south staffordshire site allocations document · 2017-03-10 · without the written consent of...

Bloor Homes Land off Pendeford Mill Lane, Bilbrook South Staffordshire Site Allocations Document Publication Plan


CONTENTS:

Page No:

1. INTRODUCTION 1

2. PLANNING POLICY CONTEXT 2

3. METHODOLOGY AND SITE SELECTION 10

4. BILBROOK 11

5. LAND AT PENDEFORD MILL LANE, BILBROOK 13

6. CONCLUSION 24

APPENDICES:

APPENDIX 1: SITE PLAN

APPENDIX 2: ILLUSTRATIVE MASTERPLAN - PHASE 1

APPENDIX 3: ILLUSTRATIVE MASTERPLAN - PHASE 2

APPENDIX 4: TECHNICAL NOTE ON FLOOD RISK

APPENDIX 5: TECHNICAL NOTE ON ECOLOGY

APPENDIX 6: TECHNICAL NOTE ON HIGHWAYS



1. INTRODUCTION

1.1 These representations are made by Pegasus Group on behalf of Bloor Homes

Limited to the South Staffordshire Site Allocations Document (SAD) ‘Publication’

Consultation. This representation relates to land off Pendeford Mill Lane, Bilbrook

(Site Ref: 443) which is within the control of Bloor Homes (Appendix 1).

1.2 These representations respond to the emerging policies and allocations, having

regard to the national and local policy context. The representations also provide

comment in respect of the evidence base that underpins the emerging Site

Allocations Document and the methodology and approach to site selection,

making reference to representations submitted on behalf of Bloor Homes at

earlier stages in the formulation of the Plan.

1.3 The representations are framed in the context of the requirements of the South

Staffordshire SAD to be legally compliant and sound. The tests of soundness are

set out in the National Planning Policy Framework (NPPF), paragraph 182. For a

Plan to be sound it must be:

Positively Prepared – the plan should be prepared on a strategy which

seeks to meet objectively assessed development and infrastructure

requirements, including unmet requirements from neighbouring authorities

where it is reasonable to do so and consistent with achieving sustainable

development;

Justified – the plan should be the most appropriate strategy, when

considered against the reasonable alternatives, based on proportionate

evidence;

Effective – the plan should be deliverable over its period and based on

effective joint working on cross boundary strategic priorities; and

Consistent with National Policy – the plan should enable the delivery of

sustainable development in accordance with the policies in the Framework.

1.4 The representations also have regard to the Government’s recently published

White Paper which places emphasis on planning for the right number of homes in

the right places, in particular making enough land available and assessing

housing requirements.



2. PLANNING POLICY CONTEXT

2.1 It is recognised that the SAD is intended to deliver the spatial strategy set out in

the Core Strategy, adopted by the Council in December 2012. The Core Strategy

sets out a hierarchy of settlements and a spatial strategy of dispersing growth

across the District, with the majority of development being focussed to the Main

Service Villages (MSV), which includes Bilbrook within Locality Area 4 (Central

Area).

2.2 Within these villages a choice of housing will be delivered to meet local needs,

whilst recognising the constraints that impact upon the District, including

affordable housing, with extra care and specialist housing being regarded as a

priority. The Core Strategy recognises that development to meet the Districts

housing need will be required outside the existing development boundaries of a

number of settlements. Core Policy 1 of the Core Strategy confirms that Green

Belt release will be required around some of the villages to deliver the housing

numbers allocated within Core Policy 6.

Housing Requirement

2.3 The Core Strategy identifies, through Core Policy 6 (Housing Delivery) a minimum

requirement to deliver 3,850 net new homes within the District between 2006

and 2028. This equates to delivery of 175 new homes per annum. Core Policy 6

then provides greater detail as to how the housing requirement will be delivered

across the Locality Areas. This includes the provision of a minimum of 515

dwellings within Locality Area 4 within which Bilbrook is located. Of this

requirement for Locality Area 4, a minimum of 105 dwellings are to be allocated

within or adjacent to Bilbrook.

2.4 It is recognised that net housing completion rates within the Plan period have

often exceeded the annual minimum requirement established through the Core

Strategy, however site opportunities outside of the Green Belt are becoming

significantly diminished.

2.5 In addition to the reduction in deliverable supply, concern is raised that the

housing requirement contained within the Core Strategy has not been informed

by the consideration of the full objectively assessed housing need (FOAN) for the

District. Instead, the Core Strategy requirement has been derived from the West

Midlands Regional Spatial Strategy (WMRSS) Phase Two Revision Panel Report.



2.6 The Government’s imperative to boost significantly the supply of housing is set

out clearly in paragraph 47 of the National Planning Policy Framework (NPPF).

This requires local planning authorities to ensure their local plans meet the full,

objectively assessed needs for market and affordable housing in the housing

market area, consistent with the policies set out in the Framework.

2.7 In relation to establishing a housing requirement, paragraphs 50, 158 and 159 of

the NPPF set out a number of matters which should be taken into account. Local

Planning Authorities should ensure that their assessment of, and strategies for

housing, employment and other uses are integrated and they take full account of

relevant market and economic signals. In order to assess full housing needs,

there is a need to take account of evidence of current and future demographic

trends, market trends and the needs of different groups in the community.

Paragraph 159 explains that this means:

Meeting household and population projections, taking account of migration

and demographic change;

Addressing the need for all types of housing including affordable housing

and the need of different groups in the community;

Catering for housing demand and the scale of housing to meet this demand.

2.8 On 6 March 2014 the Department for Communities and Local Government (CLG)

launched the Planning Practice Guidance (PPG). This was accompanied by a

Written Ministerial Statement which included a list of the previous planning

practice guidance documents cancelled when the website was launched.

2.9 The PPG seeks to explain further elements set out in the NPPF. With respect to

the objective assessment of housing need, it makes the following points amongst

others:

Household projections provide the starting point of overall housing need;

They may require adjustment for example to reflect previously suppressed

household formation rates; and

It is relevant to take account of the likely change in job numbers.



2.10 The recently published White Paper recognises that over 40% of local planning

authorities do not have a plan that meets the projected growth in households in

their area. South Staffordshire District Council falls into this category.

2.11 It is understood that the Council, in conjunction with the Black Country

Authorities, has now undertaken a SHMA to consider the Full Objectively Assessed

Need (FOAN) for the period 2016 to 2036, however this work remains

unpublished and the FOAN remains unestablished. It is noted that the Council is

instead seeking to rely on the minimum housing requirement of 175 dpa

identified through the adopted Core Strategy. Whilst there is likely to be a

significant level of criticism raised that this element of the evidence base is

missing, it is clear that land needs to be taken out of the Green Belt as soon as

possible to boost and enable a continuous supply of housing to meet needs in the

short term. Therefore, the production of the SAD provides the most expeditious

route to significantly boosting housing land supply in line with Government policy.

2.12 Whilst the production of this second tier Local Plan is supported as a mechanism

by which to remove land from the Green Belt and boost housing land supply

within the immediate future, progression of the SAD should not delay the

publication of the Joint SHMA or be at the expense of an early review of the Local

Plan. It is necessary for the SAD to set out a clear commitment in policy to

establishing the FOAN and reviewing the spatial development strategy for

meeting this requirement and clear milestones for undertaking this work.

2.13 Proposed Policy SAD 1 provides a commitment to undertake an early review of

the Local Plan. This review is to be informed by the consideration of the FOAN

and the distribution of any housing shortfall across the wider Housing Market

Area. This approach is supported by Bloor Homes, however, the policy itself

needs to provide clarity and certainty in respect of the following:

The date for when the FOAN is to be established;

The date by which a Memorandum of Understanding to deal with the

distribution of growth and unmet need for the Greater Birmingham Housing

Market Area will be signed; and

The date for adoption of an updated Local Plan

2.14 Whilst paragraph 6.11 of the Publication Plan establishes an ‘aim’ to adopt a New

Local Plan for South Staffordshire by 2022, this commitment should be



strengthened and incorporated within a redrafted version of Policy SAD1 to

ensure that the FOAN is established and any unmet housing need that is

determined through a review of the appropriate housing requirement can be

delivered expeditiously.

2.15 It is not considered necessary to link the timescales of the Local Plan review as a

whole to that of the Black Country Core Strategy as set out at paragraph 6.14.

Whilst it is appropriate to work collaboratively with other authorities in the

preparation of an evidence base, the South Staffordshire District Council Local

Plan Review should be brought forward without delay and should not be

constrained by the timing of other emerging plans, the timing of which is outside

the control of South Staffordshire District Council.

2.16 The timescales for such a review should instead be aligned to the evidence that

exists of unmet needs across the Greater Birmingham Housing Market Area

(including South Staffordshire) and the adopted Birmingham Development Plan

(BDP).

2.17 Council’s reference to the emerging cross boundary evidence being undertaken in

respect of the Birmingham Housing Market Area is welcomed. It is relevant that

there will be a shortfall in housing provision within the Greater Birmingham

Housing Market Area (HMA), within which South Staffordshire falls. This is clearly

evidenced in the Joint Housing Study commissioned by the GBSLEP and Black

Country Authorities.

2.18 The issue of housing need arising in Birmingham which cannot be met within the

city’s boundaries is not a new issue historically. In its recent iteration, it has been

clear for at least 5 years that there is a significant level of unmet housing need

arising in Birmingham for which provision should be made. This unmet need is

the single largest component of housing growth in the West Midlands, and is a

key driver in the growth of the region generally.

2.19 The scale of the unmet need, whilst not confirmed until very recently, has been

known for some time. This situation led to the agreement between Birmingham

City Council and those Councils in the Housing Market Area (HMA) whose

emerging plans were under examination at the time, that the matter could be

dealt with subsequent to the adoption of these plans. The use of a policy which

promised an early review of the plans from those Councils that might contribute



to meeting the unmet need became the accepted method of dealing with the

emerging issue of the unmet housing needs of Birmingham.

