODSALL

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04 ENVIRONMENTAL CONSIDERATIONS

INTRODUCTION

4.1 This section assesses the relevant environmental 4.6 Russell House provides GP facilities off Bakers Way at Amenity Distance considerations at the site. It demonstrates that there are an approximate 890m walk from the centre of the site no constraints that prevent the development of the site and Codsall Dental Practice is located on Bakers Co-operative Food 830m for a residential-led scheme. Gardens at about a 740m walk. Zen Spa and Beauty 850m PROXIMITY TO LOCAL FACILITIES 4.7 Bus service number 5 provides a frequent 7-day service between Wolverhampton and Codsall via Dunstall and The Crown Joules Public House 860m

4.2 The plan opposite indicates the location of the local Bilbrook (half-hourly or better on weekdays). The Russell House Doctors Surgery 890m facilities within Codsall. service is supplemented further by service 5A that runs mon-Sat on an approximate half-hourly frequency The Bull Public House 900m 4.3 St Nicholas CE First School is located at about a 1.4km along a slightly different route. Service 10B provides Nationwide Building Society 900m walk from the centre of the proposal site with a three services in each direction on weekdays between signalled crossing of Wood Lane/Baker’s Way provided Wolverhampton, Perton and Codsall. Lacey’s Bistro 915m en route with the final leg of the journey along Church Lloyds Pharmacy 925m Road. Codsall Middle School and St Christophers 4.8 Codsall railway station provides regular, frequent services between Birmingham New Street and Catholic Primary school can be reached further to the Post Office 925m east at around a 1.9km walk from the centre of the site. Shrewsbury via Wolverhampton via Wolverhampton Coffee Shop 955m Codsall Community High School is located off Elliotts and Telford Central amongst other stations. Lane at about a 2.0km walk; the leisure centre is located Codsall Fish Bar 955m alongside the school. Urban Hair and Beauty 1.0km 4.4 The post office is located in the centre of Codsall at about an 925m walk from the centre of the site. A St Nicholas CE (VC) First School 1.4km

number of local restaurants, takeaways, and public Codsall Village Hall 1.4km houses are located in the centre of Codsall at about an 900m-955m walk from the site. Codsall Community High School 2.0km

4.5 Several foodstores are available in the village along with ABC Early Learning & Childcare Centre 2.1km facilities such as pharmacies, banks, and other typical high street shops and services.

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IMAGES

1 View south along Stawmoor Lane 2 View south-east along Wood Road 3 View south along Slate Lane 4 Moatbrook Lane/Strawmoor Lane junction 5 Slate Lane/Moatbrook Lane junction 6 Wood Road/Slate Lane junction

ACCESS AND MOVEMENT

Local Highway Network

4.9 The main body of the proposal land is located on the western side of Codsall; fronting Moatbrook Lane to the north and Strawmoor Lane to the west. A railway line lies to the south of the development with housing lying beyond a treeline to the east. A smaller parcel of proposal land lies to the north of Moatbrook Lane, south of Wood Road, and west of Slate Lane.

4.10 The speed limit on Wood Road along the site frontage is 40mph, Slate Lane is subject to a 30mph speed limit, Strawmoor Lane and part of Moatbrook Lane are subject to the national speed limit with the majority of Moatbrook Lane that fronts the site being subject to a 30mph speed limit.

4.11 Strawmoor Lane is approx. 5.5m wide and has the nature of a country lane with verges present; no lighting or footways are currently provided. Strawmoor Lane turns first eastwards at Moatbrook Lane and then northwards at right angles to become Slate Lane; Slate Lane is relatively narrow in places at about 3.8m and has housing on its eastern side with frontage access to the lane; the lane is lit but no footways are present. 1 4.12 Wood Road forms part of the route from the site, through Codsall and Bilbrook, and towards the A449 Stafford Road. The route carries only modest traffic levels. Strawmoor Lane and Moatbrook Lane are lightly trafficked routes by any standard.

