Local Plans and National Planning Policy Framework: LPA Self Assessment

Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

Local Plans and the National Planning Policy Framework

Compatibility Self Assessment Checklist

(April 2012)

Introduction

We have produced a checklist to help you assess the content of your local plan1 against

1 We use the term “local plan” throughout this document. However, adopted plans may 1 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment requirements in the National Planning Policy Framework (NPPF) that are new or significantly different from national policy previously set out in PPGs and PPSs.

These elements are highlighted in red and in italics.

Although not part of the NPPF it also includes the ‘Planning policy for traveller sites’ published on 23 March 2012.

How will it help?

We want to help local authorities to get up-to-date plans in place. This tool will help you to:  assess your local plan against national policy  identify gaps  understand risks  start to plan how to manage those risks.

This will help you to:  respond proactively and speedily to the NPPF  prepare for an examination  make robust planning decisions  implement your policies.

PAS will continue to work with authorities through the NPPF transition period.

Why does it matter?

It matters because to have a plan-led system we need to have sound plans in place. The transition arrangements give authorities with an adopted plan a year to get their policies ‘up to date’ (in conformity with the NPPF). After that, the policies will be judged by their degree of conformity and the presumption in favour of sustainable development will apply. If you haven’t got a plan in place, you need to do so as soon as possible; the further along the process you are, and the closer the conformity of your policies, the more weight they will have (for full details see Annex 1 ‘Implementation’ paragraphs 208-219).

For PAS’s interpretation of what you need to know about transition, see ‘Things we think you should know about the NPPF’.

Who should use it?

The checklist was written with adopted plans in mind, but it should also be useful as a check for emerging local plans. It is for all planning authorities in England, including counties and National Parks.

What it doesn’t do

It is not an interpretation of national planning policy or a prescribed solution. It excludes the implications of the Localism Act. It doesn't deal with the process of plan-making or aspects of the NPPF which relate specifically to decision making. Nor does it list the things that you don’t have to comprise a number of development plan documents prepared under the Planning and Compulsory Purchase Act 2004, in which case it may be all of those documents that a local planning authority may wish to consider in the context of the NPPF using this document. 2 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment do any more as requirements have been dropped.

What else are PAS doing?

There are more parts to this document to follow, including  a comprehensive checklist of all requirements, new and retained,  An understanding of what the ‘gaps’ or discrepancies might mean for you (your risks)  Some actions you could take to address these risks How should you use it?

We have structured the checklist in the order of the NPPF, but you might want to prioritise the areas that you think are most important to your area and your overall strategy, and concentrate on the policy areas where you have the most development pressure.

The checklist has used, wherever possible, the same wording as that set out in the NPPF. However, our focus has been to capture the main ‘prompts’ that you need to consider while keeping the checklist to a reasonable length. However you should cross-refer to the NPPF itself whilst going through the checklist. We have provided paragraph references to help you do this.

Note, however, that this document highlights the new/significantly different bits of the NPPF compared to PPGs and PPSs. You’ll need to think about whether, if you’ve quite an old adopted plan, it was fully compliant with more recent bits of government guidance (eg PPS3 revised June 2011).

The checklist concentrates on identifying where the gaps (or incompatibilities) are; you might want to also keep your own audit trail of the evidence you have identified to demonstrate compatibility, or otherwise, with the NPPF.

How we made it

 We looked at the NPPF and the Impact Assessment published alongside the draft NPPF.  We identified the main things that it asks or requires local plans to include, and highlighted those that are significantly different from previous national policy and guidance as set out in PPGs and PPSs.  We turned this into a checklist, and set out some ideas about how local planning authorities could identify parts of their local plan that may be most at odds with this, what may happen as a result, and things they could do to manage this (to follow).  We developed these ideas in consultation with a selection of local planning authorities.

We’ve worked with the Planning Inspectorate on this and it builds on pilot work done by the Inspectorate. The checklist is intended to provide a constructive starting point for any assessment of how the Framework impacts on plan preparation and is an important element of the support service referred to in paragraph 217 of Annex 1 to the National Planning Policy Framework

What will happen to this document in the future?

