1. DISTRICT STRATEGY 1.1 Overview 1.1.1 This first chapter of the report deals with strategic matters. It sets the scene for consideration of objections to other District-wide Plan policies and the subsequent examination of area policies on a settlement by settlement basis. Given the history of local plan preparation at Bromsgrove it is inevitable that the focus is very much on the identification of sustainable locations for growth, ADR designation, and the confirmation/amendment of Green Belt boundaries. 1.1.2 I commence with an examination of issues considered at the Round Table Session held on 24 May 2001 attended by, amongst others, the House Builders’ Federation and many of the national housebuilders active in the region. I conclude that the quantity of ADR land identified by the Council (141.6 ha, excluding the 10.3 ha employment-related ADR for Redditch) is likely to be sufficient to accommodate longer-term development needs well beyond the Plan period - to about 2021, and possibly beyond that - thereby satisfying PPG2 (Green Belts) requirements in respect of safeguarded land. The Council’s general distribution of ADR land is supported. This provides for a concentration of ADRs on Bromsgrove town, the largest and dominant settlement in the District, with secondary growth at other sustainable settlements situated within public transport corridors on the conurbation side of the District. I look at the selection criteria used by the Council in its review of candidate ADRs and set out the basis on which I assess the suitability of objection sites. I recommend that land be designated as ADRs and excluded from the Green Belt at: the former Brickworks site, Alvechurch; south of Kidderminster Road, Hagley; Bleakhouse Farm, Wythall; Church Road, Catshill; and Kendal End Road, Barnt Green. 1.1.3 Other topics covered in this early section of the report include ‘village envelope’ settlements, planning obligations, sustainable development and enforcement of planning control. ******************** 1.2 Round Table Session – Areas of Development Restraint 4/1002 The Hagley Estate 1 Bromsgrove District Local Plan (Proposed Modifications) Inquiry 2001 – Inspector’s Report 6/1002 The Hagley Estate 578/1002 The Hagley Estate 1258/1053 Mr J M Pashley 166/1074 The Bromsgrove Society 300/1075 Crest Homes Midlands Ltd 574/1244 J J Gallagher Ltd 1262/1382 Bryant Group 211/1385 Stansgate Planning Consultants (Various Clients) 1036/1386 House Builders’ Federation 1037/1387 Bellway Estates 1044/1388 David Wilson Estates 1242/1405 Wimpey Homes Holdings Ltd 1052/1429 Westbury Homes (Holdings) Ltd 1064/1430 Persimmon Homes 1076/1432 Bovis Homes Ltd 1086/1433 Barratt West Midlands (These objections also appear in the report under Policy DS8 [Proposed Modification No DS/MOD12]) Key Issues 1.2.1 (1) Whether (a) the BDLP should be abandoned and a new Plan prepared in accord with policies of the Worcestershire County Structure Plan 1996- 2011, or (b) the Plan period should be extended to 2011. (2) Whether 2016 is a suitable time horizon for ADR provision. (3) Whether sufficient ADR land has been identified and justified in the explanatory text. (4) Whether the overall geographical distribution of ADR land proposed is appropriate. (5) Whether the Council’s ADR selection process has been comprehensive and rigorous, subject of proper consultation and the choice of sites adequately explained. (6) Whether ADR sites should be prioritised, phased or ranked in order of suitability. (7) Whether ADR sites should be described in terms of gross area or net developable area. (8) Whether there is a meaningful distinction to be drawn between ‘interim’ and ‘confirmed’ Green Belt in terms of ADR selection. 2 Bromsgrove District Local Plan (Proposed Modifications) Inquiry 2001 – Inspector’s Report Inspector’s Appraisal and Conclusions 1.2.2 Issue 1: The Council has explained in Background Paper 5 (Plans Relevant to Bromsgrove) the reasons why it is continuing to progress the BDLP to adoption, despite the fact that the Plan is time-expired with a nominal end date of March 2001. Amongst these is the strong encouragement being given by the Government Office for the West Midlands. 1.2.3 I agree that it is vitally important to see the process through to the end. Not only will this result in completion of district-wide local plan coverage of the county, which is an important government planning objective in itself, but it will confirm Green Belt boundaries for all parts of the District. This will afford greater certainty for all involved in the development process. Moreover, the establishment of Green Belt boundaries and the provision of safeguarded land to meet likely development needs well beyond the Plan period will, I am sure, reduce the time taken to undertake a Review of the Plan. I am told that such a Review has already started and is proceeding in parallel with the present procedures. 