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  1. Purpose of Document

This Pre-Publication Consultation Statement describes how Tamworth Borough Council has undertaken communityparticipation and stakeholder involvement to produce the Local Plan/Core Strategy. It sets out how previous stages of consultation and engagement have shaped the Publication version of the Local Plan. It is produced to fulfil requirements set out in the Town and Country Planning (Local Planning)(England) Regulations 2012. It forms the statement defined at Regulation 17 (d) comprising, “a statement setting out:

(i) which bodies and persons were invited to make representations under regulation 18,

(ii) how those bodies were invited to make representations,

(iii) a summary of the main issues raised by those representations, and

(iv) how those main issues have been addressed in the Core Strategy.”

During the course of preparing the Local Plan/Core Strategy the relevant Regulations, originally published in 2004 were updated in 2008 and 2009. In April 2012 a set of Regulations were issued which replace all previous versions in their entirety. Whilst the requirement to produce this statement is not new, the specific regulations, which refer to it, have changed. The Regulations refer to the entire process of preparing Development Plan Documents (DPDs) such as the Local Plan. Work undertaken under previous Regulations is still valid albeit that the specific Regulation (including number) may have changed. Under previous regulations most of the work in preparing the Local Plan/Core Strategy was referred to as Regulation 25. In the 2012 Regulations the equivalent stage is referred to as Regulation 18.

This Consultation Statement forms one of the “proposed submission documents” referred to at Regulation 19. Italso highlights how the Council has met the requirements of the adoptedStatement of Community Involvement (SCI) (2006).

  1. Summary of consultation undertaken

The Borough Council has been working on the Local Plan/Core Strategy since 2006 and has produced a number of consultation documents, including the Issues and Options in 2008, an Option Report and a separate proposed Spatial Strategy, both in 2009, and most recently the specific Housing Policy document during early 2011.

Prior to the publication of this Pre-Submission Publication version of the Local Plan, a total of fivedistinct periods of consultation and engagement had taken place as follows:

  1. Early involvement on identifying issues and a vision for the Core Strategy: 2006/07
  2. Issues and Options: March 2008
  1. Refined Options Document: March 2009
  2. Participation on Preferred Spatial Strategy Document: October 2009
  3. Housing policies consultation March 2011

A number of consultation response reports have already been published, within Council and Cabinet Reports, which give details for each period of consultation including the issues raised, and how the comments made will be used to inform the subsequent stages of the Core Strategy’s production.The council’s responses were made to each comment received during stages2-5 of the consultation periods. In all cases the council’s response indicated where the comments made would result in a change to the Core Strategy.These are included within Appendix

It is important to emphasise that consultation was not restricted to these 5 periods; it has been continuous since 2006. During and between the consultation periods, the council has undertaken continuous consultation with the communities of Tamworth, along with other stakeholders including developers, landowners and infrastructure providers to input into the Core Strategy’s development. This has included delivering stakeholder workshops, staffed public exhibitions at borough wide locations and presentations to individual groups across the borough. In addition to ensuring information was made available on the Council’s website, permanent exhibitions on the Core Strategy were placed in the reception area of the council’s offices (Marmion House) and also at the central library. During the production of the Core Strategy a number of Local Development Framework (LDF) newsletters have been produced and distributed to keep stakeholders up to date of the Core Strategy’s progress.

In terms of who has been involved in the consultation, Appendix 5 sets out the organisations, including statutory bodies, who were invited to have their say and get involved in the Local Plan/Core Strategy’s development at each consultation stage, and where applicable, at specific policy development stages.

3. Relationship to the TamworthStatement of Community Involvement (SCI)

The SCI was adopted in 2006.It outlines who should be consulted at each stage of Core Strategyproduction and the sorts of methods which could be used.Since adoption, the Town and Country Planning (Local Development)(England) (Amended) Regulations 2008 have altered the stages ofproduction of a Development Plan Document, removing the PreferredOptions (regulation 26) stage and therefore reverting to a two ratherthan three stage consultation system.Under current legislation there are two stages where the documentshould be the subject of consultation namely the early stage ofdocument formation (Reg.18 stage) when issues and policy optionsare being explored and developed and then formal consultation on thePublication Version when the plan has been almost finalised (thecurrent stage). A revision to the SCI will beundertaken in due course to reflect changes in procedure.

The Council has therefore undertaken more consultation andengagement under the new Regulation 18 stage than is currentlyrequired. This would have been necessary in any event to give thepublic and stakeholders the opportunity to respond to alteringcircumstances, to adequately and comprehensively allow full andproper participation. The nature of the consultation and those involvedhas complied with the SCI.

The SCI proposes that the consultation methods and those engagedwith would vary according to the purpose of the consultation and thebodies or persons who the council were keen to involve. This provedto be the case with intensive wide ranging awareness raising eventsbeing predominant at the identifying issues and Issues and Options Stage including one to onemeetings with key stakeholders, workshops, andpublic exhibitions. This included a series of workshop events involvinglarge number of stakeholders in order to identify and refine issues, develop options andpreferences for shaping the spatial strategy for the borough.Throughout the Local Plan/Core Strategy’s preparation Tamworth councillors have been supported through individually tailoredworkshops and discussion sessions. The establishment of a cross-party LDF Working Group to oversee its production also ensured political buy in to the document at the most senior level.