3 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

It will be reviewed in the light of feedback from local planning authorities that have used it and other stakeholders and updated again as necessary later in 2012.

If you have any feedback please send it to PAS at:

Email: [email protected]

Disclaimer

This is a PAS document and has not been endorsed by the Department for Communities and Local Government. We are positive that if you go through this exercise you will be able to make a judgment, with confidence, about how your plan relates to the requirements of the NPPF. It will also give you some indication of the sort of actions you may wish to pursue if you need to move towards alignment with the NPPF in any of the policy areas.

1A: Achieving sustainable development

The presumption in favour of sustainable development and core planning principles (para 6-17)

What NPPF expects local plans to Questions to help understand Does your local plan address this How significant are any include to deliver its objectives whether your local plan includes issue and meet the NPPF’s differences? what NPPF expects expectations? Do they affect your overall strategy?

Policies in local plans should follow (1) Does the plan positively seek (1). Since its inception, the Tamworth (1) There are no significant the approach of the presumption in opportunities to meet the Local Plan has positively explored all differences between the content of favour of sustainable development development needs of the area? the opportunities to meet the the NPPF and the content of the and guide how it should be applied development needs of the area. Local Plan policies or its supporting locally (15). evidence base. At the outset of the formulation of the Tamworth 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 or 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 Tamworth Local Plan has set to determine the maximum levels of housing/employment growth for the area, which are the most appropriate and sustainable (i.e. via weighing up social, economic and environmental considerations of the options, simultaneously).

A large level of evidence (i.e. SHLAA, SHMAA, EMLR, etc) was collected to identify the economic, social and environmental (e.g. scale and type of housing/employment requirement) needs of the area and how they could be addressed, within the given constraints.

The council has also worked with a large number of stakeholders; such as local communities, neighbouring authorities and infrastructure providers to identify and address cross boundary issues (i.e. transport, housing, employment, and environment) throughout the formulation of the plan. For example, it was clearly acknowledged that the council will not be able to meet its housing needs within its area and worked with the Neighbouring Authorities to reach an agreement that a proportion of Tamworth’s (1000 dwellings) housing needs will be met within their areas (via an agreed Memorandum of understanding). In addition, this was demonstrated in a number of studies that were jointly commissioned with Neighbouring Authorities (i.e. Green Belt Review, Southern Staffordshire Housing Needs Study, etc).

(2) Does the plan meet objectively (2) Throughout the formulation of the (2) There are no significant assessed needs, with sufficient Local Plan, a large level of evidence differences between the content of flexibility to adapt to rapid change, has been collected or updated to the NPPF and the content of the (subject to the caveats set out in objectively identify the economic, Local Plan policies or its supporting para14)? social environmental needs of the evidence base. area and the most sustainable way of addressing them.

The Local Plan sets out what development is likely to be delivered. The outcome of the policies will be regularly monitored and contingency plans will be implemented, if necessary. There is a commitment within the Tamworth Local Plan to ensure consistency with the National Planning Policy Framework. The Local Plan has tried to include sufficient flexibility into the policies. However, the unique characteristics of the Borough affect the extent to which the plan can be flexible, in terms of limiting the extent of any realistic alternatives. All the alternatives have been considered through the SA/SEA process. It has incorporated measures such as: > Allowing applicants to demonstrate whether their proposals will be viable after any section 106 /CIL contributions. >The density policy is applicable in broad locations rather than being specific to places. 3 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

> Allowing retail and leisure development within an out of town centre location, providing the applicant is able to demonstrates compliance with a number of perquisites are met (i.e. situated in a sustainable location, compliance with a sequential test, etc) > Allows B use classes to be used for alternative uses, providing a proposal meets the criterion. > The affordable housing and housing type policy will be applied flexible to ensure viability of a scheme and reflect the changing housing requirements of the area. The Local Plan does not include a phasing policy due to severe development constraints facing the area(i.e. environmental designations, no viable alternatives for delivering strategic development within the tight borough boundary) and to maximize the delivery of housing, not withstanding land outside the borough boundary. The memorandum of understanding that has been agreed between Tamworth and the Neighbouring Authorities, in relation to the delivery of housing delivery ensures a proportion of the Tamworth’s housing needs are met within the neighbouring areas and demonstrates flexibility. This is also ensures a maximum flexibility in policies, which is a reflection of the 4 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

governments planning agenda set out in the NPPF. (I.e. sustainable economic growth, sufficient flexibility, etc).