4.13 Staffordshire County Council (SCC) have been consulted through the official pre -application process to discuss the proposed access strategy and potential highway impacts of the proposed development site. Positive feedback has been received from SCC with regard to the access proposals. Furthermore, the potential scope of the Transport Assessment which would support any subsequent planning application has been agreed.

2 3

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Policy Considerations

4.13 The Staffordshire LTP 2011 covers the plan period 2011- 4.16 The content of this Vision Document for the proposed 4 2026 and has among its stated aims: development demonstrates that the location of the land is well placed to make use of existing local facilities and • Enabling economic growth without causing sustainable transport services/infrastructure with the congestion need for only limited mitigation works to provide connections from the site to these facilities, sustainable • Providing opportunities for residents and infrastructure, and sustainable services. visitors to access jobs, training and education

• Keeping the highway safe and serviceable 4.17 Any subsequent planning application will be supported whilst achieving value for money by a Travel Plan alongside a Transport Assessment. The

• Improving on our excellent safety record Travel Plan will address the policy considerations set out in the LTP and seek to promote the residential • Encouraging and providing for active travel development in a sustainable manner.

4.14 Policies 5.1 and 5.2 of the Plan address the promotion 4.18 The relevant national policy is set out in the National 5 of alternatives to private motor vehicles and Planning Policy Framework (NPPF) which states that: encouraging low-emitting vehicles and vehicle efficiency. “Development should only be prevented or refused o n transport grounds where the residual cumulative 4.15 Policies 6.1 and 6.2 deal with encouraging walking and impacts of development are severe.” cycling for health benefit reasons and helping residents to access services (sustainably) by integrating transport 4.19 We shall, of course, be aiming for the much higher and land use policies. Policy 6.4 aims at improving standards that that set out in local policy by Staffordshire’s road safety record and Policy 6.6 deals encouraging active modes of travel alongside public with reducing emissions from road transport. transport as realistic opportunities to private car use.

6

LAND AT STRAWMOOR LANE | CODSALL 11191999

Proposed Access Strategy

4.20 At a potential site capacity of up to 230 dwellings we are proposing an access strategy that extends Strawmoor Lane northwards to serve the northern parcel of land, meeting Wood Lane at a priority junction and providing a more attractive route to Wood Lane for traffic (rather than along Slate Lane) from the development proposal and elsewhere. To help enforce this, signs indicating ‘ motor vehicles prohibited except for access ’ are proposed to the western extent of Moatbrook Lane and on Slate Lane on its junction with Wood Road.

4.21 The main vehicle access to the major body of the development will be from Strawmoor Lane in the form of a priority junction, with Moatbrook Lane forming a priority crossroads junction with Strawmoor Lane and on through the northern development parcel to Wood Lane. A separate pedestrian access is provided to Moatbrook Lane in the northeast corner of the site. The access arrangements are indicated on the accompanying drawings to the left and right.

4.22 The site access points can accommodate a refuse lorry, which is typically the largest vehicle that might be expected to access site on a week-to-week basis.

4.23 The proposed development of around 230 dwellings w o u l d be expected to generate around 120 two-way peak hour vehicle trips; two vehicle movements per minute with the majority of traffic expected to head north along Strawmoor Lane. The site access strategy can easily accommodate such levels of traffic and the impact of the development traffic is such that it will be barely perceptible to existing road users on the local and wider highway network away from the site access.

4.24 The visibility splay requirements at the proposed site ac c e s s

junctions have been based on recorded traffic speeds and are PROPOSED SITE ACCESS STRATEGY OVERVIEW in line with guidance set out in Staffordshire County Council’s Residential Design Guide (Appendix A).