Table 1 (reproduced from the Tamworth Adopted SCI, 2006): When will we involve you?

Defined Stage in Core Strategy Production (as defined in PPS12 & 2004 Regulations) / Prescribed methods of community involvement / Tamworth Core Strategy compliance with Amended Regulation 25

Pre-production

/ Community involvement is not prescribed at this stage. It will be for us to determine whether community involvement is required and what the most appropriate means would be. The level of community involvement will largely depend on the type of Development Plan Document being prepared. / Stage 1: Identification of issues and vision
Stage 2: Issues & Options Consultation
Stage 3: Refined Options Consultation
Production / During this stage community involvement plays an essential role. Informal community involvement will be undertaken at an early stage. We will involve a variety of stakeholders – relevant specific consultees and other organisations such as local community groups, environmental organisations, developers, landowners and agents – to discuss issues and participate in developing proposals and options. Stakeholders and interested parties will also have the opportunity to submit formal representations during a six-week consultation period on the Preferred Options Report. Representations received during this six-week consultation period will be taken into account in the preparation of the Submission Development Plan Document. / Stage 4: Preferred Spatial Strategy Consultation
Stage 5: Refined Housing policies Consultation
Submission / Formal representations can be submitted during a six-week consultation period. An additional six-week consultation period may be held on a Site Allocations Development Plan Document if representations seeking the inclusion of alternative sites and/or changes to the boundaries of identified sites are submitted during the initial consultation period. You can then make comments about these alternative sites or proposed boundary changes during the additional six-week consultation period. / Stage 6: Pre-Submission Consultation
Examination / If you have made a formal representation at the submission stage then the Inspector will consider your representation.
Adoption / There will be no opportunities for community involvement at this stage.

4. Relationship with the Sustainability Appraisal (SA)

The Sustainability Appraisal of the Core Strategy has been developed intandem with the Core Strategy’s production. An SA scoping report wasproduced for consultation in 2006. This enabled advice from stakeholders and the public to betaken into account in establishing the scope and objectives of the SA.

Sustainability Appraisals were undertaken (and were subject to consultation alongside the Core Strategy document) at the Issues & Options Stage, The Preferred Spatial Strategy and of the Housing policies consultation paper. The SA has been updated to apprise the current Pre-Submission Publication Document.Carrying out the SA at Publication stage has allowed it to reflect thepolicies in their more developed form and to reflect ongoing changes to both national and regional planning policy.

  1. Compliance with the Duty to Co-operate

The Council, in preparing the Local Plan/Core Strategy, will need to show that it satisfies Section 110 of the Localism Act 2011. The Council must work with neighbouring authorities and Staffordshire County Council as well as the following organisations:

  • Environment Agency
  • Historic Buildings & Monuments Commission for England
  • Natural England
  • Civil Aviation Authority
  • Homes & Communities Agency
  • Primary Care Trusts (PCT)
  • Office of the Rail Regulator
  • Highways Agency
  • Integrated Transport Authorities

The Council has worked closely with Staffordshire County Council, Natural England and the Environment Agency to ensure that future development is of the right amount, in the right location and can be successfully mitigated. In addition each of these organisations has submitted comments on the Local Plan/Core Strategy, including the accompanying Sustainability Appraisal- Strategic Environmental Assessment which have been addressed through subsequent revisions to the Local Plan/Core Strategy.

The Council has also been working closely with the County Council to identify the future educational provision required to deliver the strategy. The Tamworth Local Transport Plan (LTP) is a jointly agreed strategy between Staffordshire County Council and Tamworth Borough Council to deliver transport infrastructure. The LTP forms an important element of the Local Plan. The Highways Agency has procured a transport assessment of the strategy and identified a number of junction improvements to the A5 which are required to deliver future growth and these form part of the relevant transport policies within the Local Plan. The PCT has been engaged throughout the development of the Local Plan but has not identified any specific healthcare related infrastructure requiring delivery.

Tamworth has been working closely with its neighbouring authorities-namely Lichfield District Council and North Warwickshire Borough Council to identify future potential locations to deliver an aspect of Tamworth’s future housing needs. This resulted in the commissioning of a joint Development & infrastructure study in 2010 which assessed the suitability of arrange of sites across the 3 districts. This has subsequently informed the strategy for future housing delivery set out in the Pre-Submission Publication version. The Council has recently agreed a Memorandum of Understanding (MoU) with both Lichfield District and North Warwickshire Borough Councils. Both councils have agreed to deliver a proportion of Tamworth’s future housing needs within their respective administrative boundaries. The MoU sets out the number of houses to be accommodated, their distribution ad the phasing mechanism for their delivery. This will be set out in more detail through Lichfield and North Warwickshire’s respective Local Plans and within subsequent Development Plan Documents; should they be required.

