Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Inquiry held on 5, 6, 7, 8, 14, 15 and 25 November 2024 Site visit made on 11 November 2024 by J Woolcock BNatRes (Hons) MURP DipLaw MRTPI an Inspector appointed by the Secretary of State Decision date: 16th January 2025 Appeal Ref: APP/E1855/W/22/3310099 Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA • The appeal is made under section 78 of the Town and Country Planning Act 1990 (as amended) (the 1990 Act) against a refusal to grant planning permission. • The appeal is made by NRS Aggregates Ltd against the decision of Worcestershire County Council (WCC). • The application Ref is 19/000053/CM. • The development proposed is a sand and gravel quarry with progressive restoration using site derived and imported inert material to agricultural parkland, public access and nature enhancement. • This decision supersedes that issued on 5 May 2023. That decision on the appeal was quashed by order of the High Court. Decision 1. The appeal is dismissed. Preliminary matters Procedural considerations 2. It was made clear at the Case Management Conference (CMC), held on 7 August 2024, that the re-determination Inquiry would not be reviewing the previous decision, which now has no legal effect.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Nevertheless, it is a material consideration insofar as any differences in reasoning with the previous Inspector’s reasoning would need to be explained. It was also clarified that the re-determination Inquiry would hear the evidence afresh, taking into account the development plan and other material considerations as they are now, not as they were at the time the quashed decision was determined.1 3. In addition to the accompanied site visit on 11 November 2024, and with the agreement of the main parties, I visited the locality unaccompanied on 13 November 2024. The Core Documents (CD) for the original appeal were supplemented with additional documents for this re-determination. Documents submitted in the lead up to and during the re-determination Inquiry are numbered rID. All CD and rID documents were added to WCC’s appeal website. The proceedings of the Inquiry were live-streamed. 1 rID1. https://www.gov.uk/planning-inspectorate

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 4. Possible planning conditions were considered during the proceedings on a without-prejudice basis.2 A Round Table Discussion (RTD) about suggested planning conditions and other outstanding matters took place online on 25 November 2024. Closing submissions by the main parties were subsequently made in writing.3 The Inquiry was closed in writing on 6 December 2024. 5. The appeal continues in the name of the applicant, NRS Aggregates Ltd, notwithstanding the name change in 2020 to NRS Saredon Aggregates Limited.4 6. Stop the Quarry Campaign (STQC) was granted Rule 6(6) status pursuant to The Town and Country Planning Appeals (Determination by Inspectors) (Inquiries Procedure) (England) Rules 2000. STQC represents over 4,000 local residents and has a constitution, along with an action committee. Representatives of STQC spoke at the original WCC planning committee meeting, attended the CMC, and participated in the Inquiry opposing the proposed development. 7.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The application was accompanied by an Environmental Statement (ES).5 The ES was the subject of several requests for ‘further information’.6 An ES Addendum was submitted in July 2024 by the appellant regarding a proposed amended scheme.7 This addendum is ‘any other information’ for the purposes of the EIA Regulations. 8. WCC refused the application for nine reasons, but at the re-determination Inquiry only defended Reason for Refusal (2), concerning an unacceptable impact on the openness of the Green Belt.8 STQC and interested persons maintain objections to the proposed development on Green Belt and other grounds. Local and national planning policy 9. The development plan for the locality includes the Worcestershire Minerals Local Plan, adopted in July 2022 (MLP), the Worcestershire Waste Core Strategy Development Plan Document 2012-2027 (WCS), adopted in November 2012, and the Wyre Forest District Local Plan 2016-2036 (WFLP), adopted in April 2022. The appeal site lies within the West Midland Green Belt as designated in the WFLP. Consultation on the Mineral Site Allocations DPD has been delayed by WCC until there is clarity about changes to the wider plan- making system. 10.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision A revised National Planning Policy Framework (NPPF) was published on 12 December 2024 and the parties were given time to submit written representations about any changes relevant to this appeal. I have had regard 2 rID9, rID10, rID73, rID111, rID224, rID229 and rID235. 3 rID238, rID239 and rID240. 4 rID56 and rID57. 5 CD1.03 pursuant to the Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (the EIA Regulations). 6 CD3, CD5, CD8 and CD14. 7 CD15. 8 The report to WCC Members by the Head of Planning and Transport Planning recommended approval of the application, but it was refused for the following reason: (1) Concerned a policy from the now replaced County of Hereford and Worcester Minerals Local Plan. (2) Green Belt. Other reasons concerned the impact on residential amenity and local schools (3), the local economy (4), protected trees (5), the bridleway along the A449 (6), impact on highways (7), the environment and wildlife (8), and impact on the health of the local population (9). https://www.gov.uk/planning-inspectorate 2

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 to the NPPF; the Planning Practice Guidance (PPG) regarding Minerals, Green Belt, Air Quality and Noise; the National Planning Policy for Waste (NPPW); and the Noise Policy Statement for England (NPSE). 11. Defra published interim planning guidance for PM targets in November 2024 2.5 while the Inquiry was adjourned.9 This interim guidance was discussed at the RTD held on 25 November 2024. Statements of Common Ground and suggested planning conditions 12. WCC and the appellant agreed three Statements of Common Ground (SoCG). The main SoCG included the reasons for refusal that would not be defended by WCC, along with matters on which the parties disagreed.10 The Biodiversity SoCG includes a biodiversity net gain assessment.11 The need for sand and gravel, and for inert waste capacity, was included in a Minerals and Waste SoCG.12 WCC and the appellant agreed conditions to be imposed in the event that planning permission was granted.13 STQC commented on the suggested conditions. The site and its environs 13.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The 46 hectare (ha) appeal site is located to the north of Wolverley Road (B4189), to the west of Wolverhampton Road (A449) and about 40 m to the east of Brown Westhead Park, which is a residential estate road. Some 26 ha of the site is proposed for sand and gravel extraction. The appeal site is part of the open countryside that lies between Kidderminster, Cookley and Wolverley. Land to the east of the A449 is part of a strategic allocation in the WFLP, which has been released from the Green Belt. WFLP Policy SP.LCV1 applies to this land and provides for the development of Lea Castle Village. This would deliver around 1,400 dwellings (of which 600 have planning permission and there is an outstanding application for a further 800), along with provision of around 7 ha of employment development, provision for a primary school and a village centre. Lea Castle Village is currently part built and the Illustrative Masterplan indicates future phases for residential development adjacent to the A449.14 14.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The appeal site is divided into an eastern section (13.5 ha) and western section (12.5 ha) by bridleway WC-626, which with bridleway WC-625 to the north of the appeal site, links South Lodges on Wolverley Road with North Lodges at the junction of Castle Road and the A449. Footpath WC-624 extends east/west across the western section of the appeal site. 15. The route of bridleway WC-626 is also the access to The Bungalow and its associated equestrian centre. There are other residential properties at Castle Barns and the Whitehouse to the north of the appeal site. Keepers Cottage lies to its north-west. Broom Cottage and Four Winds lie to the south of the site. Heathfield Knoll School and First Steps Nursery are located on the opposite side of the B4189 to the appeal site and near to its south-western corner. There are other schools in the wider area.15 9 rID225. 10 rID2. 11 rID5. 12 rID8. 13 rID235.01 and rID235.02. 14 CD12.45. 15 rID21 and rID40. https://www.gov.uk/planning-inspectorate 3

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 16. The appeal site is predominantly in agricultural use and is grades 2 and 3a land, which is categorised as the Best and Most Versatile (BMV) agricultural land. Several trees within the appeal site are subject to Tree Preservation Orders. The whole of the appeal site is located in a Groundwater Source Protection Zone. Hurcott Wood, which is an ancient wet woodland, is a designated Site of Special Scientific Interest (SSSI) located about 1.2 km to the south-east of the appeal site. There are other SSSIs within 3 km of the site. Heritage assets 17. The appeal site is part of the former parkland associated with Lea Castle, which was demolished in 1945. However, the site of the former Castle and its gardens are outside the appeal site. The North Lodges and Gateway to Lea Castle, which is located to the north of the appeal site, is a grade II listed building. Sion Hill House and Wolverley Court are both grade II listed buildings, located some 250 m and 500 m respectively from the appeal site. I am required by Section 66(1) of the Planning (Listed Buildings and Conservation Areas) Act 1990 to have special regard to the desirability of preserving the setting of a listed building.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The Staffordshire and Worcestershire Canal Conservation Area lies some 65 m to the north-west of the appeal site.16 Great weight should be given to the conservation of these designated heritage assets.17 Non-designated heritage assets in the locality include; 1 and 2 South Lodges, Lea Castle Farm, Broom Cottage and Keepers Cottage.18 Request to consider an amended scheme at the appeal stage 18. The appellant seeks to amend the application scheme because quarry plant and infrastructure has evolved since the proposal was first conceived in 2018/19. A revised plant is available to the appellant that would be lower in height, occupy a reduced footprint and would result in lower noise emissions. This would enable changes to the height and duration of some of the proposed bunds. 19. The Planning Inspectorate’s Procedural Guide: Planning appeals – England states that the appeal process should not be used to evolve a scheme. Despite this general principle, consideration will be given to accepting amendments having regard to the substantive and procedural tests that derive from the Wheatcroft and Holborn Studios judgments.19 20.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The main parties provided written submissions about the appellant’s request to consider an amended scheme.20 STQC objects on the grounds that the change would result in a fundamentally altered scheme and that consultation was inadequate. WCC does not oppose consideration of the amended scheme. This matter was discussed at a RTD on the first day of the Inquiry, but I reserved my judgement about whether to accept this request until the Inquiry had heard all the evidence.21 16 rID47. 17 NPPF paragraph 212. 18 rID46. 19 Paragraph 16 of The Planning Inspectorate’s Procedural Guide: Planning appeals – England, dated September 2024, which cites Bernard Wheatcroft v Secretary of State for the Environment (1982) and Holborn Studios Ltd v The Council of the London Borough of Hackney (2018). 20 rID12, rID13 and rID14. 21 rID15. https://www.gov.uk/planning-inspectorate 4

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 21. STQC questions the justification for requesting consideration of an amended scheme. However, the reason for the request, albeit relevant, is not a determinative consideration. Whether the amended scheme is a substantially different scheme, along with whether its acceptance at this stage would be prejudicial to anyone, are more important considerations. 22. Details about the proposed amended scheme are set out in CD15. The proposed changes include a reduction in processing plant height from 12 m to 6.334 m and a reduction in processing plant footprint (from 2,752 m2 to 451 m2). These amendments, along with a reduction in noise levels from the processing plant, would enable changes to some of the proposed bunds. 23. Bund 3 (350 m in length) adjacent to the Plant Area would be reduced from part 4 m / part 6 m high to a uniform height of 3 m. Bund 7 (189 m) to the west of The Bungalow would be reduced from 6 m to 4 m. Bund 11 (103 m) would no longer be needed. Bund 13 (126 m), Bund 14 (86 m) and Bund 16 (144 m) would all be reduced from a height of 4 m to 3 m.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The removal of Bund 18 (190 m) towards the eastern side of the proposed extraction area would enable the planting of a native hedgerow north/south across this part of the appeal site in the Initial Works Phase rather than at Final Restoration Stage. Bund 19 would be slightly longer with the removal of Bund 18, increasing from 117 m to 128 m in length, but would reduce in height from 4 m to 3 m. The duration of Bund 5 (88 m), located within the Plant Area, would reduce from 10/11 years to 5.5 years.22 24. Notwithstanding these proposed changes, the scheme would essentially remain a sand and gravel quarry with phased extraction and progressive restoration. The tonnage of mineral extracted, and of inert fill imported, would be comparable in the original and proposed amended schemes. So too, would access arrangements. The proposed changes to the number of bunds, and with respect to the height, length and duration of some of the retained bunds, together with some landscaping alterations, would not result in a substantially different scheme for the purposes of applying the Wheatcroft judgment. 25. I turn next to the procedural test.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision In doing so I have had regard to the differences between the circumstances in the Bramley case and what occurred in the lead-up to this re-determination Inquiry.23 STQC considers that the consultation with the public was inadequate. Details were uploaded onto WCC’s webpage for the application and appeal, with dates and locations for consultation events, and notification letters were sent to all consultees. The consultation ran for 30 days from 5 August to 6 September 2024. The appellant ran two public consultation events at Wolverley Memorial Hall on 7 August and 21 August 2024. Notices were placed in the local press. Corrections were made about incorrect references to Wolverley Village Hall and to misleading dates about the deadline for comments. STQC added a link on its Facebook page to WCC’s appeal webpage that included details about the amended scheme. However, the appellant did not send letters to third parties who had previously commented on the application and the appeal. 22 rID16. 23 R (Bramley Solar Farm Residents Group) v SoS LUHC [2023] EWHC 2842 as cited in rID13. https://www.gov.uk/planning-inspectorate 5

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 26. WCC and the appellant consider that the requirements of EIA Regulation 25 paragraphs (3) to (11) were met except for Regulation 25 (3) (g) and (i).24 These require an address in the locality where the information may be inspected. The notice here only included a web address and an address in Warwickshire, some 44 miles from Kidderminster, where copies could be obtained. The documents were available to view during the two consultation events. Notwithstanding these defects, WCC and the appellant concur that there was substantive compliance with Regulation 25 (3) as a whole. 27. STQC considers that the fact that documents were not hosted in the locality for at least 30 days could cause prejudice to those wishing to respond to the consultation. The procedural unfairness is compounded, in STQC’s submission, by reason of the failure to display site notices and to send letters/emails to those who had previously made representations, especially when there are people in the locality who have difficulty accessing material online. STQC adds that the £100 cost for a copy of the information would have been a likely deterrent to obtaining a paper copy.25 28.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision I saw at my site visits that banners were displayed in the locality drawing attention to the date and venue for the Inquiry. Many people attended the Inquiry when it was sitting, with some giving oral evidence. In addition, the proceedings were live-streamed, and recordings were made available for seven days on WCC’s website. The Inquiry accepted many written representations from interested persons who were unable to attend in person.26 Throughout the Inquiry proceedings, reference was made to both the original and proposed amended schemes. The written documentation submitted, both in the lead up to the Inquiry and whilst it was sitting, which was all available to see on WCC’s appeal website, also referred to the amended scheme. It seems likely to me that anyone who was interested in the proposed development would have had a reasonable opportunity to consider, and to comment on, the request to deal with the appeal on the basis of an amended scheme. 29. Any defect here in applying the EIA Regulations consultation requirements would not, in my view, be sufficient to rule out consideration of an amended scheme given the extensive opportunities this Inquiry provided for public engagement.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision I am satisfied that the ES, with the submitted further information and any other information, reasonably complies with Schedule 4 of the EIA Regulations. In considering the appeal, I have had regard to the Environmental Information, which includes the ES, the further information and any other information submitted, along with all the representations made about the environmental effects of the development. Taking all these factors into account, it seems to me unlikely that any procedural unfairness would result from accepting the proposed amendments to the appeal scheme. 30. The amended scheme would not be a substantially different scheme to that considered by WCC in refusing the application. Taking into account both the measures undertaken in advance of the Inquiry to draw attention to the amended scheme, along with the engagement of so many interested persons in the Inquiry proceedings, which addressed this issue, I consider it unlikely that anyone would be prejudiced by accepting the amendments. The proposed 24 rID71. 25 rID232. 26 Some of these are cited in this decision as footnotes to illustrate the issues raised, but the fact that others are not cited does not mean that they have not been considered.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision https://www.gov.uk/planning-inspectorate 6

