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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
SCG1
Plymouth and South West Devon Joint Local Plan
Statement of Common Ground
Between
Rockspring Barwood Plymouth Ltd
and
The Joint Local Plan Authorities
Relating to Woolwell Sustainable Urban Extension and
Community Park / Policy PLY44
December 2017
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
Introduction
This Statement of Common Ground has been agreed by Rockspring Barwood Plymouth Ltd. (and agents
acting on their behalf; Boyer, Barton Willmore (BW), Environmental Dimension Partnership (EDP), Peter
Brett Associates (PBA)) and the Joint Local Plan (JLP) Authorities (Plymouth City Council, South Hams
District Council and West Devon Borough Council).
This Statement has been prepared to assist the Inspectors conducting the Examination in Public of the
Plymouth and South West Devon Joint Local Plan (PSWD JLP) and clarifies those matters that have been
agreed and those that remain outstanding in relation to representation number 1095245 of the submission
version of the PSWD JLP.
In the interests of clarity, the allocation at Woolwell comprises approximately 140ha of land, which is split in
to ownership as follows; Maristow Estate (84%), Mr W Hitchins (8%), and Plymouth City Council (8%). It is
also important to highlight that the majority of the site is controlled, via legal agreements, by specialist
promoters and housebuilders. Namely, the Maristow Estate’s land is controlled through a legal agreement by
Rockspring Barwood Plymouth Ltd and Mr Hitchens’ land is controlled through a legal agreement by Hannick
Homes.
A plan showing the relevant landownerships is at Appendix 1.
All land owners and developers/promoters have confirmed to the Local Planning Authorities that they fully
support the allocation of the site for a residential-led development in the JLP. They have confirmed that the
land is available for development and are preparing an outline planning application for the site. They have also
submitted evidence to demonstrate that the site is suitable and deliverable as a residential-led development and allocation in the JLP.
Description of Site
The land at Woolwell is situated north east of, and adjoining, the existing built area of Woolwell and to the
east of Tavistock Road (A386) at Roborough. The site is predominantly within the administrative boundary of
South Hams District Council but is adjacent to the existing built edge of Plymouth and is located within the
JLP Plymouth Policy Area.
There are a wide range of services and facilities within close proximity of the site including the Local Centre at
Woolwell, adjacent to the southern boundary of the site, the supermarkets at Woolwell’s junction with
Tavistock Road, approximately 400m south west of the site via Towerfield Drive, and employment uses in
Roborough approximately 300m west of the site, off the roundabout between Tavistock Road (A386) and
Tamerton Road. Furthermore the site is approximately 9km north east of Plymouth City Centre via the A386.
The site is well positioned in relation to the existing communities of Woolwell and Roborough. As a result of
this, the surrounding area is well served by existing bus services connecting to Plymouth City Centre,
Derriford Hospital transport interchange and other key local destinations throughout the day. Plymouth
Railway Station is located on the edge of the City Centre and is accessible via a direct bus journey as service
no.1 which is operated by Stagecoach serves stops on the A386 to the west of the site at Roborough Roundabout, to the south of its junction with Bickleigh Down Road and at Woolwell Roundabout. This route
extends between Plymouth City Centre and Tavistock on a 15-minute frequency throughout a weekday and
stops on North Road East within a short walk of Plymouth Railway Station.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
In terms of walking facilities, the existing Woolwell and Roborough area is well provided for in terms of
footways, with good quality facilities connecting with those that extend along the A386 to the west of the site.
The area surrounding the site also has good cycling facilities through a combination of on and off road cycle
routes.
Proposed Development
The proposed allocation PLY44 as set out in the submission version of the PSWD JLP requires a
comprehensive residential led mixed use development to provide a sustainable urban extension, with the
provision made in the order of 2,000 new homes and a new community park. The allocation also seeks new
playing pitches and associated infrastructure as well as local facilities to support the new and existing residents
and to enhance the sustainability of the area, including a new primary school.
It is acknowledged that, whilst supporting the proposed allocation, Rockspring Barwood Plymouth Ltd have
made representations to specific elements of the proposed policy and reasoned justification.