1.2.4 The BDLP has been prepared in the context of the Hereford and Worcester County Structure Plan 1986-2001, published in June 1993. It has received a certificate of general conformity with that Plan. During its later developmental stages consideration has been given to the substance of national and regional planning policy guidance as it has emerged. Moreover, regard has been paid to the thrust of policies contained in the now-adopted Worcestershire County Structure Plan 1996-2011 (published in June 2001) and to the detailed recommendations of the previous Local Plan Inspector. As recently as 27 February 2001 Worcestershire County Council confirmed that the Proposed Modifications would not give rise to a conformity problem. In these circumstances, and notwithstanding the extremely protracted evolution of the Local Plan over a decade or so, I see no compelling argument in favour of abandoning the Plan. A fresh start under the strategic umbrella of the new Structure Plan would be likely to prove another long and frustrating exercise. This would be extremely expensive both in terms of the work already done by the Council, much of which would be forfeited, and the continued inappropriateness of many of the Green Belt boundaries that are tightly drawn around the urban areas. Any additional delay in establishing enduring Green Belt boundaries would undoubtedly give rise to further pressure for undesirable ad hoc development. 1.2.5 As regards the suggestion of extending the Plan period to 2011 to be in line with the new Structure Plan, this would I feel be quite inappropriate given the policy base of the BDLP that is rooted in the earlier Hereford and Worcester County Structure Plan 1986-2001. To take this course of action would inevitably cause the Plan to be out of conformity with strategic policy. 3 Bromsgrove District Local Plan (Proposed Modifications) Inquiry 2001 – Inspector’s Report 1.2.6 Issue 2: The BDLP Inspector found the Council’s ADR provision in the Deposit Draft to be severely inadequate. He concluded that the three ADRs proposed at BROM5, HAG 1 and HAG 2, together totalling 52.6 ha, would only be sufficient to last 4 or 5 years. This would not, in his view, be a reasonable interpretation of the phrase used in Annex B of PPG2 of “..well beyond the plan period”. He recommended that the Council should aim to provide an absolute minimum of 15 years ADR supply beyond the current plan period - that is, to 2016. 1.2.7 The Council has accepted the Inspector’s recommendation. It intends, through the Proposed Modifications, to identify sufficient ADR land to meet requirements up to a time horizon of 2016. None of the objectors, nor indeed the Council, support an earlier end date of 2011. The BDLP Inspector pointed out that such a date is only 10 years beyond the current plan period with the likelihood that well before then uncertainty about the Green Belt would recommence. I take a similar view. As regards 2016, the Bromsgrove Society and a number of individuals ally themselves with the Council. However, other objectors favour a minimum date of 2021 and a third group, including the House Builders’ Federation, a date of 2026. All agree that the key consideration should be the permanence of the Green Belt boundaries; and that a fundamental long-term review is needed at this stage, rather than being left for a subsequent Review of the Local Plan. 1.2.8 This is a difficult judgement to make. On the one hand, too short a time horizon could result in the need for another review of Green Belt boundaries during the next plan period, contrary to the thrust of PPG2 advice in respect of safeguarded land. On the other hand, it is argued that an overly-generous ADR provision and end date could conceivably make the District a target for even greater pressures, encouraging future strategic planning exercises to allocate more than a fair share of development to Bromsgrove District in light of the area’s apparent ‘potential’. This would be contrary to concerns expressed in the recently published West Midlands Regional Planning Guidance Review consultation document that too much growth is taking place in the Shire Districts at settlements like Bromsgrove and Tamworth which are becoming dormitory settlements. Such a model of growth is now regarded as an unsustainable pattern of development for the conurbation. It could also discourage developers from properly examining urban capacity, contrary to PPG3 (Housing). 1.2.9 On balance, I consider that the most appropriate time horizon for ADR provision is 2021. This makes a moderate and proportionate allowance for the long delay experienced in actioning the BDLP Inspector’s report. It would not, in my opinion, lead to an unreasonable degree of development pressure for several reasons.