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HERITAGE AND ARCHAEOLOGY

4.25 Archaeological Desk Based and Built Heritage 4.28 The study site contains no evidence for remains of Statements have been undertaken which identify and Prehistoric date, and only very limited evidence has consider heritage assets within a 1 km search radius. been recovered from within the 1km search area These assessments draw together the available pertaining to Prehistoric activity. archaeological, historic, topographic and land-use 4.29 There are two records of Medieval activity within the information in order to clarify the heritage impacts study site: the remains of Moor Hall and Moat (see 1831 and below ground archaeological potential for the site. plan) and a Medieval padlock. In addition, the LiDAR 4.26 There are no designated heritage assets on the imagery indicates that the site formerly contained ridge proposed development site, and the proposed and furrow which may be of Medieval date. No remains development will have no impact upon the significance of Saxon/Early Medieval date area recorded within the of any designated heritage assets outside of the study study site on the HER. site. 4.30 Except for the southwest corner of the study site, the 4.27 The site forms a neutral element of the wider settings of site is considered to have a negligible potential for two of the identified built heritage assets: the Church of significant remains of Saxon/Early Medieval or Medieval St Nicholas (Grade II*) and the Codsall & Oaken date. The southwestern corner of the study site Conservation Area (designated 1973). However, the however is considered to have a high potential for proposed development of the site could be sensitively remains of Medieval date relating to the former Moor MONUMENT AND EVENT DATA designed to protect their respective significance. Hall and Moat. It should be noted that the current Therefore the proposed development of the site would Illustrative Masterplan for the proposed development cause no harm to the significance of any built heritage envisages limited development within the area of Moor assets. Hall and Moat.

VIEW EAST FROM STRAWMOOR LANE ACROSS SITE PLAN OF THE TOWNSHIP OF CODSALL, 1831

LAND AT STRAWMOOR LANE | CODSALL 22212111

LANDSCAPE AND VISUAL

Policy Context

4.31 The site is not subject to any national landscape designations. The site lies within the Green Belt.

4.32 The site is located within the South Staffordshire district, located to the north western edge of Wolverhampton and to the west of Codsall residential suburb. Applicable local policy objectives address the need to enhance the landscape of the Green Belt and the green infrastructure of the District.

4.33 There are no public footpaths running through or adjacent to the four fields; however, a network of Public Rights of Way are present across the wider landscape.

IMAGES 1 View facing south from Moatbrook Lane 2 View facing west from junction located at Wood Road and Slate Lane 3 View facing south west from Moatbrook Lane 4 View facing east from Strawmoor Lane

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Landscape Character

4.34 At a regional level, within the Staffordshire County Council Planning for Landscape Change SPD (2000), the site is identified as being located within the ‘Ancient Clay Farmlands’.

4.35 The key characteristics of the Ancient Clay Farmlands 4.36 Detracting features in the area identified by the SPD include: include the following:

• A gently rolling landform with localized meres and mosses • Busy main roads and motorway

• An irregular field pattern defined by ancient hedgerows • Powerlines

• Narrow winding, often sunken lanes • Large modern farm buildings

• Hedgerow damsons and occasional native black poplars • Industrial developments

• Marl pits and field ponds • Electrified railway line

• Dispersed settlement pattern of farmsteads and wayside • Urban edge dwellings • Improved and new commuter dwellings • Traditional red brick and clay tile buildings • Introduction of wire fencing for tock control associated with deteriorating field pattern

SiteSiteSite-Site ---SpecificSpecific Context 4.41 Development fronting Moatbrook Lane and Wood 4.37 PARCEL A: Bounded by dense hedgerow planting; the 4.39 To the south of the site lies the railway line and Road will respect the character of existing properties eastern boundary influenced by the existing residential associated vegetation. Strawmoor Lane bounds the that are set back from the road frontage, retaining edge of Codsall. Three of the four boundaries are western edge to parcel B and C with small fields good quality tree stock. surrounded by roads with access from Moatbrook Lane surrounded by dense vegetation to the east of parcel C along its southern boundary. This parcel comprises a and D. 4.42 Field parcels B, C and D are irregular-shaped and singular grassland field which slopes gently to the east expansive with a small number of internal hedgerows to 4.40 The hedgerow field boundaries along with hedgerow with no internal landscape features. separate them. Scattered field trees are located within tree planting provide containment and structure and parcels B and C. 4.38 The larger southern parcel comprises 3 irregular- are also characteristic features within the local shaped fields (B, C and D). The northern boundary is landscape. They will be retained and enhanced 4.43 Parcel C and D are divided by a ditch with associated influenced by existing properties off Moatbrook Lane, wherever possible to strengthen the contained nature vegetation. The Flood Zone covers a large part of although intervening hedgerows separate the site from of the site and filter the new development and existing Parcel C and D as shown on the Landscape the residential edge. Mature hedgerows and trees built edge. Opportunities and Constraints Plan. strongly distinguish the individual parcels, with a scattering of mature trees providing the only internal landscape features.