The original Policy PLY44 wording, as submitted, is as follows:
Land at Woolwell is allocated for comprehensive residential led mixed use development to provide a sustainable
urban extension and a defined edge to the north of the city, including a new community park. Provision is made
for in the order of 2,000 new homes (about 1,880 of which are anticipated to come forward within the plan
period), with none occupied until the A386 Woolwell to the George Junction Transport Scheme has been
implemented. Development should provide for the following:
1. Delivery in accordance with a strategic masterplan and design code that should be prepared for the site
and consulted upon in advance of the consideration of any planning application. This masterplan will:
i. Identify the design philosophy and phasing of the development.
ii. Include a detailed transport and access strategy which establishes key road, walking and cycling routes and
public transport, maximising the permeability of the site by all forms of sustainable transport, both within the
development and to connecting routes in the vicinity.
iii. Set out a landscape strategy that responds to the sites location and relationship with Dartmoor National
Park.
2. The main access to the development must be agreed and delivered prior to the commencement of the main
construction works of the development.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
3. A form of development which utilises natural features with appropriate strategic landscaping that is
sensitive to its location and relationship with the Dartmoor National Park resulting in a clearly defined edge of the
city.
4. Delivery of a new Community Park and will form part of the network of Strategic Greenspace sites. It will
therefore need to be of a sufficient scale, design and quality and must be multi-functional in nature. The park
must:
i. Meet the recreational needs of the new community to prevent an unacceptable impact on South Dartmoor
Woods European Protected Site.
ii. Provide a minimum of a 40m landscape buffer between the edge of development and the Plym Valley
Strategic Green Space and setting of Dartmoor National Park.
iii. Deliver high quality accessible greenspace that incorporates areas for active recreation and play in line with
local standards.
iv. Provide a high quality network of walking, cycling and horse riding routes through the Park that link into the
adjacent Plym Valley Strategic Green Space.
v. Incorporate elements of the Sustainable Urban Drainage system that must be designed to fit within the
landscape setting of the Park and provide wildlife and amenity benefits.
vi. Incorporate new playing pitches in line with local standards and associated infrastructure, such as changing
rooms, required to support the new community. Facilities will be located in an appropriate area that does not
conflict with the other functions of the park.
vii. Incorporate significant levels of biodiversity enhancement works to mitigate the impacts of the development.
viii. Utilise the old tramway for pedestrian and cycle connections through the development and providing the
opportunity for onward links to the Plym Valley Strategic Green Space.
5. Appropriate local facilities to support the new and existing residents and to enhance the sustainability of the
area, including a new primary school.
6. A second road access to Woolwell which is capable of accommodating traffic from the existing community
and planned new development, with due consideration to the needs of public transport accessibility, and which
leads to improved traffic flow around the area and which reduces the impact of the development on the key
transport corridor and routes.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
7. Contributions to strategic highway improvements and programmes.
8. Provision of opportunities and plots for self or custom build homes.
9. Maximise opportunities for on-site energy generation.
Since submission it has been agreed that the wording of Policy PLY44 can be amended to further improve both its effectiveness and that of the Plan as a whole.
This revised wording, as agreed by Rockspring Barwood Plymouth Ltd and the JLP Authorities, is set out
below with the alterations shown in bold, and the Inspectors are respectfully asked to consider this through
the Examination process. The revised wording has resulted from the on-going work and technical evaluation
of the land in question (as summarised below).
Policy PLY44 (Revised)
Woolwell sustainable urban extension and community park
Land at Woolwell is allocated for comprehensive residential led mixed use development to provide a sustainable
urban extension and a defined edge to the north of the city, including a new community park. Provision is made
for in the order of 2,000 new homes (about 1,880 of which are anticipated to come forward within the plan
period), with none occupied until the A386 Woolwell to the George Junction Transport Scheme has been
implemented. Development should provide for the following:
1. Delivery in accordance with a strategic masterplan and design code that should be prepared for the site and
consulted upon in advance of the consideration of any planning application. This masterplan will:
i. Identify the design philosophy and phasing of the development.
ii. Include a detailed transport and access strategy which establishes key road, walking and cycling routes and
public transport, maximising the permeability of the site by all forms of sustainable transport, both within the
development and to connecting routes in the vicinity.
iii. Set out a landscape strategy that responds to the sites location and relationship with Dartmoor National Park.