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision https://www.gov.uk/planning-inspectorate 6 Appeal Decision APP/E1855/W/22/3310099 alterations to the scheme were considered in detail at the Inquiry, during which all the evidence necessary to properly assess the amended proposal was adduced. WCC and STQC oppose granting planning permission for both the original and the amended schemes. 31. Having regard to the Wheatcroft and Holborn Studios judgments, I consider that it would be appropriate in the circumstances that apply in this case, to exceptionally deal with the appeal on the basis of the amended scheme. I have, therefore, in determining this appeal, considered the proposed development to be the scheme as described in CD15, which in the remainder of this decision is referred to as the ‘appeal scheme’ or the ‘Lea Castle scheme’. The proposed development 32. The appeal scheme proposes the extraction of 3,000,000 tonnes of sand and gravel with progressive restoration over an 11-year period.27 The operation would include initial works to construct a Plant Area for crushing, screening, sorting and stockpiling sand and gravel, along with portacabins, offices and welfare facilities. The Plant Area would be set 7 m below the existing ground level.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The quarrying operation would involve five phases of extraction, along with the import of 600,000 m3 (equating to about 1,020,000 tonnes) of inert material for restoration. Depositing inert waste would require an Environmental Permit from the Environment Agency (EA). 33. Phases 1, 2 and 3 would take place in the western section of the appeal site, with the extraction of 900,000 tonnes of sand and gravel, along with the import of 198,350 m3 of inert material. The extracted mineral and imported infill would be transferred to/from the Plant Area by means of a conveyor, about 80 m long, that would pass beneath bridleway WC-626. The eastern section of the appeal site, which would include the Plant Area and Phases 4 and 5, would extract 2,100,000 tonnes of sand and gravel, and would require 401,650 m3 of inert material for restoration.28 34. Depth of extraction would vary with the undulating base of the deposit, but for the western part of the appeal site it would typically be between 5-7 m.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision For the eastern area the depth of working would range from 12 m to a maximum depth of 18 m.29 A planning condition could specify that no excavation or extraction would take place below specified heights Above Ordnance Datum.30 No de-watering is proposed as extraction would take place some 16-24 m above the water table. 35. Vehicular traffic to the appeal site would be via a new junction onto Wolverley Road (B4189). This would require the removal for a distance of 63 m of the existing brick wall that encompasses the former parkland.31 Bricks would be stored for later reinstatement. 27 CD1.02 paragraphs 3.1.7 and 3.4.2 state that phasing would be: Initial Works (1.5 years), Phase 1 (0.75 years), Phase 2 (1 year), Phase 3 (1.25 years). Phase 4 (3.25 years), Phase 5 (2.25 years) and Final Works (1 year). 28 CD1.03 paragraph 4.5.2 and rID74 Table l.2. Note Table l.1 of rID74 does not include 60,000 m3 of inert material for Phase 5. 29 CD1.02 paragraph 3.4.1. 30 rID235.02 suggested Condition 8. 31 CD1.09 Proposed Site Entrance Drawing WY TA 19-1. https://www.gov.uk/planning-inspectorate 7

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 36. Progressive restoration with site derived and imported inert materials would be to agricultural parkland, public access and nature enhancement. This would include approximately 2.7 km of new public bridleways and permissive bridleways, along with five pocket parks. Approximately 3.42 ha of native woodland blocks would be established, including reinstatement of Broom Covert. The concept restoration scheme includes the planting of about 170 avenue and parkland trees, reinstating the historic avenue of trees along bridleways WC-625 and WC-626. Some 439 m of hedgerow would be strengthened, and about 579 m of new hedgerow planted. A new acid-rich meadow grassland (7.5 ha) would be developed to promote biodiversity and educational opportunities.32 37. The appellant, the proposed operator and the owner of the land, submitted a Unilateral Undertaking (UU), dated 1 December 2024, pursuant to section 106 of the 1990 Act.33 Its purpose is to secure plans for biodiversity and landscape management, along with implementation, monitoring and management of a 30-year aftercare scheme.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision It would provide for access routes within the appeal site to be maintained beyond the duration of the development.34 The UU would ensure maintenance of a surface water drainage system. Main issues 38. I consider that the main issues in this appeal are: (1) The effects of the proposed development on the openness of the Green Belt and upon the purposes of including land within it, and whether the development conflicts with policy to protect the Green Belt. (2) The effects of the proposed development on the character and appearance of the area. (3) The effects of the proposed development on the local amenity of the area and the living conditions of nearby residents, with particular reference to noise, dust, air quality, outlook, health and well-being. (4) The effects of the proposed development on PRoW and access. (5) The effects of the proposed development on heritage assets. (6) The effects of the proposed development on highway safety, particularly for vulnerable road users. (7) The effects of the proposed development on biodiversity. (8) The effects of the proposed development on employment and the economy.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision (9) The need for sand and gravel, having regard to likely future demand for, and supply of, these minerals, along with the availability of inert material for restoration and capacity for inert waste. (10) The planning balance and planning policy. 32 CD15.23 and rID2 SoCG paragraph 4.8. rPOE1.02 paragraph 4.29 and rID240 paragraph 20 refer to a new public right of way approximately 2.3 km around the perimeter of the site. 33 rID227.03. 34 rID228.01, rID233 and rID234. DB Symmetry Ltd at paragraphs 62-63 provides that a planning obligation to dedicate access roads as public highways would be a valid obligation if it met the criteria set out in Regulation 122 of the Community Infrastructure Levy Regulations 2010. https://www.gov.uk/planning-inspectorate 8

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 Reasons Green Belt 39. The appeal site lies within the Green Belt as defined in the development plan for the area. The NPPF states that the Government attaches great importance to Green Belts. It adds that the essential characteristics of Green Belts are their openness and their permanence. When located in the Green Belt inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances (VSC). The NPPF provides that substantial weight should be given to any harm to the Green Belt, and that VSC will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations. MLP Policy MLP27, WCS Policy WCS13 and WFLP Policy DM.22 are consistent with the NPPF with respect to inappropriate development and VSC. 40.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Green Belt serves five purposes: (a) to check the unrestricted sprawl of large built-up areas; (b) to prevent neighbouring towns merging into one another; (c) to assist in safeguarding the countryside from encroachment; (d) to preserve the setting and special character of historic towns; and (e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 41. The revised NPPF introduced the ‘grey belt’, which is land in the Green Belt that does not strongly contribute to any of Green Belt purposes (a), (b) or (d). If the appeal site is grey belt land, then the proposal would not be inappropriate development if it met the requirements set out in NPPF paragraph 155. If the appeal site is not grey belt land, then NPPF paragraph 154 (h) provides that the appeal scheme would be inappropriate unless it preserved the openness of the Green Belt and would not conflict with the purposes of including land within it. It is therefore necessary in applying Green Belt policy to first determine whether the land is grey belt. In doing so I have had regard to the written submissions by the parties about the circumstances that apply in this case.35 42.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The appellant considers that the site falls within the definition of grey belt because it is not adjacent to any large built-up areas and so does not strongly contribute to Green Belt purpose (a). However, if ‘sprawl’ is to be given its usual meaning, it seems to me that purpose (a) is to restrain the unrestricted straggling expansion of large built-up areas. To fulfil that function the land need not necessarily adjoin such areas. Purpose (a) is referring to curbing unrestricted sprawl. Unrestricted straggling expansion of a large built-up area would not be confined to just the land that was contiguous with the built-up area. Unrestricted sprawl could, given that it would not be restricted, extend beyond land that was adjacent to a large built-up area. 43. In any event, in this case the appeal site is adjacent, albeit separated by the A449, to land that has been allocated in the development plan for 1,400 dwellings, along with provision of around 7 ha of employment development, provision for a primary school and a village centre. I consider development on that scale would comprise a large built-up area for the purposes of applying NPPF paragraph 143.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision It was evident at my site visits that the appeal site forms a key component of the open land that has an important role in checking 35 rID241, rID242 and rID243. https://www.gov.uk/planning-inspectorate 9

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision It was evident at my site visits that the appeal site forms a key component of the open land that has an important role in checking 35 rID241, rID242 and rID243. https://www.gov.uk/planning-inspectorate 9

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 unrestricted sprawl from Kidderminster and Lea Castle Village. I consider that the appeal site is land that strongly contributes to Green Belt purpose (a), and so does not constitute grey belt land. 44. The proposals for the appeal site; including the facilities, plant, access and bunds, are part and parcel of the proposed mineral extraction here for the purposes of applying Green Belt policy. If there is any doubt about the bunds, their construction and removal would be engineering operations. Minerals can only be extracted where they are found. NPPF paragraph 154 (h) provides that mineral extraction and engineering operations are not inappropriate development in the Green Belt provided that they preserve its openness and do not conflict with the purposes of including land within it. 45. NPPF paragraph 154 (h) must mean that some level of development for mineral extraction in the Green Belt would preserve its openness and would not conflict with its purposes, and that beyond that level the development would become inappropriate in the Green Belt, and so the exception would no longer apply.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Determining the ‘tipping point’ would depend upon the particular circumstances, as a matter of fact and degree. In assessing the likely effects upon the openness and purposes of the Green Belt, relevant considerations could include: spatial aspects, such as the siting, nature and scale of the proposed development; visual aspects of the proposal in its local context; the degree of activity likely to be generated; and its duration and remediability. This approach would accord with the PPG and the judgments in Europa Oil and Samuel Smith.36 The appeal scheme would not benefit from the NPPF exception for mineral extraction if either it did not preserve the openness of the Green Belt or was in conflict with the purposes of including land within it. 46. I deal first with whether the proposal would preserve the openness of the Green Belt. In doing so it is relevant to have in mind the judgment in Turner.37 This noted that the concept of openness of the Green Belt is not narrowly limited to a volumetric approach but is open-textured with a number of factors capable of being relevant.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Prominent among these will be factors relevant to how built up the Green Belt is now and how built up it would be with the proposed development, along with factors relevant to the visual impact on the aspect of openness which the Green Belt presents. 47. In terms of a spatial impact on the openness of the Green Belt, the proposed bunds and stockpiles, processing plant and hoppers, site office/welfare facilities and staff car parking, would to some extent impair the openness of the area. However, in my view, the spatial impact of the appeal scheme on openness would not, by itself, be sufficient to exceed the tipping point for determining whether the proposal is inappropriate development in the Green Belt. It is the overall combined spatial and visual effects, along with the activity generated and the duration/remediability of the development that determines where the tipping point lies in the particular circumstances that apply in this case. 48. I turn next to consider the assessment of visual aspects of openness in the Green Belt. Many submissions raised concern about a cumulative effect of the appeal scheme when taken together with the development of Lea Castle Village on the opposite side of the A449.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision In the absence of any more specific guidance 36 What factors can be taken into account when considering the potential impact of development on the openness of the Green Belt. PPG Green Belt Paragraph: 001 Reference ID: 64-001-20190722. 37 CD12.05 paragraph 14. https://www.gov.uk/planning-inspectorate 10

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision In the absence of any more specific guidance 36 What factors can be taken into account when considering the potential impact of development on the openness of the Green Belt. PPG Green Belt Paragraph: 001 Reference ID: 64-001-20190722. 37 CD12.05 paragraph 14. https://www.gov.uk/planning-inspectorate 10

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 about undertaking an assessment of the visual aspects of openness, I consider that the Landscape Institute’s Guidelines for Landscape and Visual Impact Assessment (GLVIA3) provides some helpful insights into assessing cumulative effects that might usefully be applied to the consideration of openness in the Green Belt.38 49. GLVIA3 refers to cumulative assessments focussing primarily on either the additional effects of the main project under consideration, or on the combined effects of all the past, present and future proposals together with the new project.39 I consider that the additional approach should apply here because that would accord with the judgment in Turner to assess likely differences between the Green Belt now and what it would be like with the proposed development. Such an incremental approach would include Lea Castle Village in the assessment baseline.40 As an existing feature Lea Castle Village would not, in an additional cumulative assessment, make any difference in a ‘before and after’ comparison because it would be common to both.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision However, that does not mean that Lea Castle Village is irrelevant to consideration of the visual impact of the appeal scheme on the aspect of openness which the Green Belt presents. 50. The judgment in Samuel Smith records that openness is the counterpart of urban sprawl. That is apparent for this locality in that the appeal site forms part of an open area between built development in Kidderminster, Fairfield, Cookley and Lea Castle Village. The contrast between the openness of this part of the Green Belt and urban development on surrounding land is apparent from the submitted photographs and was evident at my site visit. The appeal site is seen to the north of Broadwaters 41, to the east of Fairfield 42, to the south of Cookley 43 and to the west of Lea Castle Village 44. The openness of the appeal site is perceived in the context of this urban development in the wider area. Within the appeal site this sense of openness is enhanced by middle-distance views across open fields. For the western part of the appeal site these views from the PRoW are towards the wooded edges of the site.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Views from public vantage points of the eastern part of the appeal site take in the openness of the fields, which is emphasised by the rolling landform. The proposed bunds would foreshorten many of these middle-distance views. This is evident from the appellant’s photomontages for View Points VP15a, VP15b, VPCa, VPCb, VPDa and VPDb.45 The bunds would have a significant adverse effect on visual aspects of openness for this part of the Green Belt. 51. Harm to the openness of the Green Belt would occur for a limited duration and, with implementation of the proposed restoration scheme, would be entirely remediable. However, the operation of the proposed quarry for 11 years would be seen, in landscape terms, as long term.46 It seems to me that this would also be a relevant time scale to apply in assessing visual aspects of openness in the Green Belt. 38 I raised this at the Inquiry with the appellant’s landscape expert as GLVIA3 is referred to in rPOE2.07. 39 GLVIA3 paragraph 7.18. 40 Including that part of Lea Castle village consented and under construction, along with the area that is subject to as yet undetermined planning application.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision GLVIA3 paragraph 7.13 includes in cumulative assessments potential schemes that are the subject of valid planning applications. 41 rPOE1.03 Key View E and rPOE2.08 VP5. 42 rPOE2.08 View E Figure 71. 43 rPOE1.03 Key View B and rPOE2.08 VP8 Figure 11. 44 rPOE1.03 Key View D and rPOE2.08 VP4 Figure 6. 45 rPOE2.08. 46 GLVIA3 paragraph 5.51 considers 10-25 years long term. https://www.gov.uk/planning-inspectorate 11

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision GLVIA3 paragraph 7.13 includes in cumulative assessments potential schemes that are the subject of valid planning applications. 41 rPOE1.03 Key View E and rPOE2.08 VP5. 42 rPOE2.08 View E Figure 71. 43 rPOE1.03 Key View B and rPOE2.08 VP8 Figure 11. 44 rPOE1.03 Key View D and rPOE2.08 VP4 Figure 6. 45 rPOE2.08. 46 GLVIA3 paragraph 5.51 considers 10-25 years long term. https://www.gov.uk/planning-inspectorate 11

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 52. The PPG refers specifically to the degree of activity likely to be generated, such as traffic generation.47 Some activity on the appeal site would be attributable to HGV and other vehicular movements in and out of the access to the appeal site from Wolverley Road and along the haul road to the Plant Area. For the western part of the appeal site, during Phases 1-3, considerable activity would be generated by the construction and later removal of Bunds 7, 8, 9, 10, 12, 13, 14, 15 and 16, all undertaken during a 4 year period.48 Dump trucks travelling between extraction/infill areas and the conveyor in Phases 1-3 would be evident when not operating below ground level or sufficiently screened by bunds or hay bales.49 Activity would also be associated with the loading of hoppers serving the conveyor. 53. Vehicle movements on site would regularly occur from the refuelling of the excavator and dump trucks, which the Inquiry was informed would take place outside the Plant Area by mobile tankers. There would be considerable activity within the Plant Area maintaining stockpiles and loading/unloading HGVs.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Vehicular movements associated with the progressive restoration of each phase would add to activity associated with the on-going extraction operations. Much of this activity would be apparent from the PRoW through the appeal site. 54. Similar levels of activity would be apparent in the eastern part of the appeal site during Phases 4 and 5. However, Bunds 1, 2 and 3 would remain in place for the duration of the development and the conveyor would be removed on completion of the restoration for Phase 3. Nevertheless, taken overall, the movement of HGVs and large vehicles required for quarrying and restoration within the appeal site would result in considerable intensity of activity that would have a significant adverse effect on the openness of the area. 55. The assessment of effects on the openness of the Green Belt in other cases is not very helpful in assessing the likely impact of the appeal scheme. Such assessments are very site-specific and largely dependent upon the details of any particular scheme.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision This is reflected in the PPG, which requires a judgment based on the circumstances of the case.50 Notwithstanding this guidance, the appellant cites decisions at Ware Park and Pinches Quarry in support of its submissions about the effect of the appeal scheme on the openness of the Green Belt. 56. In the decision at Ware Park, the Secretary of State found that the plant, equipment, access and activity associated with mineral extraction, along with bunds and tree planting, would not be inappropriate development.51 There are some similarities between the appeal scheme and the proposed development at Ware Park, particularly regarding phased extraction, with bunding, and restoration over a 10/11-year period. However, there are important differences concerning the degree of activity likely to be generated. 57. The extraction of 3.0 million tonnes of sand and gravel in the Lea Castle scheme would be likely to generate a significantly greater intensity of activity than would the extraction of 1.75 million tonnes of sand and gravel at Ware Park. In addition, HGV movements at Ware Park would have been restricted to 47 Paragraph: 001 Reference ID:64-001-20190722. 48 rID74 Year 2 to Year 5.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision 49 rID235.02 suggested Condition 46 would require hay bales to assist with visually screening the development from bridleway WC-626. 50 Paragraph: 001 Reference ID: 64-001-20190722. 51 CD12.39 and rID45. https://www.gov.uk/planning-inspectorate 12