LAND AT STRAWMOOR LANE | CODSALL 22232333

Views

4.44 Both parcels relate visually to the existing settlement edge. The northern parcel lies adjacent to properties on either side of the road junction (see view 1), with dense hedgerow filtering views into the site. Slate Lane to the left of the viewpoint is a single track road that runs adjacent to the boundary vegetation of the northern parcel.

4.45 Viewpoint 2 shows a view from Moatbrook Lane facing east with filtered views across the site. There are no internal hedgerows or trees, with topography sloping gently to the east. The northern parcel is further Influenced by built form in the way of Wheatstone Lodge Farm, accessed via the gate shown in the view.

4.46 Viewpoint 3 shows the view from Moatbrook Lane facing south-east towards the southern parcel. The site land it slightly raised adjacent to the roadside, although bound by mature hedgerow and trees restricting views into the site itself.

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4.47 Viewpoint 4 is from the north-eastern corner of the main parcel looking south-west across the site. The residential influence is highlighted by the properties along Moatbrook Lane. All field parcels are bound by mature hedgerows and vegetation, although the site itself is expansive with no internal trees. The hedgerow along the eastern section of Moatbrook Lane is gappy and allows for clear views into the site.

4.48 Viewpoint 5 is from the western boundary of the main parcel; existing properties along Moatbrook Lane visibly providing a developed backdrop. The internal hedgerows are well-maintained and provide a strong distinction between parcels. The topography of the southern, larger parcel slopes gently towards the brook which dissects the site from east to west.

4.49 Viewpoint 6 is from the western boundary of the main, open field parcel, the southern extent of the site. Expensive views are possible with boundary vegetation providing a backdrop between existing properties to the east. The railway line lies to the right hand side of this view point, bound further by mature vegetation which restricts the possibility of any distant views towards the site.

IN SUMMARY

Overall, the site relates well to the existing residential edge of Codsall, with the proposed development providing no uncharacteristic or incongruous features. Views are limited and localized and all feature urban influences, with the railway line and associated vegetation to the south further restricting distant views.

LAND AT STRAWMOOR LANE | CODSALL 22252555

LANDSCAPE PLANNING ANALYSIS AND PUBLIC RIGHTS OF WAY

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4.50 The site is largely contained by development along Moatbrook Lane and Wood Road to the north, and the edge of Codsall to the east, placing the site within the built extents of the settlement. The parcel of land within the site to the west of Slate Lane is similarly well contained by roads that form robust boundaries. Development would not extend beyond the existing development of Moatbrook Lane and would be contained by the existing roads. Considering the above, any sprawl would be well contained within the existing fields, built edge and infrastructure network.

4.51 Trees along Woods Road and hedgerows and trees to fields bounding the site provide further physical and visual containment. To the south, the site is contained by the railway line and lies adjacent to the extents of existing residential on the edge of Codsall to the east, therefore the site does not prevent coalescence of Codsall Wood to the north and Oaken to the south. There are opportunities for the strengthening of the boundary along the railway line with additional tree belt/woodland planting.

4.52 The land between Moatbrook Lane and the railway line comprises agricultural fields including hedgerows and trees to field boundaries. To the east, tree belts and woodland provide separation with the adjacent built edge. Away from the influence of properties on Moatbrook Lane, the southern site area has a more rural character and sense of being in the countryside, although the railway line, passing trains and influence of the adjacent settlement place the site within an urban fringe/peri urban context. Whilst there are hedgerows and trees dividing the southern site area, these are degraded and gappy in places, with field trees indicating former field boundaries and railway line being open along much of its length. There are therefore opportunities for reinstating and enhancing field boundaries and providing new hedgerow, tree and woodland planting in ` this area to strengthen the landscape character and the physical and visual boundaries to the site at the interface with the wider landscape and Green Belt to the south. The development site therefore makes a limited contribution to Green Belt purposes.