2. The main access arrangements to the development must be agreed and delivered prior to the commencement
of development the main construction works of the development and delivered commensurately with the
associated phase of development. Additionally, there should be no occupation of new homes until the A386
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
Woolwell to the George Junction Transport Scheme has been implemented, with the exception of where this can
be accommodated without resulting in a severe impact on the operation of the local road network.
3. A form of development which utilises natural features with appropriate strategic landscaping that is sensitive
to its location and relationship with the Dartmoor National Park resulting in a clearly defined edge of the city.
4. Delivery of a new Community Park and that will form part of the network of Strategic Greenspace sites. It will
therefore need to be of a sufficient scale, design and quality and must be multi -functional in nature. The park
must:
i. Meet the recreational needs of the new community to prevent an unacceptable impact on South Dartmoor
Woods European Protected Site.
ii. Provide a minimum of a 40m landscape buffer between the edge of development and the Plym Valley
Strategic Green Space and setting of Dartmoor National Park.
iii. Deliver high quality accessible greenspace that incorporates areas for active recreation and play in line with
local standards.
iv. Provide a high quality network of walking, cycling and horse riding routes through the Park that link into the
adjacent Plym Valley Strategic Green Space.
v. Incorporate elements of the Sustainable Urban Drainage system that must be designed to fit within the
landscape setting of the Park and provide wildlife and amenity benefits.
vi. Incorporate new playing pitches in line with local standards and associated infrastructure, such as changing
rooms, required to support the new community. Facilities will be located in an appropriate area that does not
conflict with the other functions of the park.
vii. Incorporate significant levels of biodiversity enhancement works to Mitigate the impacts of the development
on biodiversity and incorporate biodiversity enhancement measures.
viii. Utilise the old tramway for pedestrian and cycle connections through the development and providing the
opportunity for onward links to the Plym Valley Strategic Green Space.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
5. Appropriate local facilities to support the new and existing residents and to enhance the sustainability of the
area, including a new primary school and appropriate contributions to mitigate the impact of the development on
secondary schools in Plymouth.
6. A second road access to Woolwell which is capable of accommodating traffic from the existing community and
planned new development, with due consideration to the needs of public transport accessibility, and which leads
to improved traffic flow around the area and which reduces the impact of the development on the key transport
corridor and routes.
7. Contributions to strategic highway improvements and programmes.
8. Provision of opportunities and plots for self or custom build homes.
9. Maximise opportunities for on-site energy generation.
Matters Agreed by Both Parties
Joint Working
The Parties agree that there has been positive cooperation and engagement on the proposed allocation for
some considerable time. This is detailed below and the Parties are committed to working together to deliver
the proposals set out in PLY44 both in respect of the JLP Examination but also, crucially, the preparation and
submission of an outline planning application and its determination.
Land at Woolwell represents the largest of the proposed allocations in the JLP and will provide an appropriate
and sustainable urban extension to the City. It is agreed that it will deliver significant benefits to the city of
Plymouth and surrounding area, which are amplified due to the strategic scale and nature of the allocation in
this location.
The Parties recognise the importance of the delivery of the allocation to the JLP and have, and will continue
to, invest significant resources in to its delivery. The technical team appointed by Rockspring Barwood
Plymouth Ltd includes:
Consultant Topic Areas
Barton Willmore Urban Design and Masterplanning
Boyer Planning and EIA
Environmental Dimensions Partnership Landscape, Ecology, Arboriculture, Archaeology and
Heritage.