2.20 The Birmingham Development Plan (BDP) was adopted on 10th January 2017. Its

adoption has given very significant weight to a housing deficit in terms of un-met

need of 37,900 dwellings over the period 2011-2031. The BDP also commits

Birmingham City Council to working actively with neighbouring Councils through

the Duty to Cooperate to ensure that appropriate provision is made elsewhere

within the HMA to meet the shortfall of 37,900 dwellings.

2.21 The BDP also places detailed and significant requirements on the City Council, in

Policy TP48, setting out how this active involvement in the provision and delivery

of the 37,900 should be satisfied. It states:

The Council will also play an active role in promoting, and

monitor progress in, the provision and delivery of the

37,900 homes required elsewhere in the Greater

Birmingham Housing Market Area to meet the shortfall in

the city. This will focus on:

The progress of neighbouring Councils in undertaking

Local Plan reviews to deliver housing growth to meet

Birmingham’s needs.

The progress of neighbouring Councils in delivering

the housing targets set out in their plans.

The extent to which a 5 year housing land supply is

maintained in neighbouring areas.

2.22 Policy TP48 from the BDP then spells out the consequences of the failure of

neighbouring Councils to plan for this unmet need, in terms of the potential

implications for the City itself:

If it becomes clear that progress is falling short of the level

required, the Council will undertake a review of the reasons

for this, and if this indicates that it is necessary to reassess

the capacity for housing provision in Birmingham, a full or

partial review of this Plan will be undertaken.

2.23 Finally, Policy TP48 sets out key indicators which would trigger this, including:

Failure of a relevant Council to submit a replacement or

revised Local Plan, providing an appropriate contribution

towards Birmingham’s housing needs, for examination within

3 years of the adoption of this Plan.



2.24 Therefore, it is fundamentally important that Policy SAD 1 be redrafted to

explicitly commit the Council to submit a replacement or revised Local Plan for

examination by January 2020 and to incorporate an appropriate contribution

towards Birmingham’s housing needs. This commitment will also assist in

ensuring that homes can be delivered within South Staffordshire to meet the

identified unmet housing needs by 2031 as set out in the currently drafted Policy

SAD1.

Housing Supply

2.25 Policy SAD2 (the Housing Allocations) identifies the proposed housing allocations

that are intended to deliver the housing requirement and spatial distribution of

housing established within the Core Strategy.

2.26 The Housing Background Topic Paper that accompanies the Publication Plan sets

out the housing land supply position at 1st April 2016, identifying completions of

2,450 new homes since 2006; a committed supply of 1,006 new homes; and a

residual requirement to identify land for the delivery of 394 homes to 2028.

2.27 The proposed allocations set out in Policy SAD2 are assumed to be capable of

delivering a minimum of 891 homes. Taken at face value, the proposed

allocations provide an oversupply of 497 dwellings over the Plan period, however

in reality some of these allocations may not result in a start or could be delayed

to such an extent that delivery is pushed back beyond the Plan period. For

example, landowners may not be willing to sell a site as the price that can be

achieved is not what they want; a developer cannot secure finance or meet the

terms of an option; there are supply chain constraints that hinder a site; or, there

are unexpected constraints that render a site undeliverable.

2.28 The SAD provides an opportunity to provide a robust contingency to not only

ensure delivery of the housing requirement established through the Core

Strategy, but also to provide an uplift in housing delivery, over and above the

minimum requirement established in the Core Strategy. This opportunity would

provide the benefit of identifying additional housing land at a much earlier point

in time than that which would result through a review of the Local Plan, providing

much needed flexibility in the supply and ensuring a plan led approach can be

maintained within the District upon publication of the SHMA and establishment of

the FOAN.



2.29 Such flexibility could be provided through the introduction of reserve sites. This is

an approach that has been endorsed by Inspector’s elsewhere, including within

the Stratford on Avon Core Strategy. The Stratford on Avon Core Strategy makes

provision, through Policy CS16 (Housing Development) to identify ‘Reserve

Housing Sites’ through the Site Allocations Plan that have the capacity to deliver

up to 20% of the total housing requirement within the Plan period. Bloor Homes

consider this to be a pragmatic approach in providing flexibility to ensure housing

needs are met and provides additional resilience in the Plan in case slippage is

experienced through the Local Plan review process.

2.30 It is noted that the Council is currently unable to identify a five year housing land

supply and this is highlighted in the Policy Team’s response to the recent planning

application at Hobnock Road, Essington:

Whilst 5 years’ worth of housing supply can be demonstrated

against the Core Strategy housing requirement, and as at

31st March 2016 the Council had oversupplied its target by

700 dwellings, this requirement figure is not based upon an

assessment of the full objectively assessed needs of the

housing market area, as required by NPPF paragraph 47.

Therefore, with regard to the PPG and NPPF, it cannot be

considered an up-to-date housing requirement for the

purposes of measuring housing supply. As a result, the

Council is unable to robustly demonstrate a 5 year supply of

housing land to meet the requirements of paragraph 47 of

the NPPF.

2.31 The scale of uplift should be informed by the evidence that is available. The most

up to date information that is currently published is that which is contained within

the GBSLEP and Black Country Joint Housing Study. This identifies, based on

demographic projections alone, a requirement for 208 dwellings per annum. Bloor

Homes consider that this level of uplift can be provided within the District,

without undermining the spatial development strategy set out in the adopted

Core Strategy.

Green Belt

2.32 The spatial strategy for South Staffordshire requires the removal of land from the

Green Belt. Green Belt release is required as soon as possible to ensure a

continuous supply of housing land is available. Without Green Belt release in the

immediate future, the Council’s ability to demonstrate a rolling five year supply of

housing land (including appropriate buffer) will be significantly diminished. Land

at Engleton Lane, Brewood is a site that is available now and deliverable.



2.33 In addition, the Core Strategy, through Policy GB2, identifies the requirement to

allocate safeguarded land to meet the longer term needs of the District beyond

the current plan period (post 2028). This equates to the equivalent of 10 years

supply of dwellings (based on the Core Strategy requirement of 175 dwellings per

annum). The National Planning Policy Framework (NPPF) makes it clear that

changes to the Green Belt boundary can only be made through the review of a

Local Plan, as such it is entirely appropriate for the Council to be considering the

Green Belt through the SAD. Paragraph 83 of the Framework is clear that should

Green Belt boundaries be changed regard should be had for their permanence in

the long term, so that they are capable of enduring beyond the current plan

period. For these reasons the principle of identifying safeguarded sites, as set out

in Policy SAD3, is consistent with national policy and supported. However,

evidence suggests that an uplift should be applied to the housing land supply and

this should also be reflected in any longer term requirements.

2.34 The Publication Plan rectifies the flawed calculation utilised by the Council at

Preferred Options stage in determining the quantum of safeguarded land required

to ensure the delivery of 175 dwellings per annum over a ten year period beyond

the Plan. Bloor Homes supports the revised approach in assuming 30dph on a net

developable site area of 70% in calculating the quantum of safeguarded land

identified within the SAD. This approach is now consistent with the assumptions

utilised for calculating the housing yield that will be achieved within the proposed

housing allocations within the Plan period, having regard to the necessary open

space, highways and drainage infrastructure that would be required to support

residential development.

2.35 It should be noted that the White Paper sets out the Government’s proposals to

amend national policy to make it clear that plans and development proposals

should make efficient use of land. Whilst an assumption of 30dph on a net

developable site area of 70% is supported as a sensible and conservative

approach in calculating the potential housing yield that can be achieved, this

should not prevent a higher density being realised, particularly with the Council’s

current emphasis on the provision of smaller homes.



3. METHODOLOGY AND SITE SELECTION

3.1 South Staffordshire District Council have published, alongside the Publication

Plan, a Methodology Paper and a Site Selection and Discounted Sites Paper which

demonstrates how the proposed allocations have been chosen.

3.2 The Methodology Paper details the approach that has been taken by the Council

in arriving at the proposed allocations. The process has been robust and allowed

a number of opportunities for stakeholder consultation and evidence gathering

which has supported the emergence of the selected sites.

3.3 Bloor Homes generally support the methodology as set out in the Methodology

Paper. Each site has been scored against a number of criteria as part of the tier 1

site selection, then those sites with the higher scoring have been progressed to

tier 2 where a qualitative assessment has been undertaken to identify the

preferred options. This has resulted in the ‘sound’ sites in Bilbrook being

identified, including land off Pendeford Mill Lane, Bilbrook (identified as site 443).

3.4 Land off Pendeford Mill Lane, Bilbrook is included within the ‘Site Assessment and

Discounted Sites’ paper at page 11, identified as site 443. The assessment

confirms that the site progressed through the first tier of assessment. Following

the tier 2 assessment it is concluded that part of the site should be allocated for

residential development to meet the entire housing need for Bilbrook within the

plan period. It is also considered that a proportion of the site will also meet

Bilbrook’s proposed safeguarded land requirement.

3.5 Whilst the Site Assessment and Discounted Sites Paper considers that for Bilbrook

no site outperformed another through the tier one assessment it is clear from the

RAG (Red-Amber-Green) assessment that land at Pendeford Mill Lane scored well

in comparison to other sites. This provides a clear evidence-based illustration of

how the site has been selected in part as a proposed allocation, with further land

identified as safeguarded to meet longer term development need. This

demonstrates that the process thus far has been positively prepared, justified and

effective.



4. BILBROOK

4.1 The Core Strategy splits the District into a number of locality areas with each

locality area having its own vision.