(3) Do you have a policy or policies (3) The introduction of the Local Plan (3) There are no significant which reflect the principles of the sets out the approach the council will differences between the content of presumption in favour of sustainable take to reflect the NPPF’s the NPPF and the content of the development? A model policy is presumption in favour of sustainable Local Plan policies or its supporting provided on the Planning Portal in the development. evidence base. Local Plans section, as a suggestion (but this isn't prescriptive). A Sustainability Appraisal has been undertaken throughout the formulation of the Local Plan, to assess the plans economic, social and environmental impacts. The Local Plan policies have been amended to minimize or eliminate any potential adverse impacts, where necessary.

The Local Plan includes a large range of policies that promote measures to encourage the sustainable development of the area. The Local Plan policies promote the three facets of sustainable development, when applied collectively to a potential scheme and can also help resolve any potential conflicts between them. The NPPF sets out a set of 12 core land-use principles which should underpin plan-making (and decision- making) (17)

1B: Delivering sustainable development

1. Building a strong, competitive economy (paras 18-22)

Set out a clear economic vision for (4) Is there an up to date assessment (4) To support the content and the (4) There are no significant the area which positively and of the deliverability of allocated implementation of the Local Plan, an differences between the content of proactively encourages sustainable employment sites, to meet local Employment Land Review has been the NPPF and the content of the economic growth (21). needs, to justify their long-term recently undertaken to assess the Local Plan policies or its supporting protection (taking into account that suitability, availability and supply of evidence base. LPAs should avoid the long term employment sites. protection of sites allocated for employment use where there is no Overall, this concluded that none of reasonable prospect of an allocated the employment areas are performing site being used for that purpose) poorly and discussions with letting para (22)? agents indicated that there was demand for the units. It also recommended that the strategic network of employment areas needed to be protected for employment use, in order to help fulfil the economic potential of the area.

It should be emphasized that the assessment of the deliverability of employment sites is also supported by a number of other studies such as the Tamworth Town Centre and Retail Study (2011/12), Office Background Paper (2009), Local and Neighbourhood centre health check Employment Land Study (2008). The

studies helped assess the need for different types of employment uses that may be required in the area.

2. Ensuring the vitality of town centres (paras 23-27)

Set out policies for the management (5) Have you undertaken an (5/6) The Local Plans Spatial (5/6) There are no significant and growth of centers over the plan assessment of the need to expand Strategy is aiming to promote the differences between the content of period (23). your town centre, considering the vitality / viability of the town centre the NPPF and the content of the needs of town centre uses? through encouraging its expansion Local Plan policies or its supporting and regeneration. It also seeks to evidence base. (6)Have you identified primary and enhance the role Local and secondary shopping frontages? Neighbourhood centres play in addressing local needs.

The Tamworth Town Centre and retail Study (2011 & 2012) has assessed the qualitative/quantitative need for both comparison and convenience retail goods, as well as whether this need is addressed by the existing retailers and whether there is a sufficient capacity for any additional floor space during the life of the plan.

This study helped identify the primary and secondary frontages within the town centre. It concluded that there was a capacity for additional 20,000 SQM (Gross) of comparison goods floor space and 1,600 SQM (Gross) goods floor space between 2021 -28.

The study also set out a hierarchy for retail and leisure development and identified a number of Local and Neighbourhood centres that will seek to address local needs and complement the town centre.

A number of sites have been identified to meet the identified need for additional Town Centre uses.