Peter Brett Associates Transport, Hydrology and Drainage, Utilities,
Geotechnical, Noise and Vibration, Air Quality,
Lighting, Energy and Waste.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
In addition, both South Hams District Council and Plymouth City Council have invested considerable Officer
time to the delivery of the allocation including the Joint Local Plan Team and the Councils’ Urban Fringe
Delivery Team.
It is also recognised that Officers from Devon County Council, as the highways and education authority, and
Dartmoor National Park Authority have been proactively engaged throughout the preparation of the JLP and
also with the pre-application process.
The Approach
The Parties recognise the importance of a collaborative approach to ensuring the timely delivery of the
Woolwell allocation. This includes establishing a partnership in respect of its promotion through the JLP
process.
In addition, the promoters of the site have embarked on the preparation and submission of an outline
application and pre-application consultation with the local planning authority, South Hams District Council,
and other stakeholders. It is intended that the application will be submitted in the Spring 2018. Further details
of the progress made to date are set out below.
Planning Application - Progress to Date
The Parties are in agreement that progress has been made to date to inform the preparation of the outline
planning application. The JLP Authorities further agree that the application is being brought forward with the
engagement and agreement in principle of a substantial number of key statutory consultees, including the relevant Local Highways Authority, Highways England and the Dartmoor National Park Authority.
The following aspects of the progression of the application are brought to the Inspectors’ attention and an
update will be provided at the Examination.
EIA Scoping
A significant amount of engagement and technical work has taken place to date. An EIA scoping request for
development of up to 2,000 dwellings was submitted to South Hams District Council and a response to this
request was received on 30th November 2017, confirming agreement to the scope of the Environmental
Statement and allowing progress on the EIA ahead of submission of a planning application.
Pre-application and projected planning application submission
An outline planning application for up to 2,000 dwellings is due to be submitted in Spring 2018. A planning
performance agreement (PPA) is, at the time of writing, about to be signed by South Hams District Council
and Rockspring Barwood Plymouth Ltd. The PPA agrees to a timetable that allows for submission of a planning
application in accordance with these timescales.
Officers have been engaged from the very infancy of the proposed development and as such consultation has
been very effective and continues to be an evolving process.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
A series of regular pre-application meetings and discussions have taken place which have informed the
technical assessments and establishing the principles to inform the masterplanning. Meetings have taken place
between the land promotion team and officers of the JLP authorities, as well as with other key stakeholders
including local Councillors, Bickleigh Parish Neighbourhood Plan Working Group, Dartmoor National Park,
Devon County Council and Highways England. Consultation with statutory consultees and the local
community is ongoing and will inform the planning application and masterplanning for the site that is being
prepared.
Technical work
At the time of writing, a significant amount of technical work has been undertaken to underpin the proposed
planning application. Further information on this can be provided to the Inspector if required.
Trajectory & Delivery
The JLP Authorities’ latest trajectory for the delivery of Woolwell is set out in Examination Document TP3F. This indicates first residential completions are anticipated to come forward in the period 2024-25.
Prior to this, the JLP Authorities considered that first completions would be delivered in the period 2021-22
(Examination Document TP3A).
The Parties agree that the Woolwell allocation will make a significant contribution to housing supply during
the Plan period. Notwithstanding this agreement, Rockspring Barwood Plymouth Ltd considers that the latest
trajectory (TP3F) is extremely cautious and that first completions can be achieved in the period of 2021.
The Parties agree that the trajectory at TP3F does not represent Policy but is a monitoring tool to ensure that
the objectively assessed need for housing is met over the Plan period. The differences between the Parties on
this matter does not therefore affect the principle of the allocation and can be put before the Inspectors for
consideration under Matter 7.
Highways and Transportation
Woolwell to the George Transport Scheme
Rockspring Barwood Plymouth Ltd acknowledges the need for off-site transport and highways measures and
are committed to making contributions to their delivery that are necessary and justified. Pre-application
discussions are ongoing with Plymouth City Council, Devon County Council and Highways England to inform
the Transport Assessment that will be submitted with the outline planning application. This will determine
what mitigation measures onand off-site will be required and will be controlled and enforced via appropriate
planning conditions and Section 106 Obligations.