LANDSCAPE OPPORTUNITIES AND CONTRAINTS

LAND AT STRAWMOOR LANE | CODSALL 22272777

FLOOD RISK AND DRAINAGE

4.53 The site is shown to be predominantly in Flood Zone 1, which is land considered to have a low probability of fluvial/tidal flooding. There are some lower areas of the site which are in Flood Zones 2 & 3 these are not proposed for development.

4.54 One ordinary water course is present, entering from the west and flowing eastwards, becoming a Main River on the eastern boundary.

4.55 No record of historic flooding on the site exists, however, anecdotal evidence suggests that the lowest parts of the site (i.e., those adjacent to the watercourse) are seasonally wet, which is to be expected. A sequential approach to the development layout is sufficient to reduce the risks relating to the watercourse.

4.56 The area is not considered to be at notable risk from groundwater-flooding a n d there are no small or large waterbodies that pose a risk to the site should they fail.

4.57 Tidal and canal sources are not considered to pose a risk due to the distance and terrain between the site and such features.

4.58 The topography of the site supports the use of gravity storm drainage, with a general fall towards existing watercourses.

4.59 It is anticipated that some foul drainage will require pumping. A pumping station will therefore be required on the site at a location which is to be determined based on the final layout requirements.

4.60 An initial surface water drainage strategy has been produced for the site and is incorporated within the indicative masterplan. It is proposed that on site attenuation is provided up to the 1 in 100 year plus climate change event, using sustainable drainage systems with a networks of swales and ponds p r o v i d i n g suitable flow conveyance, attenuation and a controlled outfall at greenfield runoff rates.

4.61 The drainage strategy has been developed with an aim of making parcels self- sufficient wherever possible to remove a reliance on large, site-wide infrastructure and to promote the interception of exceedance flows, working with the natural DRAINAGE STRATEGY PLAN topography to locate attenuation features in the low points of each parcel. 4.62 The development parcels and associated sustainable drainage infrastructure Parcel A Catchment Surface Water Discharge Route have been located so as to avoid encroachment into the flood zones as Parcel B Catchment Existing Foul Water Drainage presently shown on EA mapping. Pre-application advice has been sought from

Parcel C Catchment Proposed Surface Water Outfall Point the Lead Local Flood Authority who are accepting of these principles and the general strategy. There may be opportunity to provide further betterment along Existing Watercourse Proposed Foul Water Outfall Point Moatbrook Lane by capturing and diverting overland flows into the on site drainage, subject to further technical studies.

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ECOLOGY Designated Sites

4.63 An initial preliminary ecological appraisal and desk- 4.67 No statutorily designated sites were recorded within planting is proposed species commonly occurring locally based study was undertaken in August 2018, by 2km of the site and the closest site was over 4km away shall be used. Where losses of hedgerows, or individual RammSanderson. The purpose of the preliminary (Donington and Albringhton Local Nature Reserve) from tree removals cannot be avoided planting will be of a ecological appraisal was: the site boundary. “like for like or better” basis.

4.68 The closest non-statutory designated site was a 4.70 Areas of the site to the south are proposed for Green Biodiversity Alert Site (BAS). The site has been retained Infrastructure provision, which provides a corridor • To classify the habitat types on the proposed site due to the type of habitat (wet pasture) and plant through the site, linking the existing Moat Brook BAS, to • To evaluate any potential for protected species to be present diversity within the drain running through the BAS. Due the woodland and farmland to the west. The current to proximity of this site considerations will be taken into drain that flows into Moat Brook will be retained and • To identify any significant ecological impacts likely to result account, to ensure the site is not disturbed during and provides suitable commuting and foraging for several from the proposed development post construction. Reduction in footfall to this site shall different species. The features shall be retained and • To provide recommendations for further surveys that might be undertaken through solutions designed to reduce enhanced with additional native planting to buffer the be required pedestrian access to the BAS. ditch from the proposed development.