4.2 Bilbrook is identified as a Main Service Village within locality area four. These

villages represent the highest order settlement within the Council’s settlement

hierarchy and are ‘the main focus for housing growth, employment development

and service provision’ as established by Core Policy 1 (The Spatial Strategy).

These settlements are identified as delivering approximately 90% of the District’s

housing growth within the Plan period. Bloor Homes support this proportion of

growth to the Main Service Villages.

4.3 The Main Service Villages are considered to be the most sustainable locations in

terms of the level of services and facilities that are present within the

settlements. These locations are considered to represent the best opportunity for

delivering growth that utilises and consolidates existing physical, social and green

infrastructure.

4.4 Chapter 7 of the Preferred Options Document provides detail on the proposed

allocations which will meet the identified housing numbers for each settlement.

The Core Strategy allocated the provision of a minimum of 105 dwellings for

Bilbrook between 2010 and 2028. The Publication Plan refines this requirement

taking account of completions and commitments which have been achieved since

between 2010 and December 2015. For Bilbrook this means a refined

requirement of 102 dwellings. It is important however that the requirements

continue to be expressed as a minimum given that the Core Strategy housing

requirement is based on historic evidence which does not reflect the FOAN.

4.5 Following the site selection process as detailed within the Methodology Paper and

Site Assessment and Discounted Sites Topic Paper, Policy SAD2 ‘The Preferred

Option Housing Allocations’ details the allocations which are proposed to meet the

residual housing requirement within South Staffordshire. In terms of the

allocation for Bilbrook the preferred option is land at Pendeford Mill Lane (in part)

which is allocated for a minimum of 102 dwellings.

4.6 The Core Strategy set out that safeguarded land to accommodate 10 years

housing supply would be allocated at Main and Local Service villages through the

site allocations document to provide certainty for development beyond 2028. As

one of the identified Main Service Villages Bloor Homes’ site at Pendeford Mill



Lane (in part) is identified within Policy SAD3 ‘Safeguarded Land for Longer Term

Needs’ as safeguarded land.

4.7 The identification of further safeguarded land at Bilbrook, to rectify the flawed

calculation utilised by the Council in determining the quantum of safeguarded

land required within the Preferred Options document is supported, however Bloor

Homes consider that this further provision should have been accommodated on

the balance of land that is available within Site 443 (Pendeford Mill Lane,

Bilbrook) to Barnhurst Lane and within the control of Bloor Homes.



5. LAND AT PENDEFORD MILL LANE, BILBROOK

5.1 Bloor Homes is in control of Land to the south of Pendeford Mill Lane, Bilbrook

which has been promoted for residential development. As has been detailed

above the site, in part, represents the Council’s proposed housing allocation at

Bilbrook, and further land has been identified as safeguarded land to meet longer

term development needs beyond the Plan period.

5.2 The site is located to the east of Bilbrook adjacent to the existing development

boundary. The site is bounded to the north by Pendeford Mill Lane which provides

good opportunities for vehicular and pedestrian access. To the south the extent of

the proposed allocation is defined by existing field boundaries while the western

most boundary abuts existing residential development. It should be noted that

Bloor Homes is also in control of land to the east of the proposed allocation,

which includes a parcel of safeguarded land identified by the Council, as well as

additional land beyond extending to Barnhurst Road, as identified on the plan

contained at Appendix 1.

5.3 The Site Assessment and Discounted Sites Paper demonstrates, on page 11 (Site

443), that the site has a low/medium impact on the natural and historic

environments and with regards to impact on environmental quality the site is

acceptable in principle with no quality issues. In landscape terms the site is to be

considered of low sensitivity due to its location adjacent to the existing settlement

boundary. With regards to the impact on land use and loss of facilities,

development on this site would result in the loss of greenfield

agricultural/grassland, however no other site in Bilbrook outperforms site 443 for

this criteria.

5.4 It is noted that the site is closely located to local amenities and facilities with

clear pedestrian routes. The assessment therefore considers that local amenities

in Bilbrook are well accessed on foot and by car from this site when compared to

other sites in Bilbrook. Appendix 1 of the SAD (page 61) identifies that the site is

approximately 0.5km from the village centre, 1.1km from Bilbrook railway station

and around 1.3km away from Codsall Community High School, all distances of

which are considered accessible by foot.

5.5 In addition, the site scores positively in respect of flooding and highways, with

only minor surface water flood risk concerns identified and minor highway works

required. These are matters which can be considered and overcome through a



detailed design stage. The illustrative layouts attached at Appendices 2 and 3

demonstrates a suitable access can be gained from Pendeford Mill Lane.

5.6 Further technical work has been commissioned by Bloor Homes to supplement the

information relied upon by the Council in considering Site 443 against the scoring

criteria. This is set out in summary below, with relevant technical information

appended to these representations.

Landscape Sensitivity

5.7 The Adopted Core Strategy (2012) sets out a number of landscape relevant

policies for the district. These include Policy OC1: Development in the Open

Countryside Beyond the West Midlands Green Belt; Core Policy 2: Protecting and

Enhancing the Natural and Historic Environment; Policy EQ4: Protecting and

Enhancing the Character and Appearance of the Landscape; and Policy EQ12:

Landscaping.

5.8 Core Strategy Strategic Objective 4 is to protect, conserve and enhance the

countryside, character and quality of the landscape and the diversity of wildlife

and habitats. In relation to landscape character, Core Policy EQ4 is central to this

and focuses on maintaining the intrinsic rural character and local distinctiveness

of the South Staffordshire landscape.

5.9 At a national level the site is located within the National Character Area Profile

61: Shropshire, Cheshire and Staffordshire Plain, as published by Natural England

(2014).

5.10 Landscape character at a local level is defined by Staffordshire’s landscape

character assessment: Planning for Landscape Change: Supplementary Planning

Guidance (2000). The site is located within the Sandstone Estatelands Landscape

Character Type (LCT).

5.11 South Staffordshire Council’s Landscape Sensitivity Study 2015 considers the

detailed landscape character of the landscape around main service villages,

including Bilbrook. The site is located within parcel BK4 and the study states:

“The LCP is reasonably well-contained visually but there are

urban influences from the settlement edge and Pendeford Mill

Lane, which is a main route in and out of the village. There is

also a large industrial site immediately beyond the canal to

the east. These elements reduce any sense of a strongly

rural landscape. Development would be relatively



unobtrusive and would relate well to the settlement pattern if

confined to the eastern part of the LCP.”

5.12 The study finds that parcel BK4s sensitivity to housing development is low/

medium (see Plate 1 below). In relation to potential for mitigation and

improvement of settlement edge the study states that any development should

link to the eastern settlement edge. Site 433 abuts the existing eastern

settlement edge, with the indicative schemes included at Appendices 2 and 3

demonstrating how development can be seamlessly integrated with the existing

settlement edge to provide a logical extension to Bilbrook.

Plate 1: Codsall & Bilbrook – Extract from Landscape Sensitivity Study

5.13 Landscape and visual constraints can be used to guide the development of a

proposal in a positive manner, often leading to opportunities and not just creating

absolute constraints to development. The constraints are considered to be:

the limited local PROW network, (providing recreational opportunities for

potential high sensitivity visual receptors); and

the location of the site within the Green Belt, which will have some influence

on the value of the local landscape.



5.14 Landscape and visual opportunities can be summarised as follows:

Notwithstanding that the site is located within Green Belt, there are no

overriding statutory landscape planning designations;

The location of the site on the eastern edge of Bilbrook and other urbanising

elements such as the commercial buildings to the east of the canal, which

reduces any sense of a strongly rural landscape and increases the sites

relationship with the settlement;

Existing vegetation and green infrastructure throughout the site, including

hedgerows, providing opportunities to enhance this through a

comprehensive landscape strategy; and

The presence of mature vegetation including the mature boundary

hedgerows along Pendeford Mill Lane and Barnhurst Lane, which will help to

minimise the visual envelope of the site and will contribute to the capacity

of the site to accommodate development.

5.15 The illustrative masterplans included within Appendices 2 and 3 provide an

indication as to how these landscape and visual opportunities can be incorporated

within a development proposal to the east of Bilbrook, including the retention of

the existing field pattern, the strengthening of existing green infrastructure and

the provision on new public open space, to minimise the visual envelope of the

site.

Impact on Green Belt

5.16 The South Staffordshire Partial Green Belt Review Method Statement (November

2016) sets out a review of parcels of land around main and local service villages

against the five purposes of the Green Belt set out in the National Planning Policy

Framework (NPPF). The western extent of the site is located within parcel 3(B). in

relation to parcel 3, the review document states that:

“Portions of the land within parcel 3 lie less than 500m from

Wolverhampton boundary at its southern edge, thereby

providing an important separating function. However, the

presence of a waterway and some significant pockets of

woodland between the settlements inhibit the encroachment

of some of the countryside between the two settlements. The

fields bordering the settlement edge make less of a

contribution, being over 500m from Wolverhampton and less

open having been compromised by residential dwellings on



the settlement edge. The narrower the gap, the greater the

contribution of the fields to the purposes; however, based on

the current width of the gap all the land between the

settlements is considered to make a considerable

contribution to the Green Belt purposes.”

5.17 Whilst the remainder of the site lies outside of parcel 3, the extent of land within

the control of Bloor Homes, including land up to Barnhurst Lane (identified at

Appendix 1) remains at least 500m from the built up edge of Wolverhampton.

5.18 In accordance with the NPPF, Green Belt boundaries should be defined clearly,

using physical features that are readily recognised and likely to be permanent. It

is considered that the Green Belt boundary, upon the inclusion of the additional

land to Barnhurst lane, would then encompass the industrial use to the east of

Barnhurst Lane. The landscape and green infrastructure strategy for the site

could also include new planting and public open space which would serve to break

down the scale of built form and provide further containment. These potential

mitigation measures, as identified within the illustrative masterplans included at

Appendices 2 and 3 will help to establish and enhance a robust landscaped

edge to the proposed development and provide a definitive boundary to the

future Green Belt.