Discussions between the Parties have continued in response to representations made regarding the limit on
occupation of new dwellings ahead of the completion of the Woolwell to the George Transport Scheme. The
modification to the policy set out above provides a caveat which is consistent with the wider policies of the
plan in relation to managing transport impacts and is in accordance with paragraph 32 of the NPPF.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
Plymouth City Council can confirm that development of the scheme is well advanced, with funding options
available, and is capable of being delivered by 2022, commensurate with anticipated delivery of the Woolwell
allocation.
Work to inform the Transport Assessment for the allocation continues; a further update can be provided at
the examination.
Main Access
Criterion 2 of draft policy PLY44 (as Submitted) states that the main access to the development must be
“submitted and delivered” prior to commencement of development.
The JLP Authorities recognise that this was a matter for review as set out in representations submitted on
behalf of Rockspring Barwood Plymouth Ltd. There is no definition in the policy as to which access is the
‘main access’. It is common ground that there are four potential points of access/egress for the Woolwell development and that the form and function of each needs to be agreed at the outline planning application
stage. The parties also agree that the timing of delivery of each access needs to be agreed at the planning
application stage and, acknowledging the scale of development, this will need to take into consideration the
phasing of development over the plan period.
The Parties therefore agree that the wording of criterion 2 should be further amended to the effect that the
main access arrangements are to be agreed prior to the main construction works being commenced and
delivered commensurate with the relevant phases of the development.
The Parties agree that the error in line M84 of EXC10A in relation to criteria 2 and the words ‘…are to be
agreed and delivered prior to the…’ is a drafting error. The changes should read as they are set out in this
Statement of Common Ground.
Outstanding matters yet be agreed by both parties
Whilst the Parties are in agreement with all substantive measures relating to PLY44, there are a number of
areas where complete agreement has not yet been reached.
The issues concerning the timing of delivery have been set out previously. In addition, agreement and/or
clarification is still being sought in respect of the exact nature of the Design Code referenced in PLY44
criterion 1.
Rockspring Barwood Plymouth Ltd has also sought to have the text “including the Pick Pie Plantation”
included within criterion 4(iii) to ensure that opportunities for its future management and inclusion as part of
the comprehensive urban extension.
The Inspectors are respectively asked to refer to the representations made on behalf of the landowners at
Regulation 19 stage in respect of the above. If these matters remain unresolved, representatives of Rockspring
Barwood Plymouth Ltd will present their case at the Examination.
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
The Inspectors are also requested to note that the Parties do not consider that these issues are of a
fundamental nature sufficient to prevent the delivery of PLY 44.
Summary and Conclusions
The agreements between Rockspring Barwood Plymouth Ltd and the JLP Authorities in this Statement of
Common Ground confirm the deliverability of the allocation of PLY44 within the plan period.
Significant cooperation between the Parties has taken place and will continue to do so both in terms of the
Local Plan Examination and the preparation and submission of an outline planning application.
Progress made since the JLP was submitted has also allowed the Parties to reach agreement on a revised
wording to Policy PLY44. These changes, which are recommended to the Inspectors, are considered to
improve the robustness of the Plan when considered against the relevant tests of Soundness.
Whilst there are outstanding issues between the Parties that the Inspectors may need to consider, it is agreed
that these do not relate to the soundness or deliverability of the allocation or that of the JLP as a whole.
Date of consideration by JLP Management
Date of consideration by JLP Steering Group
The contents of this document are agreed for the purposes of the Plymouth and South West Devon Joint
Local Plan Examination.
Signed on behalf of Rockspring Barwood Plymouth Ltd
Name and position Signature Date
Alistair Macdonald – Director,
Head of Boyer Bristol
(on behalf of Rebecca Mitchell -
Planning Executive, Barwood Land).
8th January
2018.