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision 49 rID235.02 suggested Condition 46 would require hay bales to assist with visually screening the development from bridleway WC-626. 50 Paragraph: 001 Reference ID: 64-001-20190722. 51 CD12.39 and rID45. https://www.gov.uk/planning-inspectorate 12

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 50 in and 50 out per day, whereas suggested Condition 21 for the appeal scheme would limit HGVs to 77 in and 77 out per day. The import of inert waste for the appeal scheme would add to activity associated with restoration that would not have occurred at Ware Park, where imported waste was prohibited. Furthermore, the installation, operation and removal of the conveyor required for the appeal scheme would introduce activity that would not have occurred at Ware Park, which did not require a conveyor. For these reasons, the decision at Ware Park is not comparable to the circumstances that apply in the Lea Castle scheme. 58. The development at Pinches Quarry is of a smaller scale compared to the Lea Castle scheme.52 The site area is 5.7 ha. The scheme would extract approximately 850,000 tonnes of sand and gravel and import a comparable quantity of inert waste for restoration. HGV trips per weekday would be 38 in and 38 out. In that case WCC did not consider the duration of 14 years to be very long-term in the context of mineral extraction and restoration.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Even allowing for the different durations, the difference in scale of Pinches Quarry would mean that it would be likely to have a significantly different effect on the openness of the Green Belt by comparison with that likely to result from the Lea Castle scheme. 59. The 2016 Green Belt Review is not of much assistance in assessing the likely effects of the appeal scheme on the openness of the Green Belt because the overall objective of the Review was to test the Green Belt against the five purposes set for it in the NPPF and to determine the extent to which it was contributing to those purposes. Furthermore, the appeal site forms only a part of parcel N7 on which the assessment was based.53 60. Notwithstanding the limited duration of the proposed development and its remediability, in my judgement, the combination of adverse impacts on openness arising from spatial and visual aspects of the appeal scheme, along with the degree of activity generated, mean that the proposal would not preserve the openness of the Green Belt. 61. Conflict with the five purposes of the Green Belt would result in inappropriate development.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision In applying NPPF paragraph 154 (h) different considerations apply in assessing whether the proposed development conflicts with the Green Belt purposes, compared to those that are relevant in assessing whether the land itself strongly contributes to any of purposes (a), (b) or (d) in determining grey belt status. 62. However, if ‘sprawl’ has its ordinary meaning of a straggling expansion of an urban area, then I find no conflict with purpose (a) because use of the land for a quarry would itself serve to check the unrestricted sprawl of Kidderminster and Lea Castle Village.54 The nature and scale of the proposed quarry would result in a land use that was readily distinguishable from the built form apparent in Kidderminster and Lea Castle Village. STQC acknowledges that there would be no breach of the strict wording of purpose (b) because neither Cookley nor Wolverley are towns. The proposal would not undermine purpose (b), which is to prevent neighbouring towns merging into one another. 52 CD12.40. 53 CD12.02. 54 CD12.06. In paragraph 22 of Samuel Smith the Supreme Court stated that as a barrier to urban sprawl a quarry may be regarded in Green Belt policy terms as no less effective than a stretch of agricultural land.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision https://www.gov.uk/planning-inspectorate 13

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision https://www.gov.uk/planning-inspectorate 13 Appeal Decision APP/E1855/W/22/3310099 63. Green Belt purpose (c) is to assist in safeguarding the countryside from encroachment. The proposed quarrying operation would encroach into the countryside, insofar as it would introduce a form of development into a part of the open countryside. However, it seems to me that the nature and scale of mineral extraction with progressive restoration in this case would not be so intrusive that it would bring the proposal into significant conflict with purpose (c). STQC highlights the importance of the former parkland to the historic setting and character of Cookley and Wolverley. Even if Cookley, Wolverley and Kidderminster were considered to be historic towns, I am satisfied that with appropriate landscaping the separation distance of the proposed quarry from these settlements would be sufficient to preserve their setting and special character so far as purpose (d) is concerned. The proposal would not conflict with purpose (e), which is to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 64. The appeal scheme would not conflict with the purposes of including land within the Green Belt.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Subject to the imposition of appropriate planning conditions, mineral extraction and inert waste infilling could be undertaken to high environmental standards, as required by the NPPW, and the site could be restored to a high calibre landscape. However, I have found that the appeal scheme would not preserve the openness of the Green Belt. That is sufficient by itself to debar the proposed development benefitting from the NPPF exception for mineral extraction in the Green Belt. 65. The proposal would be inappropriate development in the Green Belt, which is by definition harmful to the Green Belt. The following sections of this decision consider whether the appeal scheme would result in any other harm, and then has regard to other considerations, so that a balancing exercise can be undertaken to determine whether VSC exist. Character and appearance of the area 66. The character and appearance of the area, except as it relates to Green Belt openness, is not a matter of concern for WCC.55 But it is an issue for STQC.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision There is considerable local concern about the operational impacts of the proposal on the historic landscape and harm to the visual amenity of the area.56 STQC also raises concerns about the suitability of the proposed concept restoration scheme. 67. The site lies within National Character Area 66 Mid Severn Sandstone Plateau. Within the regional landscape character assessment, it is part of the Kinver Sandlands LCA. At a more local level the site lies within the Sandstone Estatelands, which is characterised as an open rolling landscape with an ordered pattern of large fields, typically defined by straight thorn hedges. The guidelines for this area seek to restore the distinctive hedgerow pattern and woodland planting.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision There is considerable local concern about the operational impacts of the proposal on the historic landscape and harm to the visual amenity of the area.56 STQC also raises concerns about the suitability of the proposed concept restoration scheme. 67. The site lies within National Character Area 66 Mid Severn Sandstone Plateau. Within the regional landscape character assessment, it is part of the Kinver Sandlands LCA. At a more local level the site lies within the Sandstone Estatelands, which is characterised as an open rolling landscape with an ordered pattern of large fields, typically defined by straight thorn hedges. The guidelines for this area seek to restore the distinctive hedgerow pattern and woodland planting.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The more detailed landscape description unit for the site, the Churchill Sandstone Estatelands, refers to the undulating topography with impoverished soils and tree cover in ordered patterns with parkland and belts of trees.57 STQC’s evidence states that the appeal site is part of an important, attractive, and valued landscape.58 There is no specific evidence to indicate 55 rID2 SoCG paragraph 8.11 refers to the submitted Landscape and Visual Impact Assessment (CD1.04), which states that there were no objections from the County Landscape Officer or Hereford and Worcester Gardens Trust. 56 rID26. 57 CD1.04. 58 rPOE3.02 paragraph 4.18. https://www.gov.uk/planning-inspectorate 14

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The more detailed landscape description unit for the site, the Churchill Sandstone Estatelands, refers to the undulating topography with impoverished soils and tree cover in ordered patterns with parkland and belts of trees.57 STQC’s evidence states that the appeal site is part of an important, attractive, and valued landscape.58 There is no specific evidence to indicate 55 rID2 SoCG paragraph 8.11 refers to the submitted Landscape and Visual Impact Assessment (CD1.04), which states that there were no objections from the County Landscape Officer or Hereford and Worcester Gardens Trust. 56 rID26. 57 CD1.04. 58 rPOE3.02 paragraph 4.18. https://www.gov.uk/planning-inspectorate 14

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 that the site is a valued landscape for the purposes of applying NPPF paragraph 187. 68. The parkland trees that remain on the appeal site, including the Wellingtonia, give an appreciation of this as former parkland, associated with entrance gatehouses and containment within estate walls. An operational quarry would have an adverse impact on this distinctive landscape. However, I accept that important trees could be protected by the imposition of appropriate planning conditions.59 Furthermore, the concept restoration scheme would add features that would enhance the landscape character of the area. 69. The appellant’s assessment finds that the overall slight/moderate adverse effect on the character of the area would be offset by the slight/moderate beneficial effect that would result from the site restoration. Harm during the operation would be balanced, to some extent, by the landscape benefits of the restoration planting. But I consider that the appellant’s assessment understates the likely impact of the proposal on the character of the area, particularly with respect to the local soundscape during the quarrying operation. 70.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision For the reasons given later in this decision, the scheme could be operated within the limits for noise sensitive properties set out in the Minerals PPG. But no noise limits are set for receptors outside these properties, such as those using the PRoW.60 However, NPPF paragraph 198 provides that decisions should ensure that new development is appropriate for its location taking into account the likely effects on, amongst other things, the potential sensitivity of the site to impacts that could arise from the development. In doing so, the NPPF requires the identification and protection of tranquil areas that have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. Without any minerals guidance on acceptable limits outside noise sensitive properties, it seems to me that this is a matter of judgement. There is evidence of how much the local ambience is cherished in the 2,030 letters of representation submitted about the application, along with the many submissions to the Inquiry.61 71.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The submitted noise survey results indicate some relatively low daytime background levels.62 It seems likely that L background levels for the western A90 and central parts of the appeal site, including in the vicinity of the proposed conveyor, would be similar to those at The Bungalow. No noise predictions were originally submitted for the PRoWs crossing through the appeal site. But in most cases, it would be reasonable to presume that noise levels from the quarrying operation along parts of these routes would be higher than those predicted at the noise survey locations, which are located towards the outer boundaries of the appeal site.63 59 rID2 paragraph 2.17, CD10.1 paragraphs 737-738, rID7, rID157/rID230, rID235.02 suggested Conditions 4, 43 and 47. 60 rID240 paragraph 100. 61 rID19 paragraph 3 and rID24. 62 rPOE2.10 Table 4 records levels as low as 31 dB LA90 at The Bungalow and Castle Barns. 63 rPOE2.10 Appendix B. https://www.gov.uk/planning-inspectorate 15

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 72. I asked for noise predictions on bridleway WC-626 near to the proposed conveyor. This predicts that levels would be between 63-51 dB L within Aeq,T 1-10 m of the conveyor.64 These levels of plant noise would be considerably higher than current background levels, as indicated by the recorded levels at The Bungalow, which range from 31-44 dB L across the 2018, 2023 and A90 2024 surveys. I accept that plant noise levels would decrease with distance from the point where bridleway WC-626 would pass over the conveyor, but they are indicative of some of the likely changes to the soundscape in an area acknowledged to have some tranquillity.65 I consider that the proposed development would result in harm to the character of the area by the introduction of intrusive noise, particularly during Phases 1-3, in a tranquil area, relatively undisturbed by noise, that is prized for its recreational and amenity value. 73. Turning to visual effects, the harm I have identified to visual aspects of the openness of the Green Belt would also have an adverse effect on the appearance of the area.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision However, the proposed hedgerow, tree and woodland planting would have a beneficial visual effect in the long-term. 74. STQC is critical of the concept restoration and refers to the submitted cross sections as showing a substantially different landform that would replace the existing “rolling countryside with a desolate flat crater”.66 In particular, concern was expressed about the view of the restored landform from VP8.67 It was apparent from the submitted material and my site visit that the restoration, albeit at a lower level, would not be flat and featureless. Gradients would not be so dissimilar to the existing rolling landform to appear out of place in the wider landscape.68 Concern was expressed that the impoverished soil might hinder establishment of hedgerows and trees.69 This is a consideration that could be taken into account in devising appropriate landscaping for this site. I consider that the proposed restored landform would be appropriate for the local context and that a suitable landscaping scheme could be designed and implemented in accordance with planning conditions. 75.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The slight to moderate harm to sensitive visual receptors during the operational phases of the quarry would be balanced by the slight to moderate beneficial visual effects that would result from the proposed restoration. However, during the operation the quarry would have an adverse effect on the landscape resource of slight/moderate significance that would not be entirely outweighed by the landscape benefits on restoration. The proposal would be at odds with the aims of MLP Policy MLP33, which states that planning permission will be granted where it is demonstrated that the development will conserve and enhance the character and distinctiveness of the landscape. There would also be some conflict with the underlying objectives of WCS Policy WCS12 regarding waste management facilities protecting local characteristics. Overall, 64 rID37 Table 3a 63-55 dB LAeq,T for rider on horseback; 62-52 dB LAeq,T for horse; 62-51 dB LAeq,T for pedestrian.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision This evidence was not before the previous Inspector, who concluded that the quarry would not likely result in any significant adverse noise impacts for those visiting the site area and concluded that the landscape benefits of the scheme should be afforded moderate weight in the planning balance. 65 In cross-examination regarding application of the then NPPF paragraph 191 and reducing noise to a minimum, not only for residential quality of life, Ms Canham for the appellant was asked whether the appeal site could be fairly described as a tranquil area, and replied “possibly yes”. 66 rPOE3.02 paragraph 4.20. 67 rID76 and rID223. 68 rID2 paragraph 8.11 and rID226. 69 rID22. https://www.gov.uk/planning-inspectorate 16

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision This evidence was not before the previous Inspector, who concluded that the quarry would not likely result in any significant adverse noise impacts for those visiting the site area and concluded that the landscape benefits of the scheme should be afforded moderate weight in the planning balance. 65 In cross-examination regarding application of the then NPPF paragraph 191 and reducing noise to a minimum, not only for residential quality of life, Ms Canham for the appellant was asked whether the appeal site could be fairly described as a tranquil area, and replied “possibly yes”. 66 rPOE3.02 paragraph 4.20. 67 rID76 and rID223. 68 rID2 paragraph 8.11 and rID226. 69 rID22. https://www.gov.uk/planning-inspectorate 16

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 I find that the harm to the landscape character of the area weighs against the proposal in the planning balance. Local amenity and living conditions 76. Many interested persons raised concerns about noise, dust, air quality, outlook and the effects on the health and well-being of those living in the locality, attending education facilities or visiting the area for recreation or other purposes. These were not issues for WCC, and STQC advanced no further specialist evidence on these matters. However, STQC referred to the evidence of other submissions to the Inquiry, including from the residents of The Bungalow, the equestrian business, PRoW users and Heathfield Knoll School, particularly in the light of Defra’s updated interim guidance on PM .70 2.5 77.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The technical evidence submitted by the appellant about noise, which is based on reasonable worst-case conditions, demonstrates that the appeal scheme could be operated in accordance with the limits set out in the Minerals PPG.71 Specific noise limits could be imposed by condition for nearby dwellings.72 During the removal of soils and the creation of screen bunds or restoration works, the noise limit at these receptor locations could be limited to 70 dB L (free field) for a period of up to 8 weeks in any calendar year.73 Aeq 1-hour Subject to these conditions the proposed development would accord with the policy aims of the NPSE to avoid significant adverse impacts on health and quality of life. 78. The evidence submitted by the appellant reasonably complies with Defra’s Interim Planning Guidance for PM Targets, which advises that evidence 2.5 should be provided to identify key sources of air pollution within the scheme and appropriate action taken to minimise emissions of particulate matter (PM) as far as is reasonably possible.74 The action here includes the submission of detailed dust monitoring proposals that could be the subject of a planning condition.75 79.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The potential for the appeal scheme to cause silicosis was a serious and emotive concern in many submissions and representations to the Inquiry.76 Silicosis results from the inhalation of respirable crystalline silica (RCS). It is acknowledged that some of the PM arising from quarrying operations can comprise RCS, which is a recognised hazard for personnel working at quarries. This risk is increased where minerals are crushed. Processing within the Plant Area would involve crushing, screening and sorting. However, investigations have determined that there is only a small proportion of oversized gravel within the deposit and therefore a large crusher section would not be required within the plant.77 Details about a crusher, including the use of water to control dust emissions during crushing, could be a matter for approval.78 Blasting and crushing imported material could be prohibited by condition.79 70 rID27, rID67, rID68 and rID225. 71 CD1.07, rID37, rID215 and rID222. 72 CD235.02 Suggested Condition 31. 73 CD235.02 Suggested Condition 32. 74 ES and ES Addendum, rPOE2.02 and rID38. 75 rID75. 76 rID55. 77 rPOE2.02 paragraph 4.5.3. 78 rID235.02 Suggested Condition 10 and rID230.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision 79 rID235.02 Suggested Conditions 58 and 55. https://www.gov.uk/planning-inspectorate 17