5.19 Table 1, overleaf, below sets out a summary of the likely impacts on Green Belt

purpose, in landscape and visual terms, using the criteria set out by the South

Staffordshire Green Belt Review (2016). This assessment considers the extent of

land within the control of Bloor Homes as identified at Appendix 1.



Table 1: Green Belt Impact of Site 443

Green Belt purpose

Criteria Summary

To check the unrestricted sprawl of large built-up areas.

Is the parcel abutting the boundary of Wolverhampton, Dudley, Walsall or Cannock?

Does the parcel play a role in preventing ribbon development?

The site is located on the eastern edge of

Bilbrook and is contained to the west by the existing settlement edge and to the east by a road corridor, the Shropshire Union Canal and industrial land use. The sites mature green infrastructure boundaries serve to contain it both physically and visually.

To prevent neighbouring towns merging

into one another.

What is the distance to the nearest neighbouring settlement?

Does the parcel play a major role in maintaining separation? (This will partly be a function of the size of the parcel). Are there natural or man-made

features that could prevent settlements from merging with one another? (These could be outside the parcel itself).

The closest settlement in this location is the north-western extent of Wolverhampton.

Development of the site will represent a relatively small scale extension on the eastern edge of Bilbrook. Beyond the site to the south

and east there is an extensive area of open land (at least 500m) which serves to maintain separation. Overall, development of the site will not lead to coalescence (‘merging’) of neighbouring settlements.

To assist in

safeguarding the countryside from encroachment.

Has the parcel already been

affected by encroachment of built development within the parcel? Are there existing natural or manmade features / boundaries

that would prevent encroachment in the long term? (These could be

outside the parcel itself). Is there evidence of positive use of the countryside in this location (e.g. footpaths, bridleways, formal or informal sport and recreation)?

Development of the site will result in the retention of an area of open land in the context of the edge of Bilbrook. The site has already

been encroached upon by built development. The canal, road and industrial land use to the

east is likely to preclude development further east, therefore limiting the chance of encroachment beyond the site. There is no public access on site, nor is there any evidence to suggest informal use of the site for

recreation.

To preserve the setting and special character of historic towns.

Are there features of historic significance in the parcel or visible from the parcel? The site is not located near to any conservation

areas or other features of historic significance.

To assist in

urban regeneration,

by encouraging the recycling of derelict and other urban

land.

Does the settlement contain

significant areas of brownfield land?

The site is influenced by urbanising features

such as the road corridors, existing urban edge, the sewage works to the north and

industrial land uses to the east. It is considered that all areas of Green Belt by their nature and designation should contribute to the recycling of derelict and urban land as Green Belt is

generally a prohibitive designation where development is rarely acceptable, thus development is focused into urban areas.



Accessibility to Amenities

5.20 The summary of the sites second tier assessment highlights land off Pendeford

Mill Lane as being able to deliver sustainable development which is closely located

to existing facilities with the village. The site has excellent links to the strategic

highway network and local employment opportunities, including the i54 Business

Park. The SAD second tier assessment states that the western part of the site is

close to the village centre with clear pedestrian routes. Further to this the site is

of an appropriate size that it can meet the allocated housing requirement for

Bilbrook and provide significant benefits in terms of open space provision and

opportunities for community infrastructure. It is for these reasons that the council

identifies the western parcel of the wider site as an allocation.

Surface Water Flooding

5.21 Included as Appendix 4 is a technical note on flood risk in relation to the whole

of site 443. The technical note identifies that there is a very low risk of fluvial and

pluvial flood risk, and a low risk of groundwater flooding on this site. The

technical note also sets out how an appropriate development drainage strategy

for surface water could work on site, this includes the incorporation of SuDS. In

conclusion there are no overriding flood risk constraints to the allocation of this

site for development.

Highways Accessibility

5.22 In the Council’s assessment the site has scored a low/medium impact with

regards to highways and access. Included as Appendix 6 is a technical note on

highway access for this site. With regards to the proposed access strategy, it is

considered that the proposed allocated site would be developed prior to the

delivery of the safeguarded land to the east. The allocated site would therefore

require its own access. The safeguarded site would have a separate access that

could eventually be connected to the access on the allocated site within the site

via a loop road. The proposed access strategy for the allocated site comprises a

ghost island junction that has sufficient capacity to serve the minimum dwelling

requirement. The safeguarded site will be served by a new roundabout. The

highways strategy seeks to support additional dwellings, which would allow

‘headroom’ for future phases, including the additional land up to Barnhurst Lane

within Bloor Homes Ltd control, would also enable a range of development scales

and mixes to be considered.



5.23 The overall access strategy for the whole of site 443 has been reviewed by

Staffordshire County Council the local highway authority, who has confirmed that

it is acceptable to them in-principle.

5.24 Preliminary capacity assessments of the two proposed access junctions have been

undertaken to ensure that their layout would be suitable for possible future traffic

demands. The results show that the junctions would operate within capacity at all

times and would have sufficient capacity to accommodate a total development at

the site comprising around 400 dwellings and would also enable a range of

development scales and mixes to be considered.

5.25 The technical advice note on highways concludes that satisfactory vehicular

access to both sites can be achieved in a manner that would enable the proposed

development to be accessed in a safe and satisfactory manner by vehicles and

sustainable travel modes such as public transport, walking and cycling, subject to

local enhancements to the network.

Impact on the Natural Environment

5.26 The SAD Site Assessment and Discounted Sites Paper demonstrates, on page 11,

that the site has a low/medium impact upon the natural environment. Included as

Appendix 5 is an Ecological Constraints and Opportunities Report covering this

site. The report sets out a number of recommendations which include retention of

the hedgerow network and trees, within any development proposals, this will

provide retained habitat for a range of wildlife. The creation of new green

corridors and areas of open space throughout the study area as part of any

development proposals, along with the creation of new areas of species-rich

grassland, new native hedgerow planting, and tree planting, and the creation of

new ponds would create new opportunities for a range of wildlife.

5.27 It is considered that taking account of the recommendations in this report and

with an appropriate scheme/design any potential impacts on habitats and

protected species could likely be mitigated/compensated. It is likely to be possible

to demonstrate a net gain for biodiversity within the study area where

appropriate enhancement measures can be implemented. As such, there are no

overriding ecological constraints to the allocation of this land for development

purposes.



Deliverability

5.28 In terms of the sites deliverability, the Framework requires that a site is

available, in a suitable location for development, viable and be achievable within

the next five years if it is considered to be considered as a deliverable site. Bloor

Homes is in control of the site and has a clear intention to bring forward a

residential scheme as is illustrated on the Indicative Masterplans (Appendices 2

and 3). Subject to the sites allocation and removal from the Green Belt it is

anticipated that development can be brought forward in the short term and assist

in meeting the District’s housing requirement. For the avoidance of doubt, Bloor

Homes is a major national housebuilder with no funding or capacity constraints

that would delay the delivery of development on this site.

Indicative SAD2 Proposal

5.29 The Indicative Masterplan for the allocated site (Appendix 2) demonstrates that

a residential development comprising at least 102 dwellings can be

accommodated at a net density of 30dph. This provides confidence that the

minimum housing requirement for the remainder of the Plan period set out in

Policy SAD2 is deliverable. The allocated site would be served by a new proposed

access via Pendeford Mill Lane through the provision of a ghost island. The

illustrative masterplan demonstrates a soft development edge retaining the

existing hedgerows; a future link to the safeguarded land to the east; a green

corridor including public open space through the site; and also storm water

attenuation features (swales and ponds). It also includes a new frontage in line

with the existing building line on Pendeford Mill Lane.

Indicative SAD3 Proposal

5.30 The illustrative masterplan for the safeguarded land (Appendix 3), demonstrates

the provision of a new roundabout which would support a further 130 dwellings at

a net density of 30dph. Again like the indicative SAD2 proposal, the indicative

SAD3 proposal demonstrates a soft development edge retaining the existing

hedgerows; a link to the allocated site to the west; a green corridor including

public open space through the site; and also storm water attenuation features

(swales and ponds). It also includes a new frontage in line with the existing

building line on Pendeford Mill Lane.



5.31 As identified within Section 2 of this representation, Bloor Homes recommend

that reserve sites are identified within the SAD to provide additional resilience in

the Plan in case slippage is experienced through the Local Plan review process.

The land at Pendeford Mill Lane, currently identified as safeguarded within the

Publication Plan, would represent a logical reserve site, free of physical constraint

that could boost supply if necessary in the short term.

5.32 The need to explore a through road from Pendeford Mill Lane to Lane Green Road

to relieve traffic pressure on the village centre, as set out in the requirements on

page 61 of the Publication Plan does not appear to be supported by the published

evidence base or even identified as an issue at earlier stages within the plan

making process.

5.33 In addition, the requirement that the delivery of safeguarded land in Codsall and

Bilbrook may need to come forward in conjunction with the strategic delivery of a

new primary school to meet the primary education needs of both villages, also

does not appear to be supported by the published evidence base or has been

identified as an issue at earlier stages within the plan making process.

5.34 Whilst the indicative proposals would not exclude the provision of these

requirements, it will be necessary to explore these requirements in more detail to

ensure these relate to specific identified needs that are reasonably related to the

proposal.

Additional Land

5.35 In addition, given ongoing and rising housing needs, there is still a requirement

to identify further safeguarded land to ensure sufficient housing land supply

2028-2038. Further land for development can be accommodated within the area

controlled by Bloor Homes, namely land to the east of the currently identified

safeguarded site on Pendeford Mill Lane up to Barnhurst Road as shown on the

Site Location Plan enclosed as Appendix 1. This would form a logical further

extension of development as part of the wider comprehensive development

strategy at this location, subject to the site’s removal form the Green Belt, which

would assist meeting this identified shortfall. This is land that currently falls

outside the Council’s identified housing allocation and area of safeguarded land.