Signed on behalf of Plymouth City Council
Name and position Signature Date
Richard Grant
Local Planning Manager
8th January 2018
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Plymouth and South West Devon Joint Local Plan - Statement of Common Ground between Rockspring
Barwood Plymouth Limited and the JLP Authorities (December 2017)
Signed on behalf of South Hams District Council
Name and position Signature Date
Richard Grant
Local Planning Manager
8th January 2018
Signed on behalf of West Devon Borough Council
Name and position Signature Date
Richard Grant
Local Planning Manager
8th January 2018
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R
K
P
A
R
K
C
H
U
R
C
H
RO
CK
W
OO
D
RO
AD
C
T
B
O
W
E
R
S
L
A
R
C
H
D
R
IV
E
Shelter
Track
LB
Henroost Wood
Spring
Spring
B
i
c
k
l
e
i
g
h
V
a
l
e
Bickleigh Viaduct
P
a
t
h
(
u
m
)
P
a
t
h
(
u
m
)
Gauging Station
Pole
Issues
Issues
Mudwell Wood
Stone
89.9m
P
a
t
h
(
u
m
)
C
o
u
r
t
T
e
n
n
i
s
Stone
P
a
t
h
Sewage Works
Stone
S
p
r
i
n
g
Stone
Emmett's wood
Stone
T
ra
ck
Slurry Beds
E
T
L
Crapp's Wood
T
r
a
c
k
T
r
a
c
k
Tanks
Carn Wood
Hatshill Wood
R
i
v
e
r
P
l
y
m
119.8m
Bickleigh Down
129.5m
Issues
128.9m
FB
Collects
Track
Track
Pond
Hatshill
House
Coombe Wood
90.2m
138.4m
L
I
T
T
L
E
D
O
W
N
L
A
N
E
P
a
th
(
u
m
)
133.5m
79.2m
Spring
106.4m
115.5m
124.4m
El Sub Sta
Spring
School House Cottages
Issues
118.9m
110.0m
114.9m
House
Bickleigh
P
a
t
h
(
u
m
)
Sinks
War
Cattle
Coombe
100.6m
Barton
Meml
E
T
L
107.3m
92.0m
87.5m
Grid
Sinks
Issues
107.9m
T
r
a
c
k
o
f
O
l
d
T
r
a
m
w
a
y
97.8m
BL
AC
KE
VE
N H
IL
L
Loading Ramp
P
a
t
h
(
u
m
)
Coombe
Barton
Cottage
H
E
L
E
L
A
N
E
72.5m
71.3m
149.7m
141.4m
DN546112
DN546283
DN546283
DN545774
DN398910
DN546492
DN91094
DN546086
DN546078
DN545955
DN86711
DN546283
DN546283
DN555650
DN545623
DN545623
DN545623
DN545623
DN281263
DN91094 - PCC
Site Boundary
- 140.65Ha / 347.55Ac
Marristow Estate
Plymouth City Council
Hitchins Land
Reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No. 100019279.
The scaling of this drawing cannot be assured
Revision
Date Drn Ckd
- - - - -
N
0 100 200
50 150 250m
Disclaimer:
The boundaries included on this drawing have been provided using Land Registry polygon data under licence using the Ordnance
Survey Mapping. They must be checked by the client or its legal advisor against the original legal Title Plans for accuracy. Barton
Willmore accept no liability for the accuracy or content of the data included in this drawing or for any resulting errors omissions or
losses incurred in reliance on it.
ScaleDate
RevisionProject No Drawing No
Drawing Title
Project
Planning ● Master Planning & Urban Design ● Architecture ●
Landscape Planning & Design ● Environmental Planning ●
Graphic Communication ● Public Engagement ● Research
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J:\26000 - 26999\26700 - 26799\26734 - Woolwell\A4 - Dwgs & Registers\M Planning\26734 - RG-M-59 - Land Ownerships Within PLY 44 Boundary.dwg - (1-5000@A1)
Check byDrawn by
bartonwillmore.co.uk
Certificate FS 29637
DRAFT
26734
WOOLWELL,
PLYMOUTH
RG-M-59
LAND OWNERSHIP
WITHIN PLY44 BOUNDARY
02.11.171:5,000@A1
-
M.D. D.S.
or 1:10,000@A3