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision 79 rID235.02 Suggested Conditions 58 and 55. https://www.gov.uk/planning-inspectorate 17 Appeal Decision APP/E1855/W/22/3310099 80. Reference was made at the Inquiry to a documented case of silicosis apparently in Australia. There is insufficient information about the specific circumstances that applied in that case, particularly regarding the local environment and air quality controls, to draw any meaningful conclusions about the likely effects of RCS for the appeal scheme.80 81. Health and Safety Executive advice is that no cases of silicosis have been documented among members of the general public in Great Britain, indicating that environmental exposure to silica dust is not sufficiently high to cause this occupational disease. Local concern about silicosis is understandable, but in the absence of evidence to indicate that the appeal scheme would pose a significant risk to the local population due to RCS, it is not a consideration that can be given much weight in determining this appeal. 82. Heathfield Knoll School and First Steps Nursery would be separated from mineral extraction in Phase 3 by the B4189, intervening woodland within the appeal site and 3 m high Bund 15.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Noise from operations in Phase 3, particularly during bund construction and removal, might be audible within the school/nursery grounds, but this would be for a limited duration. Subject to the imposition of appropriate planning conditions the quarrying operation would be unlikely to have an unacceptable adverse impact on the school and nursery by reason of dust or noise. The school has recently acquired an adjacent meadow that would be used for outdoor educational activities.81 Part of the meadow lies close to the B4189, but the majority of the area is set well back from the road and unlikely to be significantly affected by noise from Phase 3. 83. Given the separation distance between Bund 7 and The Bungalow, along with the temporary duration of the bund, the appeal scheme would not have an unacceptable overbearing or dominating impact on the outlook from this property. Other dwellings are located further from the proposed bunds, or there is intervening vegetation, and so the proposed development would not adversely affect the living conditions of occupiers by reason of harm to their outlook.82 84.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision I consider that dust could be controlled by condition, and that noise for nearby properties could be contained within the limits set out in the Minerals PPG. There is considerable local fear and anxiety about air pollution and health risks from PM and RCS, which is sufficient here to be a material planning consideration in its own right. However, this is not a matter that attracts significant weight. 85. Taking into account the cumulative effects of multiple impacts, I find that the proposal would not give rise to unacceptable effects on amenity or health and well-being, and so would not conflict with MLP Policy MLP28 or be at odds with the requirements of WCS Policy WCS14. Subject to the imposition of appropriate planning conditions, the appeal scheme would comply with MLP Policy MLP29 concerning air quality, and would reasonably accord with WFLP Policy SP.16 concerning health and well-being. 80 rID72, rID184 and rID230. 81 rID70. 82 rID2 paragraph 9.2. https://www.gov.uk/planning-inspectorate 18

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 Public Rights of Way and access 86. There is evidence that footpaths and bridleways within the appeal site are well used and provide an important local recreational resource.83 Appropriate arrangements could be made throughout the operation to ensure that PRoW within the appeal site remained available for use. This would involve some temporary diversions that would need to comply with relevant statutory requirements. 87. Construction of the conveyor tunnel would require a temporary diversion of 30 m of bridleway to the adjacent field for two weeks, with alternative arrangements for vehicle access to The Bungalow and Lea Castle Equestrian Centre either from Castle Road/North Lodge access or running parallel with the existing track accessed from South Lodges.84 The same procedure would apply for one week when the tunnel was removed at the end of Phase 3. 88. These diversions and changes would be disruptive at times.85 In addition, activity associated with the quarry, including refuelling vehicles regularly crossing bridleway WC-626 during Phases 1-3, would detract from the experience for those using this route. 89.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Local equestrians consider that noise from the quarry operation, particularly from the proposed conveyor, would deter riders from using bridleways within the appeal site.86 They are also critical of the usefulness of some of the proposed additional bridleways because of noise and the proximity to traffic. However, the effects of noise on horses depends on many variables. Some quarrying activities might startle some horses. But possible effects on horses and equestrians are not considerations that would justify dismissing the appeal. Any such harm must be weighed against the long-term benefits of the appeal scheme, which would provide new bridleways. STQC argues that permissive paths provide no benefit because they could be withdrawn at any time.87 Any permissive paths created would not provide the same rights for users as PRoW, but would be a useful addition to routes available to equestrians and walkers in the locality. In any event, the UU here makes specific provision for additions to the network, whether by public access routes made available in perpetuity under the planning system or by formal dedication as PRoW.88 90.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Overall, I consider that any harm to users of the local PRoW network during the operational phases of the quarry would be outweighed by the benefits of the proposed additional routes and recreational opportunities post restoration. I find no conflict with MLP Policy MLP30 concerning access and recreation. This is a consideration that attracts some positive weight in favour of the proposed development. Heritage assets 91. The North Lodges and Gateway to Lea Castle grade II listed building is an impressive entrance to the former castle parkland. The listed building has associations and shares group value with the estate buildings that are non- designated assets. Bridleway WC-625B passes through the gateway and leads 83 rPoE3.06. 84 rID78 and rID110. 85 rID228 and rID234. 86 rPOE3.06, rID31, rID32, rID36 and rID147. 87 rID233. 88 rID240 paragraph 109. https://www.gov.uk/planning-inspectorate 19

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 to the northern part of the appeal site. The former castle parkland forms part of the setting of the gateway and contributes to its significance. 92. Bund 17 in Phases 4 and 5, along with quarrying activity during Phase 5, in the northern part of the appeal site would, to some extent, detract from the function of the gateway as an approach to the former parkland. However, any resultant harm to the setting of the listed building would be for a limited duration. Furthermore, reinstatement of the avenue of trees along bridleway WC-625B with site restoration would enhance the historic significance of the setting of North Lodges and Gateway to Lea Castle. I have had regard to the group value of the heritage assets in the locality of the listed building. Overall, I consider that the proposal would result in less than substantial harm, towards the lower end of the scale, to the significance of North Lodges and Gateway to Lea Castle grade II listed building. 93. STQC argues that the boundary wall of the former parkland is curtilage of North Lodges and Gateway to Lea Castle. The Official List Entry does not mention the wall.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The Local List reference to 1 South Lodge refers to the “wall for Lea Castle estate springs from western elevation of building”.89 This reference does not support STQC’s view that the wall along the B4189 falls within the curtilage of North Lodges and Gateway. I am not satisfied that the evidence adduced establishes that the wall is part of the curtilage of the listed building. Reinstatement of the boundary wall along the B4189 when the access was no longer required would restore its heritage significance. 94. The settings of Sion Hill House and Wolverley Court would not be adversely affected by the appeal scheme because of the intervening vegetation and topography, which would significantly restrict intervisibility between these listed buildings and quarrying activity. Similar considerations apply to the relationship between the appeal site and the Staffordshire and Worcestershire Canal Conservation Area. The proposed development would not harm the setting of the conservation area because the canal is largely confined within woodland set down at a lower level than the land at Phase 1 that would be the nearest part of the quarrying operation to the canal. 95.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The former parkland has insufficient surviving elements to warrant identification as a non-designated heritage asset. Any harm to the setting of the non-designated heritage assets in the locality during the operation of the quarry would be offset by the benefits to the heritage landscape by the proposed restoration that would include replanting of parkland avenues and Broom Covert. Archaeological interest in the appeal site could be safeguarded by the imposition of planning conditions. 96. The less than substantial harm I have identified to the significance of North Lodges and Gateway should be weighed against the public benefits of the proposal in accordance with NPPF paragraph 215 and MLP Policy MLP32(c). Highway safety 97. A suggested planning condition would limit HGV movements associated with the quarry to 77 movements in, and 77 movements out, of the appeal site per day on Monday to Friday, and other controls would be imposed on vehicle 89 rID46. https://www.gov.uk/planning-inspectorate 20

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 movements.90 Notwithstanding these restrictions, there is local concern about the effects of traffic associated with the quarry jeopardising the safety of vulnerable road users, including motor cyclists and pedestrians.91 In particular, many expressed concern about large vehicles from the quarry travelling through Wolverley, where there is restricted road width and narrow pavements in places, particularly near to the lock bridge. 98. I am satisfied that the design of the proposed new access onto the B4189 could prevent vehicles turning right out of, and left into, the appeal site. However, STQC considers that some HGVs might still travel via Wolverley to access the quarry. Effective controls could be imposed on the movements of the quarry operator’s own vehicles. The possibility of other vehicles not subject to these controls passing through Wolverley cannot be ruled out, but such trips would be likely to be few and largely absorbed within the daily variations in the traffic flow through Wolverley. HGV traffic associated with the appeal scheme would not significantly add to the risk of accessing Heathfield Knoll School and First Steps Nursery either by vehicle or on foot. 99.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision A safe and suitable access could be provided to the site for all users. Wheel cleaning could be the subject of a planning condition and any mud tracked out onto the highway could be the subject of enforcement proceedings.92 The highway authority has considered a Stage 1 Road Safety Audit, and the detailed design could be the subject of a planning condition.93 I consider that the likely residual cumulative impacts on the local road network would not be severe.94 Any potential conflict between those using PRoW within the appeal site and quarry vehicles could be managed by the imposition of appropriate planning conditions. I find no conflict with MLP Policy MLP39 concerning transport. There are no grounds to prevent the proposed development for highway safety reasons having regard to paragraph 116 of the NPPF. Biodiversity 100. The proposed quarrying operation would disrupt the local ecosystem for some 11 years. However, the restoration scheme would provide significant biodiversity benefits.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision An updated ecological assessment was submitted dated October 2024.95 The statutory 10% biodiversity net gain now required for planning applications does not apply to the appeal scheme, but MLP Policy MLP31 provides that planning permission will be granted where it is demonstrated that the development will conserve, enhance and deliver net gains for biodiversity. 101. The Biodiversity SoCG states that the proposed development would result in a 74.16% biodiversity net gain and a 300.93% net gain in hedgerow units.96 This would accord with MLP Policy MLP11 concerning the conservation, delivery and enhancement of green infrastructure networks within the North West Worcestershire Strategic Corridor. The technical assessment submitted reasonably demonstrates how, throughout its lifetime, the appeal scheme would optimise its contribution to green infrastructure priorities. These 90 On Saturdays 39 in and 39 out. RID235.02 Suggested Condition 21. The traffic movements in the Transport Statement do not assume any back-hauling between exports and imports (CD1.09 paragraph 9.8). 91 rID58. 92 rID59. 93 CD4.34 and rID235.02 Suggested Condition 13. 94 rPOE2.05, rID134 and rID204. 95 rID7. 96 rID5.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision https://www.gov.uk/planning-inspectorate 21

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision https://www.gov.uk/planning-inspectorate 21 Appeal Decision APP/E1855/W/22/3310099 priorities include: restoring characteristic hedgerow patterns and tree cover along watercourses; creating accessible semi-natural green space; and in the Sandstone Estatelands creating acid grassland. 102. The SoCG, dated 13 September 2024, records the weight to be given to biodiversity net gain benefit as a matter on which the parties are disagreed.97 However, WCC subsequently agreed in the Biodiversity SoCG, dated 4 October 2024, that these net gains should attract significant positive weight in the planning balance.98 Mr Whitehouse for WCC considers that the extent of the biodiversity net gain proposed should be given moderate weight in the planning balance.99 103. In the long-term the appeal scheme would benefit wildlife through delivery of hedgerows, woodland, tree planting, acid grassland and waterbodies. The proposal accords with MLP Policy MLP31. I consider that the net gains for biodiversity warrant significant positive weight for the proposal in the planning balance.100 Other environmental effects 104.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision There is local concern about the effects of the proposal on hydrogeology.101 Hurcott Residents’ Committee raises the potential for degradation of groundwater quality to affect nearby SSSIs.102 The submitted Hydrological and Hydrogeological Impact Assessment states that groundwater generally flows towards the River Stour, but also took into account data from the EA’s Hurcott, Podmore, Bisslewood and Puxton observation boreholes that indicate potential for groundwater discharge as a baseflow to Wannerton Brook to the south of the appeal site. However, the technical evidence indicates that the proposed mineral extraction would not significantly alter current groundwater recharge.103 105. Contamination of the underlying aquifer could result from accidental discharge of fuels or other pollutants, especially as the Inquiry was informed that mobile refuelling tankers would operate outside the Plant Area.104 Measures to safeguard against accidents and leakage could be the subject of stringent controls enforceable by the imposition of appropriate conditions.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Any hydrogeological risk from infilling would be a matter for consideration by the EA in determining an application for an Environmental Permit, and in imposing any conditions for the lining of quarried voids and monitoring. Drainage and flood risk are matters that could be addressed by planning conditions and the UU. On this basis, I find no conflict with MLP Policy MLP37 concerning groundwater. 97 rID2 paragraph 9.1. 98 rID5 paragraph 6.1.5. 99 rPOE1.02 paragraph 5.9. 100 The scheme that was considered by the previous Inspector would have delivered a biodiversity net gain of +39.31% units for habitat and +107.51% for hedgerow units, enhancements which the previous Inspector considered should be afforded only moderate weight. 101 rID178/rID230. 102 rID199. 103 CD1.13. 104 CD1.13 paragraph 5.6.5.3 sets out measures to minimise the risk of groundwater quality degradation, including that no refuelling or maintenance should be carried out in areas of mineral working. https://www.gov.uk/planning-inspectorate 22

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 106. The effects of any lighting of the quarrying operation could be limited by the implementation of an approved lighting scheme. Subject to such a condition, the proposed development would reasonably safeguard wildlife and would not have an unacceptable adverse effect on the amenity of the area.105 107. The appeal scheme would result in the temporary loss of BMV agricultural land. This would be justified by the need for minerals, which can only be worked where they are found. With appropriate planning conditions for soil management and restoration, agricultural land could be safeguarded for future use.106 The effects on BMV agricultural land do not weigh against the proposal. There is no conflict with MLP Policy MLP35. Employment and the economy 108. The appeal scheme would provide 11 full-time equivalent jobs. The direct and indirect benefits of the proposal would make a modest contribution to the local economy. Some additional economic benefits would arise from business rates and the aggregate levy. 109.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The Inquiry received many submissions from local residents and commercial interests who considered that these economic benefits of the appeal scheme would be outweighed by an adverse impact on existing businesses, reduced demand for housing, and fewer enrolments at Heathfield Knoll School and First Steps Nursery. Local apprehension about a quarry is understandable, but I am not convinced that there is substantive evidence to indicate that these concerns about the local economy would be realised if planning permission was granted. Any permission for a phased quarrying and restoration scheme would be subject to enforceable planning conditions. Infilling would be controlled by an Environmental Permit and planning decisions should assume that the pollution control regime will operate effectively.107 Subject to appropriate restrictions, the proposed development would not be likely to result in land use conflicts that would significantly impair local economic interests. 110. Perception of harm to the local economy is a material consideration, but it is not a matter that can be given much weight in determining this appeal.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision I consider that any local adverse economic impacts from the appeal scheme would be outweighed by the additional jobs during the operation of the quarry, along with the long-term benefits for recreation from the proposed restoration. Overall, I find that the appeal scheme would benefit the local economy. Need for sand/gravel, capacity for inert fill and availability of inert material 111. MLP Policy MLP1 seeks to direct mineral extraction within Strategic Corridors. The appeal site is located within the North West Worcestershire Strategic Corridor and within an Area of Search for sand and gravel, where MLP Policy MLP3 provides that planning permission will be granted for new mineral development within allocated areas of search where there is a demonstrated shortfall in supply. 105 rID109/rID230. 106 rID235.02 suggested Conditions 38-42 and 48. 107 NPPF paragraph 201. https://www.gov.uk/planning-inspectorate 23