The strategy for the town centre was also supported by a number of other studies, such as the Town centre Linkages project, Town Centre Health Check.

3. Supporting a prosperous rural economy (para 28)

Policies should support economic Do your policies align with the Not applicable Not applicable growth in rural areas in order to objectives of para 28? create jobs and prosperity by taking a positive approach to sustainable new development (28).

4. Promoting sustainable transport (paras 29-41)

What NPPF expects local plans to Questions to help understand Does your local plan address this How significant are any include to deliver its objectives whether your local plan includes issue and meet the NPPF’s differences? what NPPF expects expectations? Do they affect your overall strategy? Policies that facilitate sustainable The Tamworth Local Plan is aiming to development but also contribute to reduce high levels of car usage within wider sustainability and health the borough through promoting more objectives (29). sustainable means of transport (such as cycling, walking and public Different policies and measures will transport). This has the potential of be required in different communities improve the health and well being of and opportunities to maximize the local population. sustainable transport solutions will vary from urban to rural areas (29). Chapter 7 of the Local Plan focuses on all the specific measures that could be implemented to encourage the use of sustainable modes of transport. For example, the Ventura – Town Centre Transport Package aims to improve the walking, cycling and public transport links between the two locations (i.e. removing barriers to pedestrian/cycling access), which includes public realm improvements. The plan includes proposals to improve the public realm around the two main railway stations and increasing the frequency of services, as well as improving bus facilities and services.

Further, the policies in this section require major developments to 11 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

undertake a Transport Assessment and submit a Travel Plan, which will assess the impact of the development on the existing transport infrastructure. This will help ensure that all the necessary place specific measures are incorporated into a potential proposal to reduce congestion and promote more sustainable modes of transport.

Policy SP9 encourages development in the most accessible locations in order to reduce the need to travel by car. This is complemented by other policies in the Local Plan which seek to encourage the development of retail, leisure facilities and employment within the Town Centre, Local and Neighbourhood centers.

Finally, a Place making SPD will be produced to set out place specific measures such as design and location of cycling facilities, design of the streets and improving safety of cyclists and pedestrians.

(6) If local (car parking) standards (6) Local parking standards have (6) There are no significant have been prepared, are they been prepared. The parking differences between the content of justified and necessary? (39) standards are necessary due to a the NPPF and the content of the (The cancellation of PPG13 removes number of factors such as; a scarcity Local Plan policies or its supporting the maximum standards for major of developable land in the area and evidence base non-residential development set out the importance to ensure the existing in Annex D. PPS4 allowed for non- land is efficiently used. residential standards to be set locally with Annex D being the default

position. There is no longer a requirement to set non-residential parking standards as a maximum but that does not preclude lpas from doing so if justified by local circumstances).

(7) Has it taken into account how this (7) This has taken into consideration (7) There are no significant relates to other policies set out other policies in the NPPF. differences between the content of elsewhere in the Framework, the NPPF and the content of the particularly in rural areas? (34). Local Plan policies or its supporting evidence base

(8) Have you worked with adjoining (8) The borough of Tamworth located (8) There are no significant authorities and transport providers on at the heart of a motorway network differences between the content of the provision of viable infrastructure? (M42/6, A5) and has good public the NPPF and the content of the transport links with the wider area. It Local Plan policies or its supporting also strong travel to work area evidence base. patterns with neighbouring authorities and the wider West Midlands region. The council has worked with Neighbouring Authorities, the County Council and infrastructure providers to enhance these links (i.e. Frequency of Trains, connections at Wilnecote Station, Drayton Manor), particularly to the A5 corridor which are required to ensure safe ease of movement and facilitate growth.

Also work was undertaken in relation to the A5 corridor. It was seeking to promote a joint up approach between different stakeholders to address capacity of A5 and environmental 13 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

issues (i.e. via Gailey, Staffordshire – Towcester).

5. Supporting high quality communications infrastructure (paras 42-46) There are no new or significantly different requirements for the policy content of local plans in this section of the NPPF.