5.36 The Green Belt and landscape evidence that is set out above demonstrates that

the non-designated element of site 443 is suitable for development. With the



inclusion of the additional land it is considered that the green belt boundary

would then encompass the industrial use to the east of Barnhurst Lane. On this

basis it is considered appropriate to safeguard the additional lane up to Barnhurst

Lane.

Site Conclusions

5.37 Subject to the sites allocation and removal from the Green Belt it is anticipated

that development can be brought forward in the short term to assist in meeting

the District’s housing requirement and to provide the necessary flexibility in

supply.



6. CONCLUSION

6.1 Bloor Homes is in control of land off Pendeford Mill Lane, Bilbrook which is

identified as a proposed allocation for residential development of a minimum of

102 dwellings within the Council’s Publication Plan. The site is sustainably located

adjacent to Bilbrook which is identified as a Main Service Village within the

adopted Core Strategy and as such is the focus for a significant proportion of the

Districts growth.

6.2 The proposed allocation of this site is soundly based, having been selected

through the process detailed within the Council’s Methodology Paper. This has

demonstrated that the site at Pendeford Mill Lane is a sustainable option for the

future growth of Bilbrook both within this Plan period and beyond. The site scores

favourably against alternative options for the growth of Bilbrook and as such its

selection as a proposed allocation is entirely justified by the evidence.

6.3 The proposal to safeguard land to the east of the proposed allocation at

Pendeford Mill Lane is supported by Bloor Homes as ‘sound’ and represents a

suitable and sustainable location for meeting longer term development needs

within Bilbrook.

6.4 In addition, there is still a requirement to identify further safeguarded land for

future housing needs. It is considered that the additional land which extends up

to Barnhurst Lane to the east of the proposed safeguard land, which is also under

the control of Bloor Homes, provides a logical further extension to Bilbrook as

part of a wider development scheme along Pendeford Mill Lane. It is considered

that this additional land is included within the area of safeguarded land identified

to meet longer term development needs beyond the Plan period.

6.5 To conclude, as presently drafted, the Site Allocations Document contains areas

of unsoundness and Bloor Homes wish to express the following key points in

respect to the Publication document:

Policy SAD1 is unsound as currently drafted. To rectify this unsoundness and

to ensure the effectiveness of the plan making process, this policy should be

redrafted to explicitly commit the Council to submit a replacement or revised

Local Plan for examination by January 2020 and to incorporate an appropriate

contribution towards Birmingham’s housing needs, to align with the recently

adopted BDP.



It is necessary to an uplift in housing delivery, over and above the minimum

requirement established in the Core Strategy, to ensure flexibility in supply

and to allow for changes in circumstances.

The scale of uplift provided should be informed by the evidence that is

available now. The GBSLEP and Black Country Joint Housing Study identifies,

based on demographic projections alone, a requirement for 208 dwellings per

annum. Bloor Homes consider that this level of uplift can be provided within

the District, without undermining the spatial development strategy set out in

the adopted Core Strategy. The identification of Reserve Sites capable of

delivering up to 20% of the housing requirement would represent a

pragmatic solution to ensure flexibility and resilience. Land currently

identified as safeguarded land within the Publication Plan would represent an

appropriate Reserve Site.

Additional land has also been identified by Bloor Homes as being available to

the east of the proposed safeguarded land to meet longer term housing

requirement. This land is within the control of Bloor Homes. Technical

information submitted to supplement the Council’s evidence, demonstrates

that this further land represents the most appropriate site for increasing the

provision of safeguarded land within Bilbrook. This additional land should be

identified within Policy SAD3.



APPENDIX 1

SITE PLAN

LAND OFF PENDEFORD MILL LANE, BILBROOK - SITE LOCATION PLAN | www.pegasuspg.co.uk | TEAM/DRAWN BY: SB/CSM | APPROVED BY: CS | DATE:119/02/2016 | SCALE: 1:2500 @ A3 | DRWG: BIR.5025_04_1 I CLIENT: BLOOR HOMES MIDLANDS I

KEY

SITE LOCATION (44.26 ACRES / 17.91 HECTARES)

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APPENDIX 2

ILLUSTRATIVE MASTERPLAN PHASE 1

PENDEFORD MILL LANE

3

LAND OFF PENDEFORD MILL LANE, BILBROOK - PROPOSED ILLUSTRATIVE MASTERPLAN | www.pegasuspg.co.uk | TEAM/DRAWN BY: CLE/SB | APPROVED BY: CS | DATE: 29/10/2015 | SCALE: 1:2500 @ A3 | DRWG: BIR.5025_3_1 I CLIENT: BLOOR HOMES MIDLANDS I

KEY

SITE LOCATION

PROPOSED RESIDENTIAL DEVELOPMENT

PUBLIC OPEN SPACE INCLUDING SUDS

EXISTING VEGETATION TO BE REMOVED

PROPOSED VEGETATION

SUSTAINABLE URBAN DRAINAGE

RESIDENTIAL PRIMARY STREET

RESIDENTIAL SECONDARY STREET

KEY PRINCIPLES

1. PROPOSED VEHICULAR ACCESS VIA PENDEFORD MILL LANE;2. PRINCIPAL STREET;3. SOFT DEVELOPMENT EDGE RETAINING EXISTING HEDGEROW;4. LINK SAFEGUARDING POTENTIAL WIDER LAND;5. GREEN CORRIDOR (PUBLIC OPEN SPACE);6. GREEN INCORPORATING SUDS.7. KEY JUNCTURE REPLICATING EXISTING DEVELOPMENT PATTERNS; 8. STREET WITH OUTWARD VIEWS TOWARDS WIDER LANDSCAPE CONTEXT;9. LOCAL AREA PLAY;10. OUTWARD FACING FRONTAGES (ACHIEVING NATURAL SURVEILLANCE;11. EXISTING FIELD PATTERN RETAINED AND ENHANCED;12. STORM WATER ATTENUATION FEATURES (SWALES AND PONDS);13. NEW FRONTAGE IN LINE WITH EXISTING BUILDING LINE;14. INCREASED DEPTH OF REAR GARDENS TO ADDRESS RESIDENTIAL AMENITY OF EXISTING DWELLINGS.

SAFEGUARDED LAND

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POTENTIAL ACCESS FOR FUTURE DEVELOPMENT 4

SUBJECT TO SURVEY.



APPENDIX 3

ILLUSTRATIVE MASTERPLAN PHASE 2

PENDEFORD MILL LANE

3

LAND OFF PENDEFORD MILL LANE, BILBROOK - PROPOSED ILLUSTRATIVE MASTERPLAN PHASE 2 | www.pegasuspg.co.uk | TEAM/DRAWN BY: CLE/SB | APPROVED BY: CS | DATE: 29/10/2015 | SCALE: 1:2500 @ A3 | DRWG: BIR.5025_3_2 I CLIENT: BLOOR HOMES MIDLANDS I

KEY

SITE LOCATION

PUBLIC OPEN SPACE

EXISTING VEGETATION

PROPOSED VEGETATION

SUSTAINABLE URBAN DRAINAGE

RESIDENTIAL PRIMARY STREETS

RESIDENTIAL SECONDARY STREETS

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PROPOSED LINE OF GREEN BELT

KEY PRINCIPLES

1. PROPOSED VEHICULAR ACCESS VIA PENDEFORD MILL LANE;2. PRINCIPAL STREET;3. SOFT DEVELOPMENT EDGE RETAINING EXISTING HEDGEROW;4. STORM WATER ATTENUATION FEATURES (SWALES AND PONDS);5. GREEN CORRIDORS (PUBLIC OPEN SPACE);6. GREEN INCORPORATING SUDS.7. EXISTING FIELD PATTERN RETAINED AND ENHANCED AS GREEN CORRIDOR;8. STREET WITH OUTWARD VIEWS TOWARDS WIDER LANDSCAPE CONTEXT;9. LOCAL AREA FOR PLAY; AND10. OUTWARD FACING FRONTAGES (ACHIEVING NATURAL SURVEILLANCE.

PHASE 1

SUBJECT TO SURVEY.

PROPOSED RESIDENTIAL DEVELOPMENT



APPENDIX 4

TECHNICAL NOTE ON

FLOOD RISK

Flood Risk Statement 15081 Pendeford Mill Lane, Bilbrook Date: 20/2/17

Site Location

The study area, shown edged red,

comprises an allocation for housing (SAD2 443), an allocation for

safeguarded land (SAD3 443) and the balance of land controlled by Bloor

Homes Ltd to Barnhurst Lane. The area

is approximately 17.5Ha and is currently undeveloped land used predominantly

for grazing with no definable surface water drainage features.

The allocations will be accessed from Pendeford Mill Lane on the northern

boundary. The site falls generally from west to east with a height difference of

approximately 10m from its highest to lowest level.

Assessment of External Flood Risks

Fluvial Flood Risk Existing Flood to the Site

Environment Agency flood mapping indicates the

site lies wholly within Flood Zone 1, ie. With an annual probability of flooding from seas or rivers of

less than 1 in 1000

VERY LOW

Pluvial Flood Risk

Environment Agency flood mapping indicates the site lies outside of any pluvial flood routes and has

an annual probability of flooding from rainfall of less than 1 in 1000

VERY LOW

Groundwater Flood Risk

South Staffordshire Strategic Flood Risk Assessment (SS-SFRA) indicates elevated potential for ground water flooding in the South Staffordshire area, although there

are no recorded incidents near the site. Development proposals shall take reasonable design measures to mitigate

groundwater breaches to ensure no flood risk to any new properties.