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 112. There is an agreed landbank of 6.59 years for sand and gravel at the relevant assessment date of 31 December 2023.108 The Worcestershire Local Aggregate Assessment (LAA) identifies an annual production guideline for sand and gravel of 0.667 million tonnes per annum, derived from the 10-year sales average + 20%. The appellant considers that the LAA apportionment figure is too low and likely to need raising to allow for sufficient flexibility in demand for sand and gravel, including for increased housing construction.109 However, no convincing evidence was adduced to justify applying a higher apportionment figure.110 113. Paragraph 226 of the NPPF provides that mineral planning authorities should plan for a steady and adequate supply of aggregates by, amongst other things, maintaining landbanks of at least 7 years for sand and gravel, whilst ensuring that the capacity of operations to supply a wide range of materials is not compromised. MLP Policy MLP14 has similar provisions.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The PPG states that the aggregate landbank is principally a monitoring tool and the main basis for mineral planning authorities to consider whether to review the local plan, but it also adds that low landbanks may be an indicator that suitable applications should be permitted as a matter of importance to ensure the steady and adequate supply of aggregates.111 114. The appeal scheme would add 4.5 years to the landbank, which in the circumstances that apply in this case, would be a significant benefit. In addition, it would make a positive contribution to the geographical spread of the sources of supply for sand and gravel. Proximity to markets in Worcestershire and Birmingham might mean reduced transport emissions over possible alternative sources.112 However, there are many uncertainties and assumptions about this assessment that limit any weight that can be given to climate change benefits of the appeal scheme due to the location of markets. There is no convincing evidence of a significant need to spread supply across different marketplaces and so this is a consideration that attracts only moderate weight in the planning balance. 115.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision WCC takes no issue about sufficient supply of inert waste over the development period for site restoration.113 Evidence about decreasing void capacity for inert fill was not challenged. Nevertheless, there is insufficient detail to engage WCS Policy WCS5(a)ii about addressing a capacity shortfall necessary to achieve the aims and purposes of the WCS. The Inquiry also heard evidence about a likelihood of an increase in construction generating inert waste. The appellant refers to permitted major construction projects across the West Midlands, along with increased house building, that would be potential sources of inert waste.114 However, I share WCC’s reservations about the likelihood of large quantities of inert waste arising from large-scale development schemes in close proximity to the appeal site. The possibility of diverting infill material from NRS’s Meriden Quarry was raised by the appellant. Not much weight can be given to this because any planning permission for the appeal scheme would not be personal to NRS but would run with the land. Notwithstanding that the operator would benefit financially from accepting inert 108 rID8. 109 rID243.01. 110 rID69. 111 Minerals PPG Paragraph:082 Reference ID:27-082-20140306.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision 112 CD15.01 Section 8. 113 rPOE1.02 paragraph 4.130. 114 rID243.01. https://www.gov.uk/planning-inspectorate 24

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision 112 CD15.01 Section 8. 113 rPOE1.02 paragraph 4.130. 114 rID243.01. https://www.gov.uk/planning-inspectorate 24 Appeal Decision APP/E1855/W/22/3310099 fill, there is no certainty about its supply, and much would depend upon local commercial considerations. 116. The ES Addendum states that inert fill material for restoration would, where possible, be brought to the appeal site on NRS HGVs arriving to carry away sand and gravel.115 However, there is no guarantee that this would occur to a sufficient degree to amount to a sustainability benefit that should weigh in the planning balance in this case. WCC accepts that a new site at Lea Castle would be an environmentally better solution for managing inert waste from the south and west of Birmingham than hauling it further afield, but again commercial interests would be likely to determine the destination for inert waste.116 117. Additional capacity for inert waste would be of some benefit, but on the evidence adduced negligible weight can be given to any benefits arising from the sustainable movement of inert waste. There is a level of uncertainty about the availability of inert infill to meet the requirements for the proposed phased restoration.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision If restoration was delayed because of insufficient availability of inert infill material, the harm I have identified to the openness of the Green Belt would persist for longer, which would add to the harm I have identified. 118. The proposed development accords with MLP Policies MLP3 and MLP15 concerning the contribution towards the landbank and productive capacity in Worcestershire for a wide range of sand and gravel materials. In accordance with NPPF paragraph 224, great weight should be given to the benefits of mineral extraction, including to the economy. Planning balance 119. In applying the planning balance in this case, I have taken into account the suggested planning conditions that it would be necessary and reasonable to impose were planning permission to be granted. The suggested planning conditions concerning new bridleways would secure public access routes unless and until they were adopted as PRoW, and do not themselves seek to require dedication. 120. I have also had regard to the UU.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision These obligations would be consistent with paragraph 151 of the NPPF, which provides that in planning positively to enhance the beneficial use of the Green Belt, authorities should look for opportunities to provide access and outdoor sport/recreation, and to retain and enhance landscapes, visual amenity and biodiversity. I am satisfied that the UU would be necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind to the development, and so complies with Regulation 122 of the Community Infrastructure Levy Regulations 2010. The UU accords with MLP Policy MLP40. 121. The proposed development is inappropriate in the Green Belt, which is by definition harmful to the Green Belt. The planning balance is whether the potential harm by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations, so as to amount to the VSC necessary to justify the development. 115 CD15.01 paragraph 8.3.7. 116 rID8 paragraphs 162-178. https://www.gov.uk/planning-inspectorate 25

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 122. The harm I have identified to the Green Belt, including harm to its openness, should be given substantial weight in accordance with NPPF paragraph 153. In addition, I have found that the proposal would have an adverse effect on the landscape character of the area, which should be given slight weight. I have given considerable importance and weight to the less than substantial harm to the significance of the designated North Lodges and Gateway to Lea Castle that I consider would result from the appeal scheme. However, the public benefits of mineral extraction and to the economy would outweigh this harm. In the absence of convincing evidence that the perception of harm to public health would be likely to have material land use consequences, I consider that little or no weight can be given to local health fears. 123. The appellant considers that the following benefits are capable of amounting to VSC: need for the proposed development with particular regard to the landbank position for sand and gravel; environmental, sustainability and climate change benefits; development, growth and economic considerations; and restoration and biodiversity benefits.117 124.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision The proposal would make an important contribution to the landbank, which would help in achieving development and growth. I consider that the benefits of the proposed sand and gravel extraction and the contribution the appeal scheme would make to the economy attract great weight. Employment provision and the supply of goods and services for the operation would provide direct and indirect benefits to the local economy that should be given moderate weight. The contribution of the proposal to the geographical spread of mineral resources, along with additional capacity for inert waste, also warrant moderate weight. But for the reasons set out above, no weight should be given to the likely contribution that the proposal would make to the sustainable movement of inert waste. The biodiversity benefits of the proposal should be given significant weight. Harm to users of the local PRoW network during the operational phases of the quarry would be outweighed by the benefits of the proposed additional routes and recreational opportunities post restoration, which is a consideration that should be given slight weight in favour of the proposal. 125.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision In my judgement, the substantial weight that should be given to the harm to the Green Belt and its openness, along with slight weight given to the harm to the landscape character of the area, outweighs the combined weight of the benefits of the appeal scheme as set out above. I find that the other considerations in this case do not clearly outweigh the harm by reason of inappropriateness, and any other harm, that I have identified. Consequently, the VSC necessary to justify the development do not exist. The appeal scheme conflicts with local Green Belt policies in the development plan and is contrary to national policy in the NPPF. Planning policy 126. The appeal scheme would accord with some development plan policies, including heritage policies; MLP Policy MLP32, WCS Policy WCS9 and WFLP Policies SP.21 and DM.23. But the conflict with local Green Belt policies; MLP Policy MLP27, WCS Policy WCS13 and Policy DM.22 of the WFLP, brings the proposal into conflict with the development plan when taken as a whole. 117 rPOE2.12 paragraph 10.1.5. https://www.gov.uk/planning-inspectorate 26

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — Appeal Decision Appeal Decision APP/E1855/W/22/3310099 127. The low landbank here is not an indicator that the proposal should be permitted as a matter of importance to ensure the steady and adequate supply of aggregates because I have found that the appeal scheme is not a suitable application for the purposes of applying the Minerals PPG. There are no other material considerations that indicate that the appeal should be determined other than in accordance with the development plan. Other matters 128. I have taken into account all the other matters raised in the evidence, but none are sufficient to outweigh my conclusions on the main issues, which have led to my decision on this appeal. Conditions 129. There is no evidence before me to indicate that the imposition of any other necessary and reasonable planning conditions would enable a different planning balance to be struck and for planning permission to be granted for the appeal scheme. Conclusion 130. The planning balance for the appeal scheme falls against the proposal. The proposed development would conflict with the development plan, when taken as a whole. For the reasons given above the appeal should be dismissed.

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock INSPECTOR https://www.gov.uk/planning-inspectorate 27

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock INSPECTOR https://www.gov.uk/planning-inspectorate 27

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 APPEARANCES FOR WORCESTERSHIRE COUNTY COUNCIL (WCC): Sarah Clover Instructed by Thomas Pollock Head of Counsel Commercial Law WCC She called Christopher Whitehouse MRICS Managing Director Nextphase Development BSc (Hons) RICS FOR THE APPELLANT: Instructed by Liam Toland Planning Jenny Wigley KC Counsel She called Rachel Canham BEng (Hons) MSc Director of Walker Beak Mason Limited (WBM) CEng FIOA Rob Sutton BSc (Hons) MCIfA Director of Heritage Consultancy at Cotswold Archaeology Neil Furber BSc (Dual Hons) Landscape Director at Pegasus Group PGDip LA CMLI Liam Toland BA (Hons) MSc Liam Toland Planning MRTPI Witten evidence by Katrina Hawkins BSc (Hons) MSc Smith Grant LLP CEnv MIES MIAQM Jeremy Hurlstone BSc (Hons) The Hurlstone Partnership CMILT MCIHT FOR STOP THE QUARRY CAMPAIGN (STQC): Instructed by Tim Partridge Sioned Davies Counsel She called Rebecca Hatch Local resident Matt Harthill Local resident Bill Houle FRICS Local resident Mike Lord BA (Hons) Business Local resident Tim Partridge BA (Hons) Dip Associate Partner Rapleys and Planning Studies MRTPI Local resident INTERESTED PERSONS: Katherine Evans Local resident Jemma Powell-Tibbetts Local resident Elizabeth Rushton

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Local resident Bill Southam Local resident Mark Garnier MP Member of Parliament for Wyre Forest Rebecca Vale Local resident https://www.gov.uk/planning-inspectorate 28

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Local resident Bill Southam Local resident Mark Garnier MP Member of Parliament for Wyre Forest Rebecca Vale Local resident https://www.gov.uk/planning-inspectorate 28

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 Heather Cox Local resident Joanna Phillips Local resident Geoff Cox Local resident Cllr Marcus Hart Wolverley and Cookley Parish Council, Wyre Forest District Council, Worcestershire County Council Cllr Ben Brookes Wolverley and Cookley Parish Council Maxine Huslebee Local resident Dr Peter King Chairman Campaign to Protect Rural England Worcestershire Sheila Nock Local resident Andrew McDonald Local resident Victoria Crisp Local resident Charlotte Bennett Local resident Dean Talbot Local resident Alex Badger Local resident Cllr David Jones Wolverley and Cookley Parish Council Andrew Webber Local resident Karen Anderson Local resident Read out statement by Mel Anderson Judy Hinksman Local resident Robin Buchanan-Morgan Local resident Giovanna and Theodore Pupils at Heathfield Knoll School DOCUMENTS SUBMITTED FOR THE RE-DETERMINATION INQUIRY (rID) Documents submitted before the opening of the Inquiry rID 1 Summary Note Case Management Conference 7 August 2024 rID 2 Revised Statement of Common Ground General - Signed 13 September 2024 rID 3 Minerals and Waste Statement of Common Ground - Signed 13 September 2024 (Superseded by Revised Minerals and Waste Statement of Common Ground -

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Signed 7 October 2024 see rID8) rID 4 Pre-Inquiry Note 1 dated 26 September 2024 rID 5 Biodiversity Statement of Common Ground - Signed 4 October 2024 rID 6 The Statutory Biodiversity Metric dated 3 September 2024 rID 7 Updated Ecological Assessment dated October 2024 rID 8 Revised Minerals and Waste Statement of Common Ground - Signed 7 October 2024 rID 9 Revised Schedule of Conditions - Original Appeal Scheme dated October 2024 rID 10 Revised Schedule of Conditions - Amended Appeal Scheme dated October 2024 rID 11 Revised Schedule of Plans - Amended Appeal Scheme dated October 2024 rID 12 Appellant's Submissions on Amendments rID 13 Submissions on Amended Application on behalf of Worcestershire County Council rID 14 Rule 6 Party (STQC) Submissions on the 2024 Scheme Amendments https://www.gov.uk/planning-inspectorate 29

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 rID 15 Agenda for Round Table Discussion about dealing with the appeal scheme on the basis of an amended scheme rID 16 Comparison table regarding bunds within the Original Appeal Scheme and the proposed Revised Appeal Scheme Documents submitted during the Inquiry rID 17 Appellant’s Opening Submissions rID 18 Opening Submissions on behalf of WCC rID 19 Opening Statement on behalf of STQC rID 20 Statement by Elizabeth Hope Rushton rID 21 Statement by Mark Garnier MP rID 22.01 Statement by Bill Southam 22.02 Written Submission by Bill Southam rID 23 Statement by Heather Cox rID 24 Statement by Geoff Cox rID 25 Statement by Dr Peter King CPRE rID 26.01 Statement by Sheila Nock 26.02 Statement by Sheila Nock 26.03 Landscape questions by Sheila Nock 26.04 Noise questions by Sheila Nock rID 27.01 Statement by Mr and Mrs McDonald 27.02 Written Submission by Mrs McDonald 27.03 Questions by Mr McDonald rID 28 Statement by Dean Talbot rID 29 Written Submission by Sara Lloyd rID 30 Written Submission by Dominic Carty rID 31 Written Submission by Georgina Poolton Field Equine Vets rID 32 Written Submission by Wendy Bannerman British Horse Society rID 33 Written Submission by Linda Blakemore and

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Stephen Blick rID 34.01 Written Submission by Gill Hill 34.02 Written Submission by Gill Hill rID 35 Written Submission by Claire and Jonathan Bowen rID 36 Advice on Diverting a public bridleway or byway The British Horse Society rID 37 Response to Inspector’s request for further details about noise predictions WBM Acoustic Consultants dated 6 November 2024 rID 38 Note regarding changes in heights of bunds Smith Grant LLP dated 5 November 2024 rID 39 Written Submission by Councillor Mary McDonnell rID 40 Written Submission by Lisa Jones rID 41 Written Submission by Ian Hinksman rID 42 [Not used] rID 43 Written Submission by Amy Bailey rID 44 Written Submission by Rachel Guest rID 45 Email from Worcestershire County Council about Ware Park appeal decision rID 46 Wolverley and Cookley Local Heritage List rID 47 Staffordshire and Worcestershire Canal Conservation Area Maps rID 48 Written Submission by Mrs Marcie Smith rID 49 Written Submission by Emily Smith rID 50 Written Submission by Adam Seagrave rID 51 Written Submission by Corinna Smith https://www.gov.uk/planning-inspectorate 30

