Soundness tool
Key question / Possible evidence / Evidence provided /Justified
Participation
1. Has the consultation process allowed for effective engagement of all interested parties? / The consultation statement / The Council have produced a Statement of Community Involvement (Adopted 2006). This document outlines the details of all the stakeholders who were consulted, how and when they were, during the formulation of the plan.
http://www.tamworth.gov.uk/planning/local_development_framework/statement_of_community_involve.aspx
In line with the SCI, an extensive and ongoing process sought to involve all the stakeholders. The following consultation stages were undertaken:-
Stage 1: Frontloading-raising awareness
A Vision and Issues Consultation leaflet (2007) was produced. This informed stakeholders of the council’s intention to replace the existing development plan with a Core Strategy. It was seeking a response in relation to identifying the issues facing the area and formulating vision for the development/growth of it.
32,000 leaflets were distributed with the local newspaper; the Tamworth Herald. They were also sent
directly to around 320 people and organisations on the LDF databases who wished to be kept informed.
The information was available on the Borough Council’s website and an exhibition was displayed in the
Council’s customer service area for the duration of the consultation period.
Stage 2: Issues & Options
The Issues and Options Paper (2008) was seeking to raise a debate amongst stakeholders to identify all the issues facing the town and potential options for addressing them, in relation to the future development/growth of the town.
This document was sent to all statutory and Non statutory consultees and was made available in libraries
and in the Council’s customer service area as part of an exhibition during the consultation period. The
Council also used Limehouse, an online consultation portal which allowed stakeholders to view the
document and make representation against specific chapters, policies and paragraphs. All consultees
received an automatic email notification and a link to this portal was made available on the Borough
Council’s website where the documents could also be downloaded.
Stage 3: Options Document
The Options Paper (2009) set out an amended vision for the how the Borough will develop, Spatial Objectives to address the key issues identified and spatial options for determining the scale/location of growth, as well as draft Core Policies for managing and promoting sustainable development.
Exhibition about the option and core policies were displayed in the Customer Service area of Marmion House and the 2nd floor of Tamworth Library. This was accompanied by a Core Strategy Update Newsletter which contained summary information about the Options consultation and current progress on the Core Strategy.
Stage 4: The Preferred Spatial Strategy
The Core Strategy: Proposed Spatial Strategy (2009) document outlined what development will occur, where, when and the scale of it, in order to meet the vision/objectives of the area.
In 11 locations of the borough exhibitions were held, manned by staff. This gave an opportunity for members of public to ask questions and discuss their issues/concerns in relation to the Core Strategy, as well as make representations.
Physical copies of the main documents were made available in Glascote Library, Wilnecote Library and the mobile library. All the documents could be accessed and downloaded from the Council’s website.
Stage 5: Housing Policies Consultation
The Council re-drafted its housing policies from the 2009 Proposed Spatial Strategy document and produced a Housing Policy Consultation Document (2011) which was subjected to a 6 week consultation period. The re-drafted policies reflected an important piece of evidence on affordable housing viability which enabled the formulation of realistic affordable housing targets. Advice obtained from Gypsy and Traveller representatives facilitated a more responsive policy to be drafted.
Stage 6: Local Plan Pre-Submission Publication Document[1]
This document (March 2012) outline the final strategy for the development of the area and seeks stakeholder representations in relation to the soundness of the document.
In compliance with the SCI and regulation a Consultation Statement Regulation 17 (d) of the Town and Country Planning (Local Planning) (England) Regulations 2012 has been produced. This document outlines which stakeholders were consulted, when, how they were, as well as summarises the comments that were made in their representation and how they were taken into consideration, throughout the different stages of the formulation of the development plan.
In addition, the Cabinet Reports for the Core Strategy (2008, 2009, 2010, and 2011) that were produced during various stages of the formulation of the plan demonstrated that the consultation processes have allowed effective engagement of all the interested parties. They include all the details of a large range of stakeholders who submitted representations for the plan.