Tamworth Borough Council has also worked jointly a number of authorities in preparing the evidence base for the Local Plan as shown in the following Table:

Document / Other Organisations Involved
Southern Staffordshire Districts Housing Needs Study and SHMA Update / LichfieldDistrictCouncil & CannockChaseDistrict Council
StaffordshireCounty Wide Renewable/Low Carbon Energy Study / All Staffordshire District & Borough Councils
Surface Water Management Plan / Stafford Borough, Lichfield District, Tamworth Borough, South Staffordshire District and CannockChaseDistrict Councils
Tamworth Future Development & Infrastructure Study / Lichfield District Council & North Warwickshire District Council
Gypsy & Traveller Accommodation Assessment / Rugby Borough Council, Lichfield District Council, South Staffordshire Council, Nuneaton and Bedworth Borough Council, Cannock Chase District Council, North Warwickshire Borough Council and Tamworth Borough Council
Water Cycle Study / Stafford Borough, Lichfield District, Tamworth Borough, South Staffordshire District and CannockChaseDistrict Councils
Strategic Flood Risk Assessment / Tamworth, Lichfield, Stafford and Staffordshire Moorlands Councils & Environment Agency
Habitats Regulations Assessment / Tamworth Borough Council & Lichfield District Council, Natural England
Strategic Housing market Assessment / Tamworth Borough Council, Lichfield District Council, SolihullMBC & BirminghamCity Council
Highways Agency Preferred Option Test Modelling Report / Highways Agency
Tamworth Local Transport Plan / Staffordshire County Council
Joint Indoor and outdoor Sports Strategy / Sport England
Staffordshire Extensive Landscape Character Study / Staffordshire County Council & English Heritage
Strategic Housing land Availability Assessment / Lichfield District Council & North Warwickshire District Council
Recreational Open Space Review / Sport England
Infrastructure Delivery Plan / Network Rail, Staffordshire Fire and Rescue, Staffordshire
Police, Severn Trent Water, South Staffordshire Water, National Grid

6. Consultation stages reviewed

The following section includes a breakdown of the consultation undertaken at each of the 5 discrete stages of the Core Strategy’s production to date. It includes details of the methods used, who was invited to submit representations and a summary of the issues raised. A more detailed summary of the issues, including the council’s response, and importantly how they were incorporated into subsequent versions of the Core Strategy is set out in Appendices 1-4.

Stage 1: Frontloading-raising awareness

The production of the Core Strategy commenced with officers working with Tamworth’s communities and key stakeholders to identify the issues affecting the borough. This involved producing and distributing a LDF Questionnaire which attempted to raise general awareness that the LDF process had begun. It was also about engaging with people early on and gaining a few ideas about the issues affecting Tamworth. The intention being that comments received would inform both the Core Strategy itself along with its accompanying Sustainability Appraisal.

The Council sent 220 LDF questionnaires to organisations and voluntary groups from the Tamworth area. The questionnaire which sought views on

what people valued, disliked and requires addressing, was also posted on theCouncil website.There were 26 respondents, 23 of which had comments

to make and were entered onto the Core Strategy database.

In terms of responses, factors including Tamworth’s built and natural heritage and attractions, its strong communities, potential for growth arising from

its strategic location were valued with infrastructure, litter, image and anti-social behaviour identified as dislikes. In terms of potential remedies, these

ranged from promoting AnkerValley as new sustainable neighbourhood to limiting high density residential development along with addressing the

causes of litter. These were fed into a list of potential issues for consideration by the Core Strategy whilst helping to inform the development of a vision

for Tamworth. This was used as a basis for the subsequent consultation stage of its production:

The Council then carried out informal consultation on the vision and issues for the Core Strategy from 15 February to 16 March 2007. 32,000 leaflets

were distributed with the local newspaper; the Tamworth Herald which included both a list of suggested issues for consideration by the Core Strategy

along with a vision for the Core Strategy. Copies of the leaflet were also sent directly to around 320 people and organisationson the LDF database who

wish 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.

104 respondents made a total of 183 representations to the Core Strategy vision and issues consultation. This amounted to a 0.3% response rate, which was disappointing compared with the number of leaflets and letters that were distributed. The low response rate could be explained by the nature of the consultation, which was to stimulate discussion about a vision for the future and general issues. Many people commented that the issues that had been highlighted were obvious and valid but without firm proposals they found it difficult to comment in detail.

However, comments received illustrated general support for the vision for the Core Strategy; in particular the need to focus investment in the town centre, the need for supporting infrastructure (roads, community facilities, green spaces) to deliver the vision, support for development to respect local character and distinctiveness, minimise Greenfield development, preservation of historic buildings, ensure facilities and opportunities for both younger and older people, the need for an element of future housing provision to be accommodated outside of the borough, a greater emphasis on biodiversity and renewable energy and the need to align more closely with the (then) Tamworth Community Plan. In terms of the issues, respondents generally agreed that the issues identified were the correct ones for the Core Strategy to address although the need for improved linkages between the town centre and the out of centre retail areas and to employment areas in general, the re-use of vacant town centre properties, protecting and enhancing the canal and a greater emphasis on ensuring future growth is not at the expense of the natural and physical environment.