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 rID 52 Written Submission by Lisa Wheeler rID 53 Written Submission by Gemma Butcher rID 54 Written Submission by Victoria Grainger rID 55 Written Submission by Andrew Richards rID 56 NRS SAREDON AGGREGATES LIMITED Company number rID 57 NRS Saredon Aggregates name change document Certificate and Resolution rID 58 Statement by Andrew Webber rID 59.01 Statement by Maxine Huselbee 59.02 Written Submission by Maxine Huselbee rID 60 Statement by Alex Badger rID 61 Statement by Judy Hinksman rID 62 Written Submission by Pat Seagrave rID 63 Written Submission by Kara Mikolajczyk rID 64 Written Submission by Amie Bash rID 65 Written Submission by Jim Wells rID 66 Written Submission by Kay Nicholls rID 67 Statement by Representative of Heathfield Knoll School - Giovanna rID 68 Statement by Representative of Heathfield Knoll School - Theodore rID 69 WCC’s commentary regarding the annual production guidelines of other authorities rID 70 Land Registry Title Plan for the Meadow rID 71 Agreed Note on EIA Consultation Requirements and Newspaper Public Notice 1-31 August 2024 rID 72 Statement by Karen Anderson rID 73 WCC Response to Inspectors Queries re Conditions 11 November 2024 rID 74 Imported

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Inert Restoration Materials Summary rID 75 Lea Castle Farm - Dust Monitoring Proposals-v1 rID 76 Lea Castle Photomontage Viewpoint 8 Figures 11 and 11a rID 77 ESP comments re gas and electricity apparatus dated 11 November 2024 rID 78 Appellant's Response to the Inspector’s Site Visit Questions 13 November 2024 re boundary wall opposite Heathfield Knoll School and construction of the conveyor rID 79 Mineral Products Association Restoration Guarantee Fund NRS Acceptance 17 November 2023 and MPA Membership Certificate rID 80 Revised Figures 65a and 65b rPoE2.08 rID 81 Written Submission by Carol Fearn rID 82 Written Submission by Georgina Braley rID 83 Written Submission by Kerise Parker, John Reece, Lola, Rory, Amelia rID 84.01 Written Submission by Mrs Marcie Smith 84.02 Written Submission by Marcie Smith rID 85 Written Submission by Mr and Mrs Smith rID 86 Written Submission by Simon Betts rID 87 Written Submission by Mr Aamer Deen, Mrs Sunita Kaur rID 88 Written Submission by Sarah Betts rID 89 Written Submission by David and Jane Jones rID 90 Written Submission by R J Jinks rID 91 Written Submission by Andrew Jones rID 92 Written Submission by Camilla Lloyd rID 93 Written Submission by Helen Leedham

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock https://www.gov.uk/planning-inspectorate 31

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock https://www.gov.uk/planning-inspectorate 31

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 rID 94 Written Submission by Sue Knowles rID 95 Written Submission by Harry Edwards rID 96 Written Submission by Jason Tait rID 97 Written Submission by James Walker rID 98 Written Submission by Claire Yarnold rID 99 Written Submission by Ashley Yarnold rID 100 Written Submission by Jackie Yarnold rID 101 Written Submission by Elizabeth Hope Rushton rID 102 Written Submission by Chris Harper-Dukes rID 103 Written Submission by Angela and Neville Stephens rID 104 Written Submission by Pamela Edwards rID 105 Written Submission by Barry Lewis rID 106 Written Submission by Sallyanne Skidmore rID 107 Written Submission by Emma Stirling rID 108 Written Submission by Natalie Harrison rID 109 Written Submission by Jan Porter rID 110 Note on Conveyor Construction and Removal rID 111 WCCs Response to Inspector’s without-prejudice observations on WCC’s response to Inspector’s previous queries about suggested planning conditions 13 November 2024 rID 112 Statement by Mel Anderson rID 113 Written Submission by Joanne Powell rID 114 Written Submission by Taryn Hill rID 115 Written Submission by Alison Cooke rID 116 Written Submission by Emily Smith rID 117 Written Submission by Emma Dungey rID

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock 118.01 Written Submission by Katie Powell 118.02 Written Submission by Katie Powell rID 119 Written Submission by Victoria Grainger rID 120 Written Submission by Peter Cook rID 121 Written Submission by Neil Colclough rID 122 Written Submission by Rosie Peerman rID 123 Written Submission by Mrs Morgan and Family rID 124 Written Submission by Leah Clark rID 125 Written Submission by Helen Reeves rID 126 Written Submission by Bridget Homer rID 127.01 Written Submission by Kevin Tebbett 127.02 Written Submission by Kevin Tebbett rID 128 Written Submission by Abigail Povey rID 129 Written Submission by Maddie Ridley rID 130 Written Submission by Lorna Richards rID 131 Written Submission by Mrs Samantha Mucklow rID 132 Written Submission by Gillian Kane rID 133 Written Submission by Megan Gear rID 134 Written Submission by Catherine Cape rID 135 Written Submission by Abi Ceney rID 136 Written Submission by Alison Murphy rID 137 Written Submission by Amy Palmer rID 138 Written Submission by Andy Rudall rID 139 Written Submission by Anthony Murphy rID 140 Written Submission by Becky Lynch rID 141 Written Submission by Bill Hope rID 142 Written Submission by Cookley Cricket Club https://www.gov.uk/planning-inspectorate 32

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 rID 143 Written Submission by Hannah, Sam, Connie and Edgar Stockley rID 144 Written Submission by Helen Spiers rID 145 Written Submission by Jazz Watkins rID 146 Written Submission by Jennifer Owen rID 147 Written Submission by Jill Aston rID 148 Written Submission by Joanne Jones rID 149 Written Submission by Joe Harvey rID 150 Written Submission by John and Julieanne Priest rID 151 Written Submission by John Hobbs rID 152 Written Submission by Julieanne Priest rID 153 Written Submission by Karen Baldwin rID 154 Written Submission by Ken Powell rID 155 Written Submission by Lauren Hancock rID 156 Written Submission by Lynda Woodhouse rID 157 Written Submission by Mark Jones rID 158 Written Submission by Mark Watkins rID 159 Written Submission by Mike Watkins rID 160 Written Submission by Mrs Caroline Cook rID 161 Written Submission by Mrs Jo Metcalf rID 162 Written Submission by Mrs K Chestney rID 163 Written Submission by Mrs Pauline Jones rID 164 Written Submission by Nick Turner rID 165 Written Submission by Paul Watts rID 166 Written Submission by Pete Thompson rID 167 Written Submission by Rachael and Robert Cunningham rID 168 Written Submission by Rebecca Bostock rID 169

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Written Submission by Rebekah Lewis rID 170 Written Submission by Robin Thomas rID 171 Written Submission by Sally Fallon rID 172 Written Submission by Sarah Louise Turner rID 173 Written Submission by Victoria Newton rID 174 Written Submission by Vince Newman rID 175 Written Submission by Yolande Biggs rID 176 Written Submission by Amie Jones rID 177 Written Submission by Amy Bennet rID 178 Written Submission by Carole Pannell rID 179 Written Submission by Chris Hathaway rID 180 Written Submission by Fern Osazuwa-Bagley rID 181 Written Submission by Gavin Bromley rID 182 Written Submission by James Hinton rID 183 Written Submission by James Powell rID 184 Written Submission by Joanna McNeill rID 185 Written Submission by Jodie Dipaola-Smith rID 186 Written Submission by Jodie Yardley rID 187 Written Submission by Mildred Mukwende rID 188 Written Submission by Roderick Shaw rID 189 Written Submission by Sanjit Kandola rID 190 Written Submission by Sanjit Johal rID 191 Written Submission by John Knowles rID 192 Written Submission by Lauren Oakes rID 193 Written Submission by Jeffrey Whalley rID 194 Written Submission by Alison Billingsley rID 195 Written Submission by Alex Webster and Mollie Tromans

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock https://www.gov.uk/planning-inspectorate 33

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock https://www.gov.uk/planning-inspectorate 33

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 rID 196 Written Submission by Martine Hirrell rID 197 Written Submission by Mrs Diane Hamilton rID 198 Written Submission by Emma Hamilton and Philip Pountney rID 199 Statement by Katherine Evans for the Hurcott Residents’ Committee rID 200 Written Submission by Michelle Humphries rID 201 Written Submission by Kellie Jones rID 202 Written Submission by Amanda Brighton rID 203 Written Submission by Mr Richard Cook rID 204 Appellant’s highway response dated 12 November 2024 to rID58 by The Hurlstone Partnership rID 205 Written Submission by David Langford rID 206 Written Submission by Laura O'Neill rID 207 Written Submission by Haley and Russell Hadley rID 208 Written Submission by Jackie Bell rID 209 Written Submission by Rebecca Rogers rID 210 Written Submission by Ellie Richards rID 211 Written Submission by Kerry Archer rID 212.01 Statement by Jemma Powell-Tibbetts 212.02 Written Submission by Jemma Powell-Tibbetts for Evie and Ellie rID 213 Written Submission by Chris Tibbetts rID 214 Written Submission by Joanna Phillips rID 215 Appellant’s Sound Power Levels for Site Noise Calculations by WBM dated 13 November 2024 rID 216 Written Submission by Sallyann Mills rID 217 Written

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Submission by Mrs Jacqui Rudall rID 218 Written Submission by Mr Edwin Billingsley rID 219 Written Submission by Gary Green rID 220 Written Submission by Claire Farmer rID 221 Written Submission by Christopher Mucklow rID 222 Appellant’s Note on Planning Conditions and Noise Limits WBM dated 12 November 2024 rID 223 STQC comments on Viewpoint 8 Photomontage Year 25 rID 224 STQC Comments on suggested planning conditions dated 15 November 2024 rID 225 PM Targets: Interim Planning Guidance Defra November 2024 2.5 rID 226 Appellant’s response to STQC comments on VP8 at rID223 rID 227.01 Draft Deed of Unilateral Undertaking 227.02 Revised Draft Deed of Unilateral Undertaking 227.03 Deed of Unilateral Undertaking dated 1 December 2024 rID 228.01 Appellant’s note on securing the duration of public access routes 228.02 Avon Estates Ltd and Welsh Ministers [2011] EWCA Civ 553 rID 229 WCC’s and the appellant’s response to STQC’s comments on suggested conditions at rID224 rID 230 Appellant’s response to relevant additional Interested Party responses rID 231 Agenda for Round Table Discussion Monday 25 November 2024 rID 232 STQC note concerning rID71 on EIA agreed between WCC and the appellant rID 233 STQC response to appellant’s

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock note rID228 on securing the duration of public access routes rID 234 DB Symmetry Ltd v Swindon BC (SC (E)) [2023] 1 WLR https://www.gov.uk/planning-inspectorate 34

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock note rID228 on securing the duration of public access routes rID 234 DB Symmetry Ltd v Swindon BC (SC (E)) [2023] 1 WLR https://www.gov.uk/planning-inspectorate 34 Appeal Decision APP/E1855/W/22/3310099 rID 235.01 Revised Schedule of Conditions – Original Appeal Scheme dated 27 November 2024 235.02 Revised Schedule of Conditions – Amended Appeal Scheme dated 27 November 2024 rID 236 Appellant’s note on inert material classification and topsoil rID 237 Appellant’s note on landfill tax associated with quarry restoration rID 238 Closing Submissions on behalf of STQC rID 239 Closing Submissions on behalf of WCC rID 240.01 Appellant’s Closing Submissions 240.02 The Queen on the application of Cherkley Campaign Limited and Mole Valley DC and Longshot Cherkley Court Limited [2014] EWCA Civ 567. rID 241.01 STQC R6 party written response re revised NPPF 241.02 Response received 13 January 2025 by R6 to appellant’s comments rID 242 NPPF written submission on behalf of WCC rID 243.01 Appellant’s note received 20 December 2024 on the implications of the NPPF December 2024 243.02 Appellant’s written response to other party comments on NPPF 2024 243.03 Appellant’s response to rID241.02 received 15 January 2025 CORE DOCUMENTS (CD)