Research/ fact finding
2. Is the content of the development plan document justified by the evidence?
3. What is the source of the evidence?
4. How up to date and convincing is it? / i. Sections of the development plan document which show how the evidence points towards the selected strategy, policies or proposals
ii. Sections of the pre-submission proposals documents
iii. Sections of the preferred strategy report
iv. Sections of the sustainability appraisal report which set out its main conclusions in relation to the policies in the development plan document
v. Sections of the consultation statement
OR
A very brief statement of how the main findings of
consultation support the policies, with reference to:
o reports to the council on the issues raised during participation, covering both the front-loading and formulation phases
o any other information on community views and preferences
vi. The studies, reports and technical papers that provide the evidence for the policies set out in the development plan document. The date of preparation and who they were produced by should be signposted
OR
For each policy (or group of policies dealing with the
same issue), a very brief statement of the evidence
documents relied upon and how they support the
policy (where this is not already clear in the
reasoned justification in the development plan
document) / The Local Plan is considered justified by up-to-date evidence. A number of pieces of evidence were produced to inform the preparation of the Core Strategy, which have been referenced throughout the document to explain the position taken.
A list of all the evidence based document (including reports outlining consultation finding) that have been used to inform the content of the Tamworth Local Plan have been included in Appendix 1.
All of this evidence was produced or updated in the last couple of years and can therefore be considered up to date.
5. What assumptions had to be made in preparing the development plan document?
6. Are the assumptions reasonable and justified? / i. Sections of the development plan documents setting out the assumptions
ii. Sections of the sustainability appraisal report setting out the assumptions
iii. A very brief statement for each assumption as to how the evidence led to the assumption
iv. Reference to national or regional policy, correspondence from bodies consulted or technical papers that provide the basis for assumptions / At the outset of the formulation of the Local Plan, it was clear that the area is expected to experience high levels of growth and it would be difficult to meet all of the housing/employment needs, aspirations of it and address other issues within the area. This was due to the fact that the area faces sever development constraints such as flood risk areas, Green Belt and a tight administrative boundary. Therefore, the Local Plan set to determine the maximum levels of housing/employment growth for the area, which are most appropriate and sustainable (i.e. via weighing up social, economic and environmental considerations of the options, simultaneously).
The assumptions were outlined in the vision and issues consultation leaflet (2007). This was seeking a response in relation to all the issues facing the area and whether there were any additional issues that had been overlooked. This was followed by an issues and options stage, etc. Based upon the consultation responses, the issues have been amended or refined during the various stages of producing the Local Plan (Cabinet Reports, 2008-10; Consultation Statement, 2012).
The Local Plan: Pre submission Publication document (2012) has set out the assumptions of the document in the spatial portrait, issues and challenges sections (i.e. Chapter 2). In summary they were; the need to increase the delivery sufficient employment/housing sites and its supporting infrastructure due to economic/housing projections of the area.
The assumptions are justified by the evidence base. The details are outlined below:-
Consultation Statement (2012).
Southern Staffordshire Districts Housing Needs Study and SHMAA Update (2012)
Sustainability Appraisal incorporating Strategic Environmental Assessment (2012)
Employment Land Review (2012)
Cabinet Report: Tamworth Core Strategy: Proposed Housing Policy Consultation Responses (2011)
Core Strategy: Housing Policy Consultation (2011).
The Tamworth Town Centre & Retail Study (July 2011)
Strategic Housing Land Availability Assessment (2011,2012 and October update 2012)
Affordable Housing Viability and Policy Study (2010)
Cabinet Report: Core Strategy : Proposed Spatial Strategy Consultation : Responses (2010)
The Core Strategy Options Paper (2009):
Core Strategy: Proposed Spatial Strategy (2009)
Meeting the need for office development in Tamworth (2009)
Tamworth Future Development and Infrastructure Study (2009)
Core Strategy: Issues and Options Paper (2008)
Cabinet Report: Core Strategy: Issues and Options Consultation: Responses (2008)
Sub-Regional Gypsy and Traveller Accommodation Needs Assessment (2008)
West Midlands Regional Spatial Strategy : Phase Two Revision (2008)
2006 mid-year population estimates produced by the Office of National Statistics
Strategic Housing Market Assessment (2008)
Strategic Housing Land Availability (2008)
Employment Land Study: Future Land Estimation – undertaken by Staffordshire
County Council. (Produced May 2008)
Vision and Issues Consultation leaflet ( 2007)
Alternatives
7. Can it be shown that the council’s chosen approach is the most appropriate given the reasonable alternatives?
8. Have realistic alternatives been considered and is there a clear audit trail showing how and why the preferred strategy/approach was arrived at?