LOW

Flood Risk Statement 15081 Pendeford Mill Lane, Bilbrook Date: 20/2/17

Flooding from Artificial Sources

There are no canals or impounded waterbodies within the vicinity of the site that pose a flood risk in

the event of a catastrophic breach.

VERY LOW

Flooding from Sewers

SS-SFRA records eight flooding incident due to sewers within the vicinity to the site, however the exact location, nature and severity of any incident is not recorded, for

data protection reasons.

Severn Trent Water (STW) are responsible for the maintenance of sewerage network in this area and existing blockage or capacity issues are resolved as part of their

ongoing capital improvements programme. Pre-development enquires to STW highlighted no existing capacity issues that might pose a flood risk to the

development.

VERY LOW

Development Drainage Strategy

Surface Water Drainage Strategy BGS Borehole data obtained under Open Government License indicates varied potential within subsoils

to discharge run-off to ground via infiltration.

Surface run-off from the development shall be restricted to greenfield equivalent discharge rates and

there is sufficient space afforded in the masterplan to accommodate open SUDS features to provide flood protection up to the 100year (plus climate change) critical storm event(s).

The outfall(s) from the site will either be made to ground, direct to the Shropshire Union Canal or to

the STW surface water sewer in Lane Green Road to the south west of the development site, with third

party agreement or under requisition by STW to their existing sewerage network.

Foul Water Drainage Strategy On-site sewers are to be designed and constructed to standards adoptable by STW. Sewers are to

discharge to the existing public sewer network where levels permit, with the remaining portion of development discharging to a new adoptable pump station located near the natural low point of the

site.

Pumped wastewater is to be lifted to a new outfall into the existing STW network at chambers 2202 or

2201. Pumped flow rates are subject to agreement with STW further to an impact assessment of the new development on their existing network.

There are several STW assets located within the site boundary that shall be respected or diverted as part of the development proposals.



APPENDIX 5

TECHNICAL NOTE ON

ECOLOGY

7136 Briefing Note.vf1 February 2017 Page 1

Farncombe House Farncombe Estate Broadway Worcestersh i re W R12 7LJ Tel : 01451 870767 Fax: 01451 870060 Emai l : in fo@ecologysolut ions.co.uk Web: www.ecologysolut ions.co.uk ___________________________________________________________________

PENDEFORD MILL LANE, BILBROOK ECOLOGICAL CONSTRAINTS & OPPORTUNITIES REPORT ___________________________________________________________________

Introduction

1. Ecology Solutions was commissioned by Bloor Homes to undertake an ecological appraisal, including desktop study and an Extended Phase 1 Habitat Survey of the land at Pendeford Mill Lane, Bilbrook, Staffordshire.

2. The Pendeford Mill Lane study area utilised by Ecology Solutions includes SAD2 443 housing site for 102 dwellings (minimum), SAD3 443 safeguarded site (6.2ha), and the balance of land controlled by Bloor Homes Ltd to Barnhurst Lane as illustrated on Plan ECO1. The study area is situated to the east of the village of Bilbrook, it is bordered to the north by Pendeford Mill Lane, to the east by Barnhurst Lane, to the west by the existing residential development of Bilbrook and to the south by agricultural land.

3. The purpose of this document is to explore ecological features that may act as constraints should a formal planning application be made with respect to these potential allocations. Survey Methodology

4. An Extended Phase 1 survey was carried out in August 2016 to ascertain the

general ecological value of the land within the study area and to identify the main habitats and associated plant species, with notes made on any fauna utilising the study area. An appraisal of the suitability of ecological features for use by protected species was also undertaken.

5. In order to compile up to date background information on the study area and its immediate surroundings Ecology Solutions contacted the Staffordshire Ecological Record (SER) and the Ecological Database for Birmingham and the Black Country EcoRecord. This information is referred to where appropriate.

6. Further information on designated sites and Priority Habitats from a wider search area was obtained from the online Multi-Agency Geographic Information for the Countryside (MAGIC)1 database.

1 http://magic.defra.gov.uk

e c o l o g y s o l u t i o n s f o r p l a n n e r s a n d d e v e l o p e r s


Desk Study Designated sites Statutory

7. The nearest statutory designated site is Smestow Valley LNR, which lies approximately 1.8km southeast of the study area. This LNR is designated for its pockets of woodland and meadow and its importance to birdlife. This LNR is separated from the study area by major and minor roads, existing residential development of Pendeford and open countryside and as such, it is considered there would be no adverse effects.

8. The nearest Site of Special Scientific Interest (SSSI) is Big Hyde Rough

(SSSI) which lies approximately 5.2km north of the study area. This SSSI is well separated from the study area by major and minor roads, including the M54, and open countryside and as such, it is considered there would be no adverse effects. Non-statutory

9. The nearest Site of Local Nature Conservation Importance (SLNCI) is the Shropshire Union Canal SLNCI that lies approximately 0.7km southeast of the study area at its nearest point. This SLNCI was selected for its important bird population. This SLNCI is separated from the study area by open countryside and Barnhurst Lane and as such it is considered there would be no direct adverse effects.

10. Consideration would need to be had to ensure no polluted run-off from the study area would enter the canal during construction or operation. This could likely be achieved easily through standard techniques. Such as interceptors, attenuation and good construction practices.

Habitats Overview

11. The following habitats were identified during the surveys:

Improved Grassland;

Cultivated Field;

Hedgerows and Scrub;

Trees;

Ruderal Vegetation;

Buildings;

Menage; and

Garden.

12. The locations of the habitats are shown on Plan ECO2.

13. The majority of the study area comprises improved grassland fields separated primarily by fences. The grassland fields are generally species-poor, in botanical terms. The grassland fields are grazed by a mix of horses and Cattle on a rotational basis. The hedgerows are generally located at the site boundaries (only a single hedge is present within the main body of the study area, (see H4 on Plan ECO2) and are also generally species-poor.



Improved Grassland

14. The improved grassland fields include species such as Perennial Rye-grass Lolium perenne, Creeping Bent Agrostis stolonifera, False Oat-grass Arrhenatherum elatius, Crested Dog’s-tail Cynosurus cristatus and Soft Brome Bromus hordeaceus. Herbaceous species are limited and generally restricted to species such as White Clover Trifolium repens, Dandelion Taraxacum officinale agg., Ribwort Plantain Plantago lanceolata, Creeping Buttercup Ranunculus repens and Broad-leaved Dock Rumex obtusifolius, with more rarely found Greater Plantain Plantago major, Yarrow Achillea millefolium, Hogweed Heracleum sphondylium, Spear Thistle Cirsium vulgare and Common Sorrel Rumex acetosa subsp. within some fields.

Cultivated Field

15. Species found within the cultivated field include Courgette, but also some wildflowers, such as Common Knapweed Centaurea nigra with large patches of Redshank Persicaria maculosa.

16. These fields are of limited ecological value in the context of the study area, comprising common and widespread species. Any losses to the species-poor improved grassland fields would be of limited ecological significance and retained areas / proposed public open spaces (informal) would provide an opportunity for significant ecological enhancements, such as through oversowing with a species-rich wildflower grassland mixture and implementation of an appropriate management regime.

Hedgerows and Scrub

17. Hedgerows within the study area generally form the boundary features. The hedgerows are all species-poor. The hedgerow structure varies, with some relatively wide and thick, although some are gappy and leggy (lacking suitable management).

18. Species present in the hedges include Hawthorn Crataegus monogyna, Field Maple Acer campestre, Blackthorn Prunus spinosa, Holly Ilex aquifolium, Elder Sambucus nigra and Bramble Rubus fruticosus agg.

19. In addition, there is an amenity hedgerow H9 comprising Leyland Cypress X Cupressocyparis leylandii separating existing development to the north, from the study area.

20. It is recommended that hedgerows, be retained wherever possible within any development proposals. Losses to any hedgerows, if applicable, would therefore be of limited ecological significance and opportunities would exist within the study area for mitigation and enhancements to this habitat through replacement / new native hedgerow planting of a length / area equal to or greater than that lost together with implementation of appropriate management to improve structure.

21. There are small areas of scrub and scattered scrub associated with the buildings and hedgerows H2 and H3. This habitat is of limited ecological value in terms of its species content, generally comprising Bramble. However, it is considered that this habitat provides some suitable foraging and nesting



opportunities for a range of birds and cover / foraging opportunities for Badgers Meles meles.

22. Any losses to this habitat would be of limited ecological significance. However, it is considered that any losses would be relatively simple to offset and the opportunity exists for ecological gains through new native shrub planting.

Trees

23. There are a number of individual trees within the study area, generally associated with boundary features. These trees are generally semi-mature / mature and comprise species such as Pedunculate Oak Quercus ruber, Elm Ulmus procera, Sycamore Acer pseudoplatanus and Ash Fraxinus excelsior. There are several mature hawthorn trees scattered throughout the study area.

24. These trees are of some intrinsic ecological value, and are considered to offer suitable nesting and foraging opportunities for birds and foraging / navigational opportunities for bats.

25. It is recommended that the mature and semi-mature trees be retained

wherever possible within any development proposals. Losses to trees, if applicable, would be of some ecological significance although opportunities would exist within the study area for mitigation and enhancements through replacement / new native tree planting (including large standard trees if necessary). Ruderal vegetation

26. There are ruderal margins running along the fence lines separating the horse grazed field, as well as small areas of ruderal vegetation scattered over the study area. There is also a large area of ruderal vegetation in field F10 species present include Ragwort, Common Nettle, Bramble and Hogweed. Buildings

27. There are several large farm buildings within the study area boundary. These were constructed of brick and corrugated metal, with corrugated metal sloping roofs. Miscellaneous

28. There are small areas of habitat that have no ecological value, these include garden and amenity grassland.

Desk Study

29. Information received from the SER and EcoRecord returned records of Bluebell Hyacinthoides non-scripta (a Schedule 8 species, protected from sale only) from 0.5km south of the study area in 1982, and records of the near threatened Common Cudweed Filago vulgaris were returned from 0.5km southeast of the study area in 2001.