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD1 Original Submission | | | --- | --- | | CD1.01 | Planning Application Form | | CD1.02 | Planning Statement | | CD1.03 | Environmental Statement | | CD1.04 | Technical Appendix A - Landscape and Visual Impact Assessment | | CD1.05 | Technical Appendix B - Ecological Impact Assessment | | CD1.06 | Technical Appendix C - Pre Development Tree Condition Survey | | CD1.07 | Technical Appendix D - Noise Assessment | | CD1.08 | Technical Appendix E - Air Quality and Dust Assessment | | CD1.09 | Technical Appendix F - Transport | | CD1.10 | Technical Appendix G - Agricultural Land Classification and Soils Resource Report | | CD1.11 | Technical Appendix H.1 - Archaeological Desk Based Assessment | | CD1.12 | Technical Appendix H.2 - Written Scheme of Investigation | | CD1.13 | Technical Appendix I - Hydrological and Hydrogeological Impact Assessment | | CD1.14 | Technical Appendix J - Leisure and Recreation Report | | CD1.15 | Technical Appendix K.1 - Health Impact Assessment | | CD1.16 | Technical Appendix K.2 - Matrix Health Assessment | | CD1.17 | KD.LCF.001 - Location Plan (October 2019) | | CD1.18 | KD.LCF.014 - Application Boundary / Other land in control of the applicant (October 2019) |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD1 Original Submission | | | --- | --- | | CD1.19 | KD.LCF.002 - Current Situation (October 2019) | | CD1.20 | KD.LCF.013 - Proposals Plan (October 2019) | | CD1.21 | KD.LCF.011 - Operational (Disturbed) Land (October 2019) | https://www.gov.uk/planning-inspectorate 35 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD1.22 | KD.LCF.021 - Plant Site Layout - Plan & Elevations (October 2019) | | --- | --- | | CD1.23 | KD.LCF.022 - Plant Site - Conveyor running beneath PROW 62 6(B) (October 2019) | | CD1.24 | KD.LCF.003 - Initial Works (October 2019) | | CD1.25 | KD.LCF.004 - Phase 1 Working & Restoration (October 2019) | | CD1.26 | KD.LCF.005 - Phase 2 Working & Restoration (October 2019) | | CD1.27 | KD.LCF.006 - Phase 3 Working & Restoration (October 2019) | | CD1.28 | KD.LCF.007 - Phase 4 Working & Restoration (October 2019) | | CD1.29 | KD.LCF.008 - Phase 5 Working & Restoration (October 2019) | | CD1.30 | KD.LCF.009 - Final Works (October 2019) | | CD1.31 | KD.LCF.010 - Concept Restoration (October 2019) | | CD1.32 | KD.LCF.028 - Restoration Sections (October 2019) | | CD1.33 | Non-Technical Summary | | CD2 Initial Statutory Consultation Responses | | | CD2.01 | Western Power Distribution - 28.1.2020 | | CD2.02 | Severn Trent Water - 12.2.2020 | | CD2.03 | Historic England - 14.2.2020 | | CD2.04 | Forestry Commission - 17.2.2020 | | CD2.05 | Public Health England - 17.2.2020 | | CD2.06 | West Mercia Police - 17.2.2020 | | CD2.07 | Worcestershire Regulatory Services Air Quality and Contaminated Land - 19.2.2020 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD1.22 | KD.LCF.021 - Plant Site Layout - Plan & Elevations (October 2019) | | --- | --- | | CD2.08 | Herefordshire & Worcestershire Gardens Trust - 20.2.2020 | | CD2.09 | County Ecology Comments - 24.3.2020 | | CD2.10 | Canal & River Trust - 24.2.2020 | | CD2.11 | Cllr Cook & Cllr Rayner - 26.2.2020 | | CD2.12 | Cllr Cook & Cllr Rayner Additional Comments - 26.2.2020 | | CD2.13 | Highways Comments - 26.2.2020 | | CD2.14 | Kidderminster Town Council - 27.2.2020 | | CD2.15 | Worcestershire Regulatory Services Noise and Dust - 27.2.2020 | | CD2.16 | District Conservation Officer - 27.2.2020 | | CD2.17 | District Countryside & Parks Manager - 27.2.2020 | | CD2.18 | District Tree Officer - 27.2.2020 | | CD2.19 | Campaign to Protect Rural England - 10.3.2020 | | CD2.20 | Earth Heritage Trust 1 - 12.3.2020 | | CD2.21 | Earth Heritage Trust 2 - 12.3.2020 | | CD2.22 | North Worcestershire Water Management - 12.3.2020 | | CD2.23 | Public Rights of Way - 16.3.2020 | | CD2.24 | Wolverley & Cookley Parish Council - 16.3.2020 | | CD2.25 | County Archaeologist - 18.3.2020 | | CD2.26 | British Horse Society - 19.3.2020 | | CD2.27 | Woodland Trust - 19.3.2020 | | CD2.28 | British Horse Society - 20.3.2020 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD1.22 | KD.LCF.021 - Plant Site Layout - Plan & Elevations (October 2019) | | --- | --- | | CD2.29 | County Landscape - 20.3.2020 | | CD2.30 | Worcestershire Wildlife Trust - 25.3.2020 | | CD2.31 | The Garden Trust - 26.3.2020 | | CD2.32 | Hereford & Worcester Fire and Rescue Service - 27.3.2020 | | CD2.33 | Ramblers Association - 30.3.2020 | | CD2.34 | Environment Agency - 31.3.2020 | https://www.gov.uk/planning-inspectorate 36 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD2.35 | County Council Sustainability Team - 2.4.2020 | | --- | --- | | CD2.36 | Further Public Rights of Way Comments - 16.4.2020 | | CD2.37 | Natural England - 1.5.2020 | | CD2.38 | Worcestershire Regulatory Services Air Quality further comments - 27.5.2020 | | CD2.39 | Worcestershire Regulatory Services Noise and Dust further comments - 4.6.2020 | | CD2.40 | Further Ecology Comments - 5.6.2020 | | CD3 1st Regulation 25 Submission | | | CD3.01 | Regulation 25 Request | | CD3.02 | Regulation 25 Submission Document | | CD3.03 | Appendix A - BCL Hydro Consultant Report | | CD3.04 | Appendix B - Response to Arboriculture and Protected Species Comments | | CD3.05 | Appendix C - Updated Concept Restoration (September 2020) KD.LCF.010A | | CD3.06 | Appendix C - Surface Water Management Plan KD.LCF.032 | | CD3.07 | Appendix C - Restoration Sections – The Avenue KD.LCF.036 | | CD3.08 | Appendix D - Soil Volumes | | CD3.09 | Appendix E Bund 2: Tree Root Protection Areas KD.LCF.035 | | CD3.10 | Appendix F - Biodiversity Net Gain Report | | CD3.11 | Appendix G - Woodland: Outline Establishment and Aftercare Strategy | | CD3.12 | Appendix H - Materials for Restoration | | CD3.13 | Appendix I - Historic Environment Note |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD2.35 | County Council Sustainability Team - 2.4.2020 | | --- | --- | | CD3.14 | Appendix J - Location of NRS Existing and Potential Quarry Sites | | CD3.15 | Appendix K - Road Safety Audit and Hurlstone Partnership Response | | CD3.16 | Appendix L - Technical Specification for the Below Ground Conveyor | | CD3.17 | Appendix M - Public Rights of Way Proposed KD.LCF.033 and Post Restoration Public Rights of Way Plan KD.LCF.034 | | CD3.18 | Amended Restoration Sections Plan KD.LCF. 028A | | CD3.19 | Dormouse Report | | CD3.20 | Response to Stop the Quarry Action Group | | CD3.21 | Response to Wolverley and Cookley Parish Council | | CD3.22 | Response to CPA Email dated 5th June 2020 | | CD3.23 | Updated Certificates | | CD4 1st Regulation 25 Consultation Responses | | | CD4.01 | Worcestershire Wildlife Trust - 20.11.2020 | | CD4.02 | Cllr Rayner - 22.11.2020 | | CD4.03 | Canal & River Trust - 23.11.2020 | | CD4.04 | Further Cllr Rayner Comments - 23.11.2020 | | CD4.05 | County Ecologist - 25.11.2020 | | CD4.06 | Worcestershire Regulatory Service Noise and Dust - 26.11.2020 | | CD4.07 | The Ramblers Association & The MHDFS - 29.11.2020 | | CD4.08 | Further Worcestershire Wildlife Trust - 01.12.2020 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD2.35 | County Council Sustainability Team - 2.4.2020 | | --- | --- | | CD4.09 | Public Health England - 1.12.2020 | | CD4.10 | Historic England - 3.12.2020 | https://www.gov.uk/planning-inspectorate 37 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD4.11 | Lead Local Flood Authority - 3.12.2020 | | --- | --- | | CD4.12 | Further County Ecologist Comments - 4.12.2020 | | CD4.13 | North Worcestershire Water Management - 9.12.2020 | | CD4.14 | Hereford & Worcester Gardens Trust Further Comments - 6.12.2020 | | CD4.15 | County Highways - 14.12.2020 | | CD4.16 | Further County Ecologist Comments - 14.12.2020 | | CD4.17 | Environment Agency - 15.12.2020 | | CD4.18 | British Horse Society - 18.12.2020 | | CD4.19 | Wolverley & Cookley Parish Council - 18.12.2020 | | CD4.20 | County Archaeologist - 22.12.2020 | | CD4.21 | Worcestershire Regulatory Services Contaminated Land and Air Quality - 22.12.2020 | | CD4.22 | Public Rights of Way - 04.01.2021 | | CD4.23 | West Mercia Police - 14.1.2021 | | CD4.24 | Earth Heritage Trust - 18.1.2021 | | CD4.25 | The Garden Trust - 18.1.2021 | | CD4.26 | Woodland Trust - 18.01.2021 | | CD4.27 | Worcestershire Regulatory Services Air Quality further comments - 18.01.2021 | | CD4.28 | Worcestershire Regulatory Services Noise and Dust further comments - 18.1.2021 | | CD4.29 | Further Worcestershire Wildlife Trust Comments 1 - 27.1.2021 | | CD4.30 | Further Worcestershire Wildlife Trust Comments 2 - 27.1.2021 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD4.11 | Lead Local Flood Authority - 3.12.2020 | | --- | --- | | CD4.31 | Campaign to Protect Rural England - 29.1.2021 | | CD4.32 | County Landscape - 2.2.2021 | | CD4.33 | Further County Ecologist Comments - 3.2.2021 | | CD4.34 | County Highways - 18.2.2021 | | CD4.35 | Wyre Forest District Council Arboriculture Comments - 19.2.2021 | | CD4.36 | Wyre Forest District Council Conservation Officer - 19.2.2021 | | CD4.37 | Wyre Forest District Council Countryside & Parks Manager - 19.2.2021 | | CD4.38 | Wyre Forest District Council Formal Comments - 26.2.2021 | | CD4.39 | Natural England - 9.3.2021 | | CD4.40 | Severn Trent Water - 14.1.2021 | | CD5 2nd Regulation 25 Submission | | | CD5.01 | Regulation 25 Consultation Email Request | | CD5.02 | Regulation 25 Cover Email | | CD5.03 | KD.LCF.013A - Proposals Plan (July 2021) | | CD5.04 | KD.LCF.003A - Initial Works (July 2021) | | CD5.05 | KD.LCF.004A - Phase 1 Working & Restoration (July 2021) | | CD5.06 | KD.LCF.005A - Phase 2 Working & Restoration (July 2021) | | CD5.07 | KD.LCF.006A - Phase 3 Working & Restoration (July 2021) | | CD5.08 | KD.LCF.007A - Phase 4 Working & Restoration (July 2021) | | CD5.09 | KD.LCF.008A - Phase 5 Working & Restoration (July 2021) |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD4.11 | Lead Local Flood Authority - 3.12.2020 | | --- | --- | | CD5.10 | KD.LCF.009A - Final Works (July 2021) | | CD5.11 | KD.LCF.010B - Concept Restoration (July 2021) | | CD5.12 | KD.LCF.033C - Public Rights of Way Proposed (July 2021) | | CD5.13 | KD.LCF.034C - Post Restoration Public Rights of Way Plan (July 2021) | https://www.gov.uk/planning-inspectorate 38 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 | CD5.14 | KD.LCF.026A - Current & Proposed Public Rights of Way Figure 5A (July 2021) | | --- | --- | | CD5.15 | KD.LCF.042 - Root Protection: Existing Avenue Trees (July 2021) | | CD5.16 | Amended Non-Technical Summary | | CD5.17 | Amended ES Chapter 16 - Public Rights of Way | | CD5.18 | Response to Dormice comments | | CD5.19 | Dormice Survey Drawing | | CD5.20 | Response to Tree T22 Queries - 30.4.2021 | | CD5.21 | Arboriculture Appendix 4 - Tree Protection Fencing | | CD5.22 | Typical Sections through land around Tree 22 | | CD5.23 | Response to Landscape Officer Comments - 30.4.2021 | | CD5.24 | Response to Hereford and Worcester Gardens Trust - 30.4.2021 | | CD5.25 | Response to North Worcestershire Water Management - 19.7.2021 | | CD5.26 | Response to Public Rights of Way Officer - 14.6.2021 | | CD5.27 | Response to Public Rights of Way Officer - 19.7.2021 | | CD5.28 | Response to County Ecologist - 17.9.2021 | | CD6 2nd Regulation 25 Consultation Responses | | | CD6.01 | County Archaeologist Comments - 5.8.2021 | | CD6.02 | Worcestershire Regulatory Services Air Quality, Noise and Contaminated Land Comments - 5.8.2021 | | CD6.03 | Canal & River Trust Comments - 6.8.2021 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD5.14 | KD.LCF.026A - Current & Proposed Public Rights of Way Figure 5A (July 2021) | | --- | --- | | CD6.04 | Public Health England - 6.8.2021 | | CD6.05 | Historic England Comments - 9.8.2021 | | CD6.06 | North Worcestershire Water Management Comments - 11.8.2021 | | CD6.07 | Hereford & Worcester Gardens Trust Comments - 16.8.2021 | | CD6.08 | District Countryside and Technical Services Manager Comments - 23.8.2021 | | CD6.09 | District Tree Officer Comments - 24.8.2021 | | CD6.10 | Wyre Forest District Council Comments - 24.8.2021 | | CD6.11 | County Ecologist Comments - 27.8.2021 | | CD6.12 | Worcestershire Wildlife Trust Comments - 2.9.2021 | | CD6.13 | District Countryside and Technical Services Manager Further Comments -3.9.2021 | | CD6.14 | County Highways Comments - 6.9.2021 | | CD6.15 | Public Rights of Way Officer Comments - 6.9.2021 | | CD6.16 | Environment Agency Comments - 6.9.2021 | | CD6.17 | Sustainability Officer Comments - 6.9.2021 | | CD6.18 | Sustrans Comments - 6.9.2021 | | CD6.19 | Earth Heritage Trust Comments - 6.9.2021 | | CD6.20 | County Public Health Comment - 7.9.2021 | | CD6.21 | Natural England Comments - 7.9.2021 | | CD6.22 | Cllr Rayner & Rook Comments - 8.9.2021 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD5.14 | KD.LCF.026A - Current & Proposed Public Rights of Way Figure 5A (July 2021) | | --- | --- | | CD6.23 | County Landscape Officer Comments - 8.9.2021 | | CD6.24 | Wolverley & Cookley Parish Council - 8.9.2021 | | CD6.25 | British Horse Society Comments - 9.9.2021 | | CD6.26 | Woodland Trust Comments - 9.9.2021 | | CD6.27 | Severn Trent Water Ltd Comments - 10.9.2021 | https://www.gov.uk/planning-inspectorate 39 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD6.28 | Kidderminster Town Council Comments - 29.9.2021 | | --- | --- | | CD6.29 | Worcestershire Regulatory Services Comments re Housing & HGVs - 5.10.2021 | | CD6.30 | Worcestershire Regulatory Services Comments re Air Quality - 14.10.2021 | | CD6.31 | Natural England Comments - 14.10.2021 | | CD6.32 | District Council Tree Officer Comments - 14.10.2021 | | CD6.33 | Woodland Trust Comments - 15.10.2021 | | CD6.34 | Wyre Forest DC Countryside Officer Comments - 18.10.2021 | | CD6.35 | County Ecologist Comments - 21.10.2021 | | CD6.36 | Further County Landscape Officer Comments - 23.10.2021 | | CD6.37 | British Horse Society Clarification - 2.12.2021 | | CD6.38 | Further British Horse Society Comments - 2.12.2021 | | CD6.39 | Further Footpath Officer Comments - 2.12.2021 | | CD6.40 | Further Ecology Comments - 10.12.2021 | | CD6.41 | County Archaeologist Comments - 14.12.2021 | | CD6.42 | Worcestershire Regulatory Services Air Quality Officer - 30.12.2021 | | CD6.43 | County Highways Comments –- 6.1.2022 | | CD6.44 | Worcestershire Regulatory Services Noise and Dust Officer Comments - 6.1.2022 | | CD7 Response to Consultation Responses | | | CD7.01 | Response to County Ecologist - 17.9.2021 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD6.28 | Kidderminster Town Council Comments - 29.9.2021 | | --- | --- | | CD7.02 | Response re Clarification Size of each phase - 22.9.2021 | | CD7.03 | Response re Vehicle Movements & Air Quality - 23.9.2021 | | CD7.04 | Response from Bob Williams re Ancient Woodland - 11.10.2021 | | CD8 3rd Regulation 25 Submission | | | CD8.01 | Regulation 25 Request | | CD8.02 | Habitat Regulations Assessment | | CD8.03 | Appendix 1 - Preliminary Ecological Appraisal | | CD8.04 | Appendix 2 - BCL Hydro | | CD8.05 | Appendix 3 - Air Quality and Dust | | CD8.06 | Appendix 4 - Ecological Impact Assessment | | CD8.07 | Appendix 5 - Ancient Woodland | | CD8.08 | Appendix 6 - County Ecologist Response | | CD8.09 | Final Habitat Regulations Assessment - 29.4.2022 | | CD9 3rd Regulation 25 Consultation Responses | | | CD9.01 | Further Ecology Comments - 7.2.2022 | | CD9.02 | Cadent Gas Comments - 3.3.2022 | | CD9.03 | ESP Comments - 3.3.2022 | | CD9.04 | Last Mile Comments - 3.3.2022 | | CD9.05 | Western Power Comments - 3.3.2022 | | CD9.06 | Campaign to Protect Rural England - 18.3.2022 | | CD9.07 | ESP Bespoke Comments - 18.3.2022 | | CD9.08 | Hereford & Worcester Fire & Rescue Service Comments - 20.3.2022 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD6.28 | Kidderminster Town Council Comments - 29.9.2021 | | --- | --- | | CD9.09 | Canal & River Trust Comments - 21.3.2022 | | CD9.10 | Worcestershire Regulatory Services Noise & Dust Comments - 21.3.2022 | | CD9.11 | Historic England Comments - 24.3.2022 | https://www.gov.uk/planning-inspectorate 40 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD9.12 | County Footpath Officer Comments - 28.3.2022 | | --- | --- | | CD9.13 | North Worcestershire Water Management Comments - 29.3.2022 | | CD9.14 | Severn Trent Water Ltd Comments - 30.3.2022 | | CD9.15 | County Archaeologists Comments - 4.4.2022 | | CD9.16 | County Public Health Comments - 6.4.2022 | | CD9.17 | Earth Heritage Trust Comments - 7.4.2022 | | CD9.18 | Further Earth Heritage Trust Comments - 8.4.2022 | | CD9.19 | Further Severn Trent Water Ltd Comments - 8.4.2022 | | CD9.20 | Worcestershire Wildlife Trust Comments - 11.4.2022 | | CD9.21 | Environment Agency Comments - 12.4.2022 | | CD9.22 | Environment Agency Comments on Habitat Regulations Assessment - 12.4.2022 | | CD9.23 | County Highways Comments - 14.4.2022 | | CD9.24 | District Cllr Rayner Comments - 15.4.2022 | | CD9.25 | Worcestershire Regulatory Services Air Quality & Contaminated Land Comments - 19.4.2022 | | CD9.26 | County Ecologist Comments - 20.4.2022 | | CD9.27 | Wolverley & Cookley Parish Council Comments - 21.4.2022 | | CD9.28 | Natural England Comments - 26.4.2022 | | CD9.29 | Natural England Final Comments - 3.5.2022 | | CD9.30 | Further County Ecology Comments - 11.5.2022 | | CD10 Decision | | | CD10.01 | Committee Report |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD9.12 | County Footpath Officer Comments - 28.3.2022 | | --- | --- | | CD10.02 | Decision Notice | | CD10.03 | Committee Meeting Minutes | | CD11 Policy Documents | | | CD11.01 | National Planning Policy Framework (NPPF) (NB Superseded by National Planning Policy Framework (NPPF) Updated December 2023, see Core Document CD11.07) | | CD11.02 | National Planning Policy For Waste (NPPW) | | CD11.03 | Worcestershire Minerals Local Plan 2018-2036 | | CD11.04 | Worcestershire Waste Core Strategy | | CD11.05 | Wyre Forest District Local Plan | | CD11.06 | Worcestershire Local Aggregate Assessment: Data covering the period up to 31/12/2021 (January 2023) (NB Superseded by Worcestershire Local Aggregate Assessment: Data covering the period up to 31/12/2022, see Core Document CD11.08) | | CD11.07 | National Planning Policy Framework (NPPF) Updated December 2023 | | CD11.08 | Worcestershire Local Aggregate Assessment: Data covering the period up to 31/12/2022 | | CD11.09 | South Worcestershire Development Plan (2016) | | CD12 Other Related Documents | | | CD12.01 | Profile of the UK Mineral Products Industry | | CD12.02 | Wyre Forest District Council Green Belt Review Analysis September 2016 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD9.12 | County Footpath Officer Comments - 28.3.2022 | | --- | --- | | CD12.03 | Wyre Forest District Council Green Belt Part II May 2018 | | CD12.04 | Worcestershire Landscape Character Assessment | https://www.gov.uk/planning-inspectorate 41 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD12.05 | Turner v Secretary of State for Communities and Local Government [2016] EWCA Civ 466 | | --- | --- | | CD12.06 | R (Samuel Smith Old Brewery (Tadcaster) and others) v North Yorkshire County Council [2020] | | CD12.07 | Europa Oil and Gas Ltd v Secretary of State for Communities and Local Government [2013] EWHC 2643 (Admin) | | CD12.08 | Decision Notice for 17/0205/OUTL | | CD12.09 | Construction Management Plan for 17/0205/OUTL (Ref: Drawing No. PL1000_A) | | CD12.10 | Decision Notice for 18/0163/FULL | | CD12.11 | Noise report for 18/0163/FULL (Ref: Wardell Armstrong “Miller Homes, Land off Stourbridge Road, Kidderminster, Noise Assessment Report”) | | CD12.12 | Submitted Masterplan for 22/0404/OUT (Ref: Illustrative Masterplan: Drawing No. 204116-AFL-Z1-ZZ-DR-A-20104 P3 (NB Superseded by Illustrative Masterplan for 22/0404/OUT, Drawing No. 20104, Rev P7, see Core Document CD12.45) | | CD12.13 | Noise report for 22/0404/OUT (Ref: Wood Group “Lea Castle Village, Kidderminster, Outline Planning Application, Site Suitability assessment – Noise” dated April 2022) | | CD12.14 | Health Impact Assessment Checklist Matrix for 22/0404/OUT (Ref: “HIA Matrix for Planning” dated May 2022) |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD12.05 | Turner v Secretary of State for Communities and Local Government [2016] EWCA Civ 466 | | --- | --- | | CD12.15 | BS 5228-1:2009+A1:2014 “Code of practice for noise and vibration control on construction and open sites – Part 1: Noise” Annex E | | CD12.16 | Worcestershire Regulatory Services (WRS) “Code of Best Practice for Demolition and Construction Sites” September 2020 | | CD12.17 | Noise Policy Statement for England | | CD12.18 | Planning Practice Guidance Noise | | CD12.19 | Planning Practice Guidance Minerals | | CD12.20 | WRS “Noise Control Technical Guidance” 2013 (NB Superseded by WRS “Technical Guidance Note for Planning” (March 2024) V5.7, see Core Document CD12.36) | | CD12.21 | WRS “Technical Guidance Note for Planning” (November 2022) (NB Superseded by WRS “Technical Guidance Note for Planning” (March 2024) V5.7, see Core Document CD12.36) | | CD12.22 | Decision Notice for 20/0217/FUL | | CD12.23 | Decision Notice for 18/0748/PIP | | CD12.24 | Institute of Air Quality Management (IAQM), IAQM Guidance on the Assessment of Mineral Dust Impacts for Planning, May 2016 (v1.1) |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD12.05 | Turner v Secretary of State for Communities and Local Government [2016] EWCA Civ 466 | | --- | --- | | CD12.25 | IAQM Guidance on the Assessment of Dust from Demolition and Construction, version 1.1, 2016 (NB Superseded by IAQM Guidance on the Assessment of Dust from Demolition and Construction, version 2.2, January 2024, see Core Document CD12.37) | | CD12.26 | IAQM Land-Use Planning and Development Control: Planning for Air Quality, January 2017 | | CD12.27 | Planning Practice Guidance Air Quality | https://www.gov.uk/planning-inspectorate 42 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 | CD12.28 | Air Quality Assessment report for 22/0404/OUT (Ref: Wood “Lea Castle Village, Kidderminster, Outline Planning Application, Air Quality Assessment” dated April 2022 | | --- | --- | | CD12.29 | Wychavon DC v Secretary of State for Communities and Local Government & Butler [2008] EWCA Civ 692 | | CD12.30 | Leicestershire County Council v Secretary of State for Communities and Local Government and UK Coal Mining Limited [2007] EWHC 1427 (Admin) | | CD12.31 | Air Quality Review: Lea Castle Farm, dated 2 March 2020 | | CD12.32 | Planning Statement and Location Plan 19/000056/CM, Pinches Quarry | | CD12.33 | Planning Statement and Location Plan 22/000015/CM, Ripple East | | CD12.34 | Planning Appeal Decision 3300222, dated 06.02.23 | | CD12.35 | Ministerial Statement - Building the homes we need, dated 30.07.24 | | CD12.36 | WRS “Technical Guidance Note for Planning” (March 2024) V5.7 | | CD12.37 | IAQM Guidance on the Assessment of Dust from Demolition and Construction, version 2.2, January 2024 | | CD12.38 | Wyre Forest District Council 2024 Air Quality Annual Status Report, dated June 2024 |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD12.28 | Air Quality Assessment report for 22/0404/OUT (Ref: Wood “Lea Castle Village, Kidderminster, Outline Planning Application, Air Quality Assessment” dated April 2022 | | --- | --- | | CD12.39 | Secretary of State’s (SoS) decision letter dated 4 April 2019 in relation to an appeal by RJD Ltd and Gowling WLG Trust Corporation Limited for land at Ware Park, Wadesmill Road, Hertford (APP/M1900/W/17/3178839) | | CD12.40 | Committee Report for Pinches (4) Quarry (Application Ref: 19/000056/CM) | | CD12.41 | Decision Notice for 19/000056/CM | | CD12.42 | National and regional guidelines for aggregate provision in England 2005 to 2020 | | CD12.43 | Government’s proposed new Standard Method approach to calculating Local Housing Need | | CD12.44 | Planning Practice Guidance Green Belt | | CD12.45 | Illustrative Masterplan for 22/0404/OUT, Drawing No. 20104, Rev P7 | | CD12.46 | MHCLG Pocket Parks Frequently Asked Questions | | CD12.47 | Sustainability Appraisal of the Worcestershire Minerals Local Plan – Publication Version May 2019 | | CD12.48 | Interactive Minerals Mapping Tool - Solid Sand and Gravel Area of Search Extracts | | CD13 Appeal Documents | |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD12.28 | Air Quality Assessment report for 22/0404/OUT (Ref: Wood “Lea Castle Village, Kidderminster, Outline Planning Application, Air Quality Assessment” dated April 2022 | | --- | --- | | CD13.01 | Statement of Case of Worcestershire County Council (NB Superseded by Statement of Case of Worcestershire County Council, April 2024, see Core Document CD13.28) | | CD13.02 | See CD12.02 (Appendix WCC1 - Wyre Forest District Council Green Belt Review Analysis September 2016) | | CD13.03 | See CD12.03 (Appendix WCC2 - Wyre Forest District Council Green Belt Part II May 2018) | | CD13.04 | See CD11.05 | https://www.gov.uk/planning-inspectorate 43 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | | (Appendix WCC3 - Wyre Forest District Local Plan 2022) | | --- | --- | | CD13.05 | Appendix WCC4 - Lea Castle Village Draft Framework Masterplan | | CD13.06 | See CD12.08 (Appendix WCC5 - Planning Decision Notice 17/0205/OUTL, Former Lea Castle Hospital) | | CD13.07 | Appendix WCC6 - Officers Report for Decision 17/0205/OUTL, Former Lea Castle Hospital | | CD13.08 | Appendix WCC7 - Phasing Plan, Former Lea Castle Hospital | | CD13.09 | Appendix WCC8 - Planning Decision Notice 19/0724/RESE, Former Lea Castle Hospital | | CD13.10 | Appendix WCC9 - Approved Layout Plan 19/0724/RESE, Former Lea Castle Hospital | | CD13.11 | Appendix WCC10 - Decision Notice, Location Plan and Layout Plan for 18/0163/FULL Land off Stourbridge Road | | CD13.12 | Appendix WCC11 - Decision Notice and Location Plan 19/000048/CM, Bow Farm Quarry | | CD13.13 | Appendix WCC12 - Decision Notices and Location Plans 20/000009/CM & 20/000015/CM, Ryall North Quarry | | CD13.14 | Appendix WCC13 - Decision Notice and Location Plan 21/000029/CM, Sandy Lane Quarry | | CD13.15 | Appendix WCC14 - Worcestershire County Council Sand and Gravel Landbank Position Statement | | CD13.16 | Appendix WCC15 - Photographs of Appeal Site from Key Views |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | | (Appendix WCC3 - Wyre Forest District Local Plan 2022) | | --- | --- | | CD13.17 | See CD12.30 (Appendix WCC16 - Judgment, Mr Justice Burton [2007] EWHC 1427 (Admin)) | | CD13.18 | See CD12.06 (Appendix WCC17 - Judgment, R (on the application of Samuel Smith Old Brewery (Tadcaster) v North Yorkshire County Council [2020] UKSC 3) | | CD13.19 | See CD12.05 (Appendix WCC18 - Judgment, Turner v SoSCLG and East Dorset Council [2016] EWCA Civ 466) | | CD13.20 | Appendix WCC19 - Judgment, Timmins and A W Lymm Limited v Gedling BC [2014] EWHC 654 (Admin) | | CD13.21 | Appendix WCC20 - Planning Appeal Decision 3298447, Brown Westhead Park, dated 25/11/22 | | CD13.22 | NRS Ltd (Appellant) Statement of Case (NB Superseded by NRS Ltd (Appellant) Revised Statement of Case, April 2024, see Core Document CD13.29) | | CD13.23 | Statement of Case for Stop The Quarry Campaign - Rule 6 Party (NB Superseded by Statement of Case for Stop The Quarry Campaign - Rule 6 Party, April 2024, see Core Document CD13.30) | | CD13.24 | Statement of Case for Stop The Quarry Campaign - Rule 6 Party - Planning Timeline |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | | (Appendix WCC3 - Wyre Forest District Local Plan 2022) | | --- | --- | | CD13.25 | Statement of Common Ground - Signed 24.01.23 (NB Superseded by Revised Statement of Common Ground - Signed 15.02.23, see Core Document CD13.27) | https://www.gov.uk/planning-inspectorate 44 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 | CD13.26 | Agreed Schedule of Conditions 30.01.2023 (NB Superseded by Revised Schedule of Conditions, March 2023, see Inquiry Document ID.51) | | --- | --- | | CD13.27 | Revised Statement of Common Ground - Signed 15.02.23 (NB Superseded by Revised Statement of Common Ground General – Signed 13.09.24, see Re-determination Inquiry Document rID2) | | CD13.28 | Statement of Case of Worcestershire County Council, April 2024 | | CD13.29 | NRS Ltd (Appellant) Revised Statement of Case, April 2024 | | CD13.30 | Statement of Case for Stop The Quarry Campaign - Rule 6 Party, April 2024 | | CD14 4th Regulation 25 Submission | | | CD14.01 | PINS Regulation 25 Request - 13.01.2023 | | CD14.02 | CMC Summary Note - 19.01.2023 | | CD14.03 | Kidderminster Shuttle Press Notice - 02.02.2023 | | CD14.04 | Lea Castle Farm Regulation 25 Submission, dated February 2023 | | CD14.05 | Appendix A - Ecological Addendum Report and Biodiversity Net Gain Assessment | | CD14.06 | Appendix A - Biodiversity Net Gain Assessment 3.1 | | CD14.07 | Appendix B - Noise Technical Note | | CD14.08 | Appendix C - Cumulative Impact Assessment | | CD14.09 | Appendix D - Revised Non-Technical Summary |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD13.26 | Agreed Schedule of Conditions 30.01.2023 (NB Superseded by Revised Schedule of Conditions, March 2023, see Inquiry Document ID.51) | | --- | --- | | CD15 Revised Plans and Supporting Information – July 24 | | | CD15.01 | Lea Castle Farm ES Addendum - July 2024 | | CD15.02 | ES Addendum Appendix A - Figure 4.1 - Photoviewpoint Locations | | CD15.03 | ES Addendum Appendix A - Figures 4.2-4.10 | | CD15.04 | ES Addendum Appendix A - Figures 4.11-4.16 | | CD15.05 | ES Addendum Appendix A - Figures 4.17-4.26 | | CD15.06 | ES Addendum Appendix A - Figures 4.27-4.39 | | CD15.07 | ES Addendum Appendix A - Figures 4.40-4.49 | | CD15.08 | ES Addendum Appendix A - Figures 4.50-4.61 | | CD15.09 | ES Addendum Appendix A - Figures 4.62-4.70 | | CD15.10 | ES Addendum Appendix A - Figure 4.71 Cumulative Sites and Green Belt | | CD15.11 | ES Addendum Appendix B.1 | | CD15.12 | ES Addendum Appendix B.2 | | CD15.13 | Lea Castle Farm Non-Technical Summary - July 2024 | | CD15.14 | Drawing Nos. E2370-SGA-001 and 002 - Original and Revised Plant Layout | | CD15.15 | Drawing No. 01-LEACF-INQ_001 - Updated Temporary Soil Attenuation Mitigation Bunds | | CD15.16 | Drawing No. 01-LEACF-INQ_004 - Initial Works |

