At the Special Meeting of Tanworth Parish Council on 28 January 2016 the Neighbourhood Development Plan Steering Group, under Michael Saunders and Jonathan Ashcroft, sought feedback on its first draft document. The following are my views of the progress that has been made so far and where we should go from here.
From the beginning everyone realised this was a process that would have to wait to see how SDC’s Core Strategy evolved over time – and evolve it most certainly has. Just as the Parish Council was given conflicting advice about how an NDP should be undertaken before it began the whole adventure so the Steering Group has had to cope with substantial changes to what it is expected to do.
According to the original brief from Stratford District Council:
- The Local Service Village concept was to be applied across the district without regard to whether or not the villages were in Green Belt.
- There were to be targets applied to each LSV, Wood End, Earlswood and Tanworth village proper, according to Category.
- All three LSVs in our parish were expected to meet individual totals of new houses – eventually a combined total of 100 was proposed.
A survey of residents was conducted by the Steering Group based on this original advice. You will be aware that details of the housing totals changed up till the very last minute before it was printed.
Following the dramatic intervention of the Inspector at the Core Strategy Examination – at the specific request of the Parish Council and both Residents Associations – all this has been substantially revised.
As of February 2016:
- LSVs in Green Belt will be treated differently from other LSVs – with the normal Green Belt rules set out in the government’s National Planning Policy Framework applying case by case: brownfield, limited infill and small scale developments only.
- There will now be no targets set for LSVs in Green Belt at all. At least initially SDC hopes to meet its five year land supply by the inclusion of major sites like Long Marston as well as the controversial Gaydon.
- There is no requirement to suggest sites in all three LSVs in order to meet NDP guidelines ie the need for an NDP to identify places in the parish where new housing might be located.
Given these substantial changes to the brief it would seem reasonable for the Parish Council to invite the community to consider revisiting the central argument as to whether or not an NDP is appropriate for a place like Tanworth-in-Arden at all.
Is there not a case for relying totally on the existing protection afforded by the NPPF?
Why bother with an NDP at all?
On balance – with the substantial concessions we have gained – I now believe that it is the probably better to undertake an NDP than not to. In that way, as well as leading the argument about the relative merits of possible sites, the parish can, more importantly, make clear what limited development it will accept, establish what it does not want , and more importantly where it does not want it.
Of course, we need to accept that an adopted NDP will only be a “material consideration”- one of many factors- in determining future planning applications, but the government has made clear it will be a brave Local Planning Authority that ignores a properly constituted NDP.
For that reason I am now a proponent of continuing the process of preparing an NDP.
The first draft of our NDP needs, however, to be amended to reflect these changed circumstances and more importantly to set out a comprehensive vision of how we see the parish changing until the next Local Plan after this one emerges: Again, what we want and what we don’t want.
Inevitably, the Parish Council accepted from the start that identifying individual housing sites will be the most contentious aspect of the NDP process.
To my mind the only major flaw in the work undertaken so far by the Steering Group is that in all three LSVs the search for sites has not been comprehensive: all sites need to be identified that meet the narrow NPPF guidelines. In addition if we so decide we can offer other possible sites if the criteria to be adopted are altered with the consent of the community through its Parish Council and, ultimately, at a referendum.
I have taken the liberty of setting out below a possible revised shape for the next draft of the NDP providing both a vision and detailed list of additional sites at least for consideration. It is only by identifying all possible sites and accepting or rejecting them with valid reasons stated that the final NDP will be acceptable to other bodies, the District Council and the independent Inspector, as well as to the Parish Council and the community at large.
Suggested Shape of the next NDP Draft
The NDP must begin by stressing the importance the community places on the fact that the whole parish is within Green Belt – that fact is shown to be greatly valued in our survey of residents. Anything suggested in the Neighbourhood Development Plan (NDP) must protect and enhance this priceless asset.
Following the Examination of the Stratford on Avon District Council (SDC) Core Strategy the residents of the parish of Tanworth in Arden are content to rely on the protection afforded by the National Policy Planning Framework (NPPF) and now confirmed by the adopted SDC Core Strategy itself.
A major factor in considering the shape of the parish over the next two decades is its unique geographical situation. It is surrounded on three sides by expansive councils Redditch, Bromsgrove and Solihull with the shadow of Birmingham ever present. Neighbouring authorities seem to be content to rely on Tanworth for Green Belt with several proposing building to our very boundary.
It is all the more important that both SDC and Warwickshire County Council (WCC) are encouraged to support the maintenance of the rural nature of the parish. The NDP is particularly concerned to avoid any major development on the North East and South East quadrants of J3 of the M42 at Portway. It has also concluded that a “park and ride” or Parkway facility would not be appropriate at any of the three railway stations within the parish – The Lakes, Wood End or Danzey.