Faunal Species Overview Bats

30. From external assessment, it is considered that the large farm barns and stables only have low / negligible potential to support roosting bats due to their design and construction from prefabricated materials (e.g. metal). There were no buildings identified as having the potential to support roosting bats.

31. During the habitat survey, there were no trees identified as having potential to support roosting bats, such as cracks, holes in the trunks and Woodpecker holes.

32. It is considered that the hedgerows and individual trees offer suitable foraging and navigational opportunities for bats. Although such opportunities are restricted to the study area boundaries, and the study area is unlikely to be high value to bats. Indeed there is deemed little merit in conducting further surveys if existing opportunities at the boundaries are maintained.

33. Information returned as part of the desk study exercise shows that no records of bats have been recorded within the study area itself. The nearest field record returned was for Common Pipistrelle Pipistrellus pipistrellus from 0.2km west of the study area in 2008. There were no records returned for bat roosts within the wider search area.

34. Consideration should be given to the retention of ‘dark-corridors’ for bats

within any development proposals. Enhancements to retain the habitats and creation of new habitats (as listed above) would likely benefit foraging bats. The provision of bat boxes would also provide further roosting opportunities for bats.

Badgers

35. A Badger latrine was recorded within a hedgerow (see Plan ECO2). However no setts or any other signs of this species were recorded during the surveys.

36. No records for Badgers were returned from within the study area itself as part of the desk study exercise. The nearest record of a Badger sett was returned from approximately 0.2km north of the study area boundary in 2002. This sett would be unaffected by the proposals as it is located on the opposite side of the road (Pendleford Mill Lane), although evidence indicates Badgers cross the study area and may use it for foraging. There is also a record of a sett to the south of the study area.

37. Consideration should be given to creation of green corridors through the

study area to allow safe dispersal of Badgers through the study area.

Other Mammals

38. No evidence of any other mammals was recorded within the study area. It is considered that the hedgerows, improved grassland and scrub offer suitable opportunities for a range of small mammals.

39. A record of Otter Lutra lutra (a European protected Species, Schedule 5 Species and Priority Species) was returned just off-site adjacent to the



Shropshire Union Canal, east of Barnhurst Lane. It is not considered the habitats within the study area offer suitable opportunities for Otter, and it is not considered to represent a development constraint, due to the distance involved.

Birds

40. It is considered that the hedgerows, trees and scrub offer suitable habitat for foraging and nesting birds, while the improved grassland fields offer potentially suitable foraging opportunities.

41. Species recorded within the study area during the surveys undertaken include Goldfinch Carduelis carduelis, Woodpigeon Columba palumbus, Wren Troglodytes troglodytes, Jackdaw Corvus monedula, Robin Erithacus rubecula, Greenfinch Carduelis chloris, Pied Wagtail Motacilla alba, Carrion Crow Corvus corone, Blackbird Turdus merula and Magpie Pica pica, as well as the Red List and Priority species House Sparrow Passer domesticus and Song Thrush Turdus philomelos. House Sparrow was associated with the existing residential development to the east of the study area, whilst the Song Thrush was seen amongst the vegetation on the southern boundary hedgerow.

42. The SER and EcoRecord returned no records of any notable bird species from within the study area itself.

43. A number of notable birds were recorded from the same grid square containing the study area, including the Schedule 1 and Priority Species Redwing (in 2015), Brambling a Schedule 1 species (in 2006), the Priority Species Lesser Redpoll (in 2013), Mistle Thrush (in 2015) and Cuckoo (in 2016).

44. A number of notable birds were also returned from 1 grid square east of the study area, including the Red List and Priority Species Yellowhammer Emberiza citrinella (in 2014), Reed Bunting Emberiza schoeniclus (in 2014), Linnet Linaria cannabina (in 2014), Willow Tit Poecile montanus (in 2013), Song Thrush (in 2015), and Marsh Tit Poecile palustris (in 2013). The Red List Species Skylark Alauda arvensis (in 2015) and Spotted Flycatcher Muscicapa striata (in 2015), the Priority Species Dunnock Prunella modularis (in 2015). The Schedule 1 and Red List species Fieldfare Turdus pilaris (in 2015) and Black Redstart Phoenicurus ochruros (in 2016).

45. The nearest records of House Sparrow and Tree Sparrow Passer montanus both a Red List and Priority Species were returned from 0.2km northwest of the study area and 0.7km southeast of the study area respectively.

46. It is considered that the hedgerows, trees and scrub within the study area offer suitable foraging and nesting opportunities for the majority of the above species, while the improved grassland offers suitable foraging opportunities. However, it is not considered any of the above species would likely be reliant on the habitats present within the study area.

47. As all species of birds receive general protection whilst nesting, to avoid a

possible offence, it is recommended that any clearance of suitable nesting vegetation (including any tree felling) be undertaken outside of the main



breeding season (March to July inclusive) or that checks be made for nesting birds by an ecologist immediately prior to removal.

48. New native planting associated with any proposals would likely provide

additional nesting and foraging habitats for a range of bird species and nest boxes could be erected as part of any proposals to further increase the nesting opportunities within the study area. All nest boxes should be situated out of direct sunlight and out of the reach of predators, particularly cats. In addition, the creation of areas of rough grassland within areas of open space will provide suitable areas for ground nesting birds.

Reptiles

49. There was no habitat identified suitable for reptiles recorded within the study area during the habitat survey.

50. The SER and EcoRecord returned no records of reptiles from within the study area itself or the wider search area.

Great Created Newts and other Amphibians

51. There are no ponds within the study area boundary. However, there is one pond present that lies within 250m south of the study area which is not separated by any dispersal barriers, such as roads.

52. The SER and EcoRecord returned a record of Common Toad Bufo bufo from 0.9km west of the study area in 2007.

53. As a precaution Great Crested Newt Triturus cristatus surveys will be undertaken on the pond within 250m of the study areas southern boundary (subject to obtaining access). However given the distance of the pond, presence of this species within the study area is considered unlikely, however if necessary appropriate mitigation could include the creation of new ponds linked by green corridors of rough grassland and hedgerows, which will create terrestrial habitat dispersal routes for amphibians between ponds, and off-site habitats including the pond to the south.

Invertebrates

54. It is considered that the study area is likely to support a range of common invertebrate species. But the intensive agricultural nature and predominance of improved grassland is likely to preclude the presence of any notable assemblage.

55. The SER and EcoRecord returned no records of any notable invertebrates

from within the study area itself, or from the wider search area.

56. The retention and enhancement of the hedgerows network, trees and scrub within the study area will provide retained habitat for a range of invertebrates. The opportunity exists to enhance the study area for invertebrates through the creation of new areas of species-rich grassland, new hedgerow and tree planting, and the creation of new ponds within any development proposals, which would create new opportunities for a range of invertebrates.



Summary and Conclusions

57. Surveys were carried out in August 2016 to ascertain the general ecological value of the study area. The study area was surveyed based around extended Phase 1 survey methodology, as recommended by Natural England. In addition an appraisal of the suitability of ecological features for use by protected species was also undertaken.

58. The majority of the study area comprises improved grassland fields separated

by fences. The grassland fields are all species-poor in botanical terms, and of low ecological value. The hedgerows are primarily found at the boundaries and are also generally species-poor.

59. However any development in the study area could easily retain the areas of relatively greater ecological value (in the context of the study area) such as the hedgerows and trees.

60. There were no records of bats returned by the SER or EcoRecord from within the study area itself. The nearest record returned was a field record for Common Pipistrelle from approximately 0.2km west of the study area in 2008. There were no trees or buildings identified as having the potential to support roosting bats. The hedgerows and trees at the boundaries of the study area offer suitable foraging and navigational opportunities for this faunal group, but the study area is not considered likely to be of high value for foraging bats, and existing opportunities could be easily maintained.

61. There is a Badger latrine within the study area, however there were no other signs of Badger activity or any setts recorded. There are setts known from close proximity, and this species is likely to disperse across the study area and potentially use it for foraging.

62. An Otter (a European Protected Species, Schedule 5 Species and Priority Species) was recorded just off-site associated with the Shropshire Union Canal, east of Barnhurst Lane. It is not considered the habitats within the study area offer suitable opportunities for this species.

63. A small number of notable birds were recorded within the study area during the surveys undertaken, with a larger number being returned from within the wider search area as part of the desk study exercise.

64. There is no suitable habitat within the study area to support reptiles, and no records of reptiles were returned from within the study area or the wider search area.

65. There are no ponds within the study area, although there is one pond within 250m of the study area boundary which is not separated by any dispersal barriers, such as roads.

66. Further specific surveys will be undertaken in respect of Great Crested Newts. If necessary suitable mitigation / enhancement measures may be required, including the creation of new ponds, linked by green corridors of rough grassland, creating terrestrial habitat dispersal routes.

67. The retention of the hedgerow network and trees, within any development proposals, will provide retained habitat for a range of wildlife. The creation of



new green corridors and areas of open space throughout the study area as part of any development proposals, along with the creation of new areas of species-rich grassland, new native hedgerow planting, and tree planting, and the creation of new ponds will create new opportunities for a range of wildlife.

68. It is considered that taking account of the recommendations in this report and

with an appropriate scheme / design any potential impacts on habitats and protected species could likely be mitigated / compensated. Indeed, it is likely to be possible to demonstrate a net gain for biodiversity within the study area where appropriate enhancement measures can be implemented. As such, there is not deemed to be any overriding ecological constraint to allocation of this land for development purposes.