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock | CD13.26 | Agreed Schedule of Conditions 30.01.2023 (NB Superseded by Revised Schedule of Conditions, March 2023, see Inquiry Document ID.51) | | --- | --- | | CD15.17 | Drawing No. 01-LEACF-INQ_005 - Phase 1 - Working & Restoration | | CD15.18 | Drawing No. 01-LEACF-INQ_006 - Phase 2 - Working & Restoration | | CD15.19 | Drawing No. 01-LEACF-INQ_007 - Phase 3 - Working & Restoration | https://www.gov.uk/planning-inspectorate 45 Appeal Decision APP/E1855/W/22/3310099

Lea Castle Farm, Wolverley Road, Broadwaters, Kidderminster, DY10 3QA — Worcestershire County Council — J Woolcock Appeal Decision APP/E1855/W/22/3310099 | CD15.20 | Drawing No. 01-LEACF-INQ_008 - Phase 4 - Working & Restoration | | --- | --- | | CD15.21 | Drawing No. 01-LEACF-INQ_009 - Phase 5 - Working & Restoration | | CD15.22 | Drawing No. 01-LEACF-INQ_010 - Final Works | | CD15.23 | Drawing No. 01-LEACF-INQ_011 Concept Restoration - July 2024 | | CD15.24 | Drawing No. 01-LEACF-INQ_012 - Plant Site | https://www.gov.uk/planning-inspectorate 46