9. Where a balance had to be struck in taking decisions between competing alternatives is it clear how and why these decisions were made? / i. Sections of the consultation statement showing how the community was involved in considering issues, alternatives and options
ii. Documents used in community involvement with stakeholders and communities encouraging them to identify the issues and options they wished to see considered
iii. Any report produced at the end of the front loading phase of plan preparation setting out the issues and options raised
iv. Sections of the preferred strategy report explaining:
· how alternatives were developed and evaluated, and
· why alternatives were rejected in favour of the preferred strategy
v. Sections of the sustainability appraisal report showing the options and alternatives and explaining how they were objectively assessed
vi. Reports prepared during the plan preparation process (including after the preferred strategy participation) contributing to the decisions made on the inclusion of policies in the development plan document
vii. Sections of the consultation statement explaining how the main findings of consultation support the decisions
viii. Sections of the representations statement
OR
A brief statement of the influence upon decisions of:
the issues raised during stakeholder and community
engagement, and how they have been addressed
ix. Any other documentation showing how alternatives were developed and evaluated
x. A very brief statement and any other supporting documentation of the way decisions have been taken / The Local Plan was amended throughout the various stages of its formulation of the development plan, based upon the findings of stakeholder consultation responses and various pieces of evidence that have been collected and updated. It can be considered that the chosen approach is the most appropriate against the reasonable alternatives.
During the early stages of the formulation of the plan, the Issues and Options document (2008) outlined all the reasonable alternative options for accommodating growth in different locations of the area and how meeting the aspirations/ needs of the local community have been explored. It proposed four potential growth options for the town and the relative merits/weaknesses of each option. The growth options were: - 1. Urban Regeneration/Self Containment, 2. Urban Containment and Anker Valley Intensification, 3. Greenfield Urban Extensions, 4. Greenfield and Green Belt Urban Extensions. An initial sustainability appraisal examined the social, economic and environmental impacts of all the options. Both growth options 1 and 2 scored high against the sustainability objectives in comparison to the others. A hybrid version of all the options was taken forward. It should be emphasised that there was no robust credible case for an urban extension within the Greenbelt.
Initially, the WMRSS set out the scale/type of employment/housing growth required for the area and broad locations for it. This was used as the starting platform to raise discussions during the Local Plan Issues and options consultation stage. However, following the Governments intention to revoke the WMRSS, the most appropriate scale of growth for the area has been based upon an updated locally derived evidence base (i.e. SHLAA, SHMA, ELR, etc).
The strategic urban extension at Anker Valley option (i.e. 2) has been taken forward in the Local Plan: Pre- Submission document (2012) after numerous stages of consultation and evidence gathering. The initial Sustainability Appraisal (2008) assessed the social, economic and environmental impacts of the spatial growth options and it achieved a high score of 10. However, it should be emphasised that this spatial option performed poorly against the Sustainability Appraisal’s environmental objectives due to factors such as the site is located on a Greenfield site; and its potential negative impact on surface water flooding, biodiversity, proximity to sites of nature conservation interest. In comparison to this, the economic/social sustainability benefits of the Anker Valley spatial option are; it is located close to the town centre which would make it easier to create new sustainable transport links/reduce the need to travel, it will enable the town to meet its housing requirement and deliver a large mix/type/tenure of housing to create mixed sustainable communities, create new opportunities to deliver local facilities/services and create a diverse competitive economy through reducing pressure on the need to use existing employment sites for alternatives uses. However, the overall impact of the socio-economic benefits and the negative environmental impacts of the option were considered neutral (SA 2012, P21). Therefore, mitigation measures have been incorporated (i.e. via improving the linkages and accessibility; particularly through walking/cycling and public transport links) to minimise/eliminate any negative impacts and increase the overall sustainability scoring of the spatial option.