PLAN ECO1: SITE LOCATION & DESIGNATED SITES

7136: PENDEFORD MILL LANE,BILBROOK

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ANCIENT AND SEMI NATURAL WOODLAND

SITE OF LOCAL IMPORTANCE FOR NATURECONSERVATION (SLINC)

SITE OF IMPORTANCE FOR NATURECONSERVATION (SINC)

KEY:

Big Hyde Rough SSSIapproximately 5.2km

Smestow Valley LNR

Barnhurst Lane BAS

Shropshire Union Canal SLINC

Staffordshire and Worcestershire Canal SINC

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APPENDIX 6

TECHNICAL NOTE ON

HIGHWAYS

Bloor Homes Ltd

LAND AT PENDEFORD MILL LANE, BILBROOK, STAFFORDSHIRE

TECHNICAL NOTE 1: HIGHWAY ACCESS

1. IntroductionTravis Baker is appointed by Bloor Homes Ltd to advise on the transport, highways and civil engineering issues relating to the proposed development of land at Pendeford Mill Lane, Bilbrook for residential use.

Travis Baker has undertaken an access feasibility study to determine how the site could be accessed from and connected to the existing local highway network. This Technical Note provides a brief summary of the study’s findings and presents preliminary proposals for access to the site.

2. LocationThe land that has been identified for development comprises two adjacent sites on Pendeford Mill Lane, referenced in south Staffordshire District Council’s Site Allocations Document (SAD) as SAD2 443 and SAD3 443 (see below).

The two sites are located at the north-eastern edge of Bilbrook village. The land edged in red (SAD2 443) has been allocated to provide a minimum of 102 dwellings and the land edged in green (SAD3 443) has been allocated as safeguarded land for future development needs. In addition, Bloor Homes is also promoting the balance of the land to Barnhurst Lane. The landholding has highway frontages to Pendeford Mill Lane (all sites) and Barnhurst Lane (land east of SAD3 443 only).

Pendeford Mill Lane is a local distributor road which connects the A449 to Bilbrook and Codsall. The centre of Bilbrook lies within 1km of the site’s western boundary. Along the site frontages, Pendeford

Mill Lane is a single carriageway road of semi-rural character, with limited frontage development. However, it has street lighting and a speed limit of 30mph, rising to 40mph some 300m east of the junction with Joey’s Lane. An off-carriageway foot-cycleway is provided on the northern side of the route, which links the existing Bilbrook developed area to Barnhurst Lane and beyond (i.e. the i54 employment site and the Wolverhampton urban area). There is currently no footway along the site frontages, but grass verges of varying width are provided.

Barnhurst Lane is also a local distributor road, which connects Pendeford Mill Lane with the northern outskirts of Wolverhampton. It is a single-carriageway road with a footway on its eastern side but no footway along the site frontage. The route has infrequent side road junctions, but has limited street lighting and is subject to a speed limit of 40mph. The junction with Pendeford Mill Lane is a 3-arm ghost-island priority arrangement.

Data on existing traffic flows and speeds was obtained from Automatic Traffic Counter (ATC) surveys undertaken on Pendeford Mill Lane during 2015, which have been used to inform the design of the proposed site access strategy.

A preliminary assessment of personal injury accident records suggests that the frequency of collisions along the Pendeford Mill Lane site frontage is not unduly high given the volume of traffic using the route. There is no evidence of any significant road safety issues that might relate to existing road geometry or traffic speeds.

3. Proposed Access StrategyThe housing site (SAD2 443) would be developed as Phase 1 prior to delivery of the safeguarded land (SAD3 443). Phase 1 would therefore require its own access. Phase 2 would have a separate access that could eventually be connected to the Phase 1 access within the site.

The proposed access strategy for Phase 1 comprises a ghost island junction that has sufficient capacity to serve the minimum dwelling requirement. Phase 2 will be served by a new roundabout. The strategy seeks to support up to 400 dwellings, which will allow “headroom” for future phases and would also enable a range of development scales and mixes to be considered.

Preliminary development masterplans for Phases 1 and 2 have been prepared by Pegasus Design and are shown below. There is currently no masterplan for the land west of Barnhurst Lane, however the road network within the safeguarded land could be extended to serve this additonal land, should it come forward for development.

Phase 1 (SAD2 443)

Phase 2 (SAD3 443)

The overall access strategy for Phases 1 and 2 is shown on Drawing T15033/004, which is included in Appendix A. The strategy has been reviewed by Staffordshire County Council (SCC), the local highway authority, who have confirmed that it is acceptable to them in-principle.

It is likely that the two phases of development would eventually need to be served by a loop road, which would connect the Phase 1 and Phase 2 accesses from the external highway network. Phase 1 would be served by the first section of loop road, which would initially be provided as a cul-de-sac but with

provision for its future extension into Phase 2. A ghost island junction with Pendeford Mill Lane is proposed, which would be consistent with existing provision at the Pendeford Mill Lane/Barnhurst Lane junction, to the east. Visibility splays would be provided in accordance with calculated requirements for prevailing speeds on Pendeford Mill Lane, which were surveyed in 2015. These splays can be provided within the site or adjacent highway boundaries.

The roundabout proposed to serve Phase 2 would assist in reducing speeds on the Pendeford Mill Lane approach to Bilbrook, by providing a “gateway” between the 40mph speed limit to the east and the 30mph speed limit to the west. The roundabout would be designed to the geometric requirements of the Design Manual for Roads and Bridges (DMRB) for a compact urban roundabout.

Pedestrians and cyclists would be able to reach the development via the proposed vehicular access points, which would be connected to the existing footways and cycle infrastructure on Pendeford Mill Lane, with crossing points to/from the existing foot/cycleway on its northern side.

4. Highway CapacityPreliminary capacity assessments of the two proposed access junctions have been undertaken to ensure that their layout would be suitable for possible future traffic demands. These assessments are based on the limited amount of traffic data collected in 2015 and will need to be confirmed in a formal Transport Assessment when planning applications are submitted.

The results indicate that the junctions will operate within capacity during both peak hours and would have sufficient capacity to accommodate a total development at the site comprising around 400 dwellings and would also enable a range of development scales and mixes to be considered.

The impacts of the proposed developments on off-site junctions to the east and west will need to be formally assessed in a full Transport Assessment a planning application stage.

5. SummarySatisfactorily vehicular access to both sites can be achieved in a manner that would enable the proposed development to be accessed in a safe and satisfactory manner by vehicles and sustainable travel modes such as public transport, walking and cycling, subject to the local enhancements proposed above.

Travis Baker 22 February 2017

APPENDIX A

SITE ACCESS STRATEGY

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FUTURE PHASE 2 ACCESS

PHASE 1 ACCESS

2.4m x 62m VISIBILITY

2.4m x 62m VISIBILITY

CLIENT

DRAWN AUTHORISED SCALE DATE

PROJECT NO. DRAWING NO. REV

REV DESCRIPTION DATE BY AUTH

AMP SM 1:500@A3 27.10.2015

T15033 004 A

1. DO NOT SCALE FROM THIS PLAN. IF IN DOUBT CONTACT TRAVIS BAKER.

2. ALL DIMENSIONS ARE IN METRES UNLESS OTHERWISE NOTED.

3. THIS PLANS IS TO BE READ IN CONJUNCTION WITH ALL OTHER RELEVANT DRAWINGS RELATINGTO THIS PROJECT.

4. THIS PLAN IS FOR INFORMATION PURPOSES ONLY AND NOT INTENDED FOR USE AS A CONTRACTUAL OR CONSTRUCTION DRAWING.

5. ALL ASPECTS OF THIS PLAN SHOULD BE CONFIRMED PRIOR TO THE PREPARATION OF ANY CONTRACTUAL OR CONSTRUCTION DRAWINGS BASED UPON IT. ANY DISCREPANCIES SHOULDBE IMMEDIATELY NOTIFIED IN WRITING TO TRAVIS BAKER.

6. THIS PLAN HAS BEEN PREPARED FOR THE EXCLUSIVE USE OF THE COMMISSIONING PARTY ANDUNLESS AGREED IN WRITING BY TRAVIS BAKER NO OTHER PARTY MAY USE OR RELY ON ITS CONTENTS. NO LIABILITY IS ACCEPTED BY TRAVIS BAKER FOR ANY USE OF THIS DRAWING OTHERTHAN FOR THE PURPOSE FOR WHICH IT WAS ORIGINALLY PREPARED

.7. IT SHOULD BE NOTED THAT THIS PLAN MAY INCLUDE DATA PROVIDED BY THIRD PARTIES. NO

LIABILITY IS ACCEPTED BY TRAVIS BAKER AS TO THE ACCURACY OF THIS DATA.

8. THIS DRAWING SHALL NOT BE REPRODUCED IN ANY WAY WITHOUT THE WRITTEN PERMISSIONOF TRAVIS BAKER.

9. FOR THE PURPOSES OF THESE CONDITIONS WITHIN THIS DOCUMENT, 'TRAVIS BAKER' SHALLREFER IN ALL CASES TO TRAVIS BAKER TRANSPORT PLANNING LTD.

PROJECT

PENDEFORD MILL LANE,

BILBROOK

TITLE

PHASE 1 AND PHASE 2 ACCESS

STRATEGY

STATUS.

CONCEPT DESIGN

COPYRIGHT TRAVIS BAKER TRANSPORT PLANNING LIMITED 2012- ALL RIGHTS RESERVED

Travis Baker

11 Malin Hill

The Lace Market

Nottingham

NG1 1JQ

Tel: 0115 896 6655

[email protected]

www.travisbaker.co.uk

BLOOR HOMES

A

ANNOTATIONS AMENDED. 21.02.17 TC SM

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