Opportunities for Enhancement 4.71 Other additional enhancements that can be provided include the incorporation of bat boxes and bird nest Habitats 4.69 The recently revised NPPF 2018 requires sites to deliver boxes. Implementation of hedgehog(/mammal) friendly biodiversity net gains and benefits. Therefore, additional 4.64 The site was dominated by arable fields and improved fencing and gaps in gravel boards will also be enhancements shall be provided within the development grassland bounded by hedgerow, drains and scattered implemented to prevent isolation and fragmentation for plan to achieve this objective. Where new landscape trees, with field margins of scrub and poor semi these species. improved grassland. No ponds were identified on the site, however there were eleven ponds identified within 500m of the site Several of these were beyond major Low Suitability Bat Trees dispersal barriers. Three ponds were identified that may High Suitability Bat Trees provide suitability for great crested newt (GCN). Moderate Suitability Bat Trees Site Boundary 4.65 The majority of habitats onsite are considered to be of Suitable Ditch for Water Vole low inherent ecological value. However, the dense continuous scrub hedgerows and trees are of ecological and intrinsic value at the site level. These habitats where possible shall be retained. Any of these habitats that will be lost shall be mitigated through landscape replanting.

Protected/Priority Species

4.66 The site offers potential for protected species, notably: bats, breeding birds, GCN, otter, water vole and white clawed crayfish dedicated surveys for these species will be undertaken to identify their presence and inform the scale of any required mitigation. Badger, reptiles and local biodiversity action plan (LBAP) species such as brown hare shall be mitigated for on site accordingly with sensitive vegetation management and precautionary methods of works during construction. ECOLOGICAL OPPORTUNITIES AND CONTRAINTS PLAN LAND AT STRAWMOOR LANE | CODSALL 22292999

KEYKEYKEY

SITE BOUNDARY

EXISTING TREES AND HEDGES

POTENTIAL ACCESS LOCATIONS

OPPORTUNITIES FOR HIGHWAY IMPROVEMENTS

EXISTING PUBLIC RIGHTS OF WAY

OPPORTUNITIES FOR FOOTPATH CONNECTIONS

RESIDENTIAL AMENITY CONSIDERATIONS

FLOOD ZONE

ELECTICITY CABLES AND CLEARANCE ZONE

INDICATIVE TOPOGRAPHY

POTENTIAL LAND TO BE ENHANCED AND RETAINED AS GREENBELT

POTENTIAL FOR ARCHAEOLOGICAL REMAINS OF MOORHALL AND MOAT

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SUMMARY OF ANALYSIS

4.72 Richborough Estates have considered landscape character, ecology, highways, flood risk and drainage, heritage and archaeology, and it has been 4.73 Principal considerations and opportunities that a development proposal should take into consideration are as follows: demonstrated that there are no constraints that would preclude development at the site. The analysis has shown: CONSIDERATIONS OPPORTUNTIES

• Site topography and associated high/low points; • To provide access into the site from existing road network • The site is well-located in terms of local facilities and (Strawmoor Lane) services, in particular to local bus and train services • Existing landscape comprising mainly hedgerows and trees at field boundaries • To create an attractive new walkable neighbourhood • The site access strategy can easily accommodate levels of traffic envisaged to be associated with the proposed • Areas of the site subject to surface water flooding • To create a high quality, distinctive and landscape led development; it is considered that the impact of such development supported by public open space, children’s • Ecological value of existing habitats development traffic will be barely perceptible to existing play, sports and community allotments • Existing electricity cables and associated nono----buildbuild road users on the wider highway network • To create a highly sustainable living place which offers a easements • There are no designated heritage assets on the proposed range of dwelling types, sizes and tenures and increases • Residential amenity of existing dwellings development site, and the proposed development will have housing choice no impact upon the significance of any designated heritage • Local vernacular and character of existing residential areas • To make efficient use of land, though the application of a assets outside the study area range of appropriate densities • Transitional location of the site between built up areas • The site relates well to the existing residential edge of and the wider countryside • To create development identity areas which draw upon local Codsall, with the proposed development providing no vernacular and complement existing character • Impact on the existing highway network uncharacteristic or incongruous features • Provide a fully interconnected landscape structure, based on • The potential for development to extend northnorth----westwardswestwards • Views are limited and localised and all feature urban retention of existing mature trees and hedgerows, and along Wood Road to cause the perceived visual enhancement where necessary influences, with the railway line and associated vegetation coalescence and merging with adjacent properties to the south further restricting distant views • Improvements to Strawmoor Lane/Moatbrook Lane junction • The development site makes a limited contribution to and provision of new link road between Moatbrook Lane Green Belt purposes and Wood Road • • The majority of habitats on site are considered to be of low Provision of new footpath network through public open space and connectivity to existing Public Rights of Way inherent ecological value