Two key aims should be at the heart of our NDP:
1) The avoidance of urban sprawl – the main reason for the establishment of the Green Belt in the first place
2) The protection not just of the character but also of the unique setting of twin gems of the parish – Tanworth Conservation Area and the Earlswood Lakes
In order to achieve the first aim no sites should be identified in our NDP that would cause existing villages or settlements to merge eg Tanworth village and Wood End along Vicarage Hill or Wood End and Earlswood along The Common. Also sites were discounted that would take the built up areas towards our western and northern boundaries.
The second aim is dear to the heart of our community and is well set out in the excellent environmental section of the NDP
At the outset we wish to identify two major concerns about the declared policies of SDC:
1) We object to SDC’s plans to categorise Wood End as a Local Service Village (LSV). It is a riibbon development
2) We are concerned about the determination of SDC to identify Built Up Area Boundaries (BUABs) in Green Belt.
Faced with determined opposition from us when SDC tried to impose BUABS on LSVs in Green Belt through the Core Strategy the Council now seeks to implement this policy through the back door during the preparation of a Site Allocations Plan (SAP). We have been unable to find the concept of LSVs anywhere else in England and to our knowledge no other local authority feel the need to identify BUABs in order to establish what and what is not infill in Green Belt.
To try to address this problem our NDP examined three possibilities:
Not identifying the two outstanding BUABs in our NDP namely Tanworth proper and Wood End
Drawing tight boundaries along the lines of those previously identified by SDC eg those drawn up for Earlswood some years ago (H. Earl)
Draw loose boundaries in one or more LSVs (or widen the existing ones in the case of Earlswood) to allow additional specially chosen sites acceptable to the community at large that would normally be deemed outside BUABs
Clearly the Core Strategy no longer imposes targets for each of the three LSVs. There is actually no need to identify any sites in LSVs in Green Belt beyond brownfield or limited infill. In open countryside only sites that met the normal NPPF criteria would be permitted anyway.
Any additional sites identified by the NDP and agreed at a referendum beyond the tightly drawn boundaries would no longer need to be identified in all three LSVs either. One or none would meet the government’s criteria for a qualifying NDP.
In the end the community should decide not to identify BUABs for either Wood End or Tanworth. If that argument should subsequently be proved unsustainable we should retain the ability to opt for Option Two – the proposed tight boundaries as set out in Appendix ?.
There can be no doubt that any attempt to identify any sites in the three LSVs beyond brownfield and limited infill will be the most controversial aspect of the whole NDP process.
The fear of those drawing up this NDP must be that one controversial proposal could sink the whole plan either when it is considered by the Parish Council or at referendum stage. Clearly, the Steering Group would wish to avoid wasting all the considerable effort that has been invested in the preparation of the plan.
The NDP needs first of all to identify all the possible brownfield and infill options available in all three LSVs eg Doctor’s Hill and any brownfield opportunities in the wider parish eg old MEB site on A435 , the current sewerage works outside Tanworth or the garage facility at Gorcott Hill.
Only when that has been done comprehensively can consideration be given to rejecting those sites that are totally unsuitable and seeking possible additional sites to be recommended for projects such as starter homes or buiding properties suitable for residents wishing to downsize.
I am not suggesting or endorsing any of the following but the NDP must show that it has considered all possibilities and stoutly rejected those that are unsuitable and not acceptable to the community.
The following list is by no means exhaustive and clearly not without great controversy.
Tanworth Village Proper
The conclusions of the NDP should be that, with the projected Doctor’s Close and Cank Farm developments and one possible infill site on Doctor’s Hill, Tanworth village proper has been developed enough for the foreseeable future.
The Butts sites, North and South on the school side, should not be considered as ever being suitable for development as they would damage the character and setting of the village and in particular the view of the parish church from the east.
Similarly, the gap site on Vicarage Hill next to the Bellfield, any extension of Bates Lane west from Far Leys or towards the two houses on the north side of existing extended Bates Lane toward Forde Hall Lane or finally between Oxgangs and Tanworth Cottage should be firmly rejected as inappropriate.
The obvious possibility for a few starter or downsize house is the Warwickshire Lad site. I will leave it to others to advocate that site. Unsuitable sites because they are likelt to cause sprawl are any further extension along Penn Lane or Vicarage Hill, the fields at the junction of Penn and Broad Lane, any extension along the Common or Wood End Lane towards the M42 or along Broad Lane towards Aspley Heath/Rushbrook Lane.
As the only LSV with established BUABs I am sure Earlswood Residents can offer up both possible sites that could be developed and identify the ones that are unsuitable.
The existing NDP Environmental section is excellent and must cross refer in detail to the kind of general principles set out above. The final Executive Summary and the NDP opening and closing sections need also to be clear and unambiguous.
In conclusion, despite the changes in policy we have helped achieve so far, government can always change its policy or be changed itself after the 2020 election.
Secondly, Stratford District Council still has two major weapons up its sleeve – the Site Allocations Plan it is preparing and its conversion to the idea of a West Midlands Combined Authority. Both of these represent major battles to come.
Tanworth-in-Arden NDP must be a weapon in our armoury – not in theirs.