• Dense continuous scrub hedgerows and trees are of ecological and intrinsic value; these habitats will be retained wherever possible

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“Planning policies and decisions should ensure that developments establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit”

Para 127(d), NPPF 2019 32 LAND AT STRAWMOOR LANE | CODSALL

05 VISION FOR LAND AT STRAWMOOR LANE

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05 VISION, CONCEPT PLAN AND DESIGN PRINCIPLES

VISION FOR STRAWMOOR LANE MAIN DESIGN PRINCIPLES SUMMARY OF PROPOSALS:

• To produce a new living environment of the highest • Continuous northnorth----southsouth linear green corridor standard, with a clear recognisable identity which is • Continuous easteast----westwest linear green space corridor • complementary to the vernacular and character of Number of dwellings provided = Approx. 230 accommodating retained mature field boundary Codsall • landscaping Net Developable Area = 6.980 Ha (17.25 Acres) • To provide the right ingredients for a balanced andand • • Proposed central open space feature straddling easteast --- Approximate residential density = 33/34 dph sustainable new development, which provides a rangerange of west linear green space • Total Open Space Area = 10.740 Ha (26.540 Acres) high quality homes and a range of publicly accessibaccessiblele open spaces • Proposed pedestrian footpath connections

• To provide a range of new community infrastructure to • Proposed road framework linked for vehicle permeabipermeabilitylity PROPOSED COMMUNITY FACILTIES: benefit existing and new residents of Codsall alikealike • No vehicular access along Slate Lane (existing roadroadsideside • Allotments (approx. 0.5 Ha) • To establish safe, attractive and secure neighbourhoodsneighbourhoods,neighbourhoods , hedgerow to be retained and enhanced where • MultiMulti----useuse Games Area (MUGA) streets and places which promote social interactioninteraction and necessary) afford access and movement priority to pedestrians and • Local Equipped Area for Play (LEAP) • Highway improvements to Strawmoor Lane/Moatbrook cyclists Lane junction • Proposed parking for Allotments and MUGA • To apply the practical use of environmentally frienfriendlydly • Proposed footway link from site onto Moatbrook LanLanee technology and techniques through the development, with the emphasis on carbon reduction, energyenergy----savingsaving • New continuous footpath within site along StrawmoorStrawmoor PROPOSED HIGHWAY IMPROVEMENTS: and the avoidance of waste Lane frontage • Strawmoor Lane/Moatbrook Lane junction • To provide a locallylocally----inspiredinspired and meaningful new green • Existing landscape to be retained and enhanced wherwheree improvements space network which enhances the character of the ssiteite necessary • New road link (as northwards ‘extension’ of Strawmoor and natural environment and creates a robust and • Proposed surface water attenuation (to incorporate Lane) between Moatbrook Lane and Wood Road) enduring new Green Belt boundary enduring new Green Belt boundary permanent wet features and opportunities for ecologecologicalical • Proposed footway link onto Moatbrook Lane • To create a place which will enhance the attractionattraction of and biodiversity enhancements) Codsall as a place to live, incorporating aspects ooff local • New continuous footpath within site along Strawmoor Codsall as a place to live, incorporating aspects of local • Continuation of building frontage along Moatbrook LLaneane character, landscape, heritage, visual amenity and Lane frontage • biodiversity Proposed areas for play, including ‘Multi Use GamesGames Area’ and ‘Local Equipped Area for Play’

• Proposed allotments and associated parking facilitifacilitieses

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