6. Delivering a wide choice of high quality homes (paras 47-55)

Identify and maintain a rolling supply (9) What is your record of housing (9) An assessment of housing (9) There are no significant of specific deliverable sites sufficient delivery? delivery has recently been differences that affect the Tamworth to provide five years’ worth of undertaken, over a 15 year period Local Plans overall strategy. housing against their housing Have you identified: (i.e. financial year 1996/97 -2011/12). requirements; this should include an a) five years or more supply of It demonstrated that Tamworth has a additional buffer of 5% or 20% specific deliverable sites; good record of persistently delivering (moved forward from later in the plan b) an additional buffer of 5% (moved its housing requirement on average period) to ensure choice and forward from later in the plan period), over this period and since 2006 competition in the market for land or against the requirements set out in (47). c) If there has been a record of the WMRSS: Phase 2 Revision persistent under delivery have you preferred Option (Housing identified a buffer of 20% (moved Background Paper 2012). forward from later in the plan period)? [Para 47]. To support the Tamworth Local Plan’s housing strategy the existing SHLAA has been updated (October 2012). This has been used as the basis for identifying and demonstrating that the council has maintained a five year supply of deliverable housing sites within the area.

The SHLAA demonstrated that the sites identified in it are capable of delivering 1386 dwellings, which in comparison to the Local Plan annual housing requirement target of 205 is the equivalent of 6.76 years supply of deliverable housing sites (i.e. 1386 / 205).

Further the SHLAA (October 2012 Update) also demonstrates that the council has identified a sufficient number of housing sites to provide a 5 % buffer (1076 dwellings) and 20% buffer (1230 dwellings) of deliverable sites

(10) The five year supply of (10) Does this element of housing developable sites does not include (10) There are no significant supply include windfall sites; if so, to any windfall sites. differences between the content of what extent is there ‘compelling the NPPF and the content of the evidence’ to justify their inclusion Local Plan policies or its supporting (48)? evidence base.

Illustrate the expected rate of housing (11) To what extent does the removal (11) The removal of the national and (11) There are no significant delivery through a trajectory and set of national and regional Brownfield regional brownfield targets has not differences that affect the overall out a housing implementation targets have an impact on housing had a major impact on the Tamworth. strategy. strategy describing how a five year land supply? This is due to the fact that supply will be maintained (47). opportunities for major brownfield development have been explored and there is now limited scope within the area.

Further more, there is no locally set brownfield target. The council seeks to adopt a flexible approach to

promoting the growth of the Borough by encouraging the redevelopment of the remaining brownfield sites, whilst simultaneously encouraging the delivery of the sustainable urban neighbourhood at Anker Valley which will address a significant proportion of housing needs of the Borough.

At the same it should be emphasized that the revised national guidelines no longer consider garden development as brownfield development.

Plan for a mix of housing based on (12) Does the plan include policies (12) Section 5 of the Local Plan (12) There are no significant current and future demographic and requiring affordable housing? includes a policy for the provision of differences that affect the overall market trends, and needs of different affordable housing. strategy. groups (50), and caters for housing demand and the scale of housing (13) Do these need to be reviewed in (13) The affordable housing policy (13) There are no significant supply to meet this demand (Para the light of removal of the national does not need to be reviewed in light differences that affect the overall 159) minimum threshold? of the removal of the national strategy. minimum threshold because an Affordable Housing Viability and Policy Study has been undertaken to establish the correct targets and thresholds. The policy was also supported by the Strategic Housing Land Availability Assessment (2011) and a Strategic Housing Market Assessment.

(14) In 2007, the WMRSS set a (14) Is your evidence for housing housing requirement of 2900 provision based on up to date, dwellings for the area. It clearly (14) There are no significant 16 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

objectively assessed needs acknowledged that Tamworth would differences that affect the overall not be able to meet its needs within strategy. its own boundary and a proportion of the need will be met within the Neighbouring areas boundary. The evidence base for the Local Plan has established the need for the Borough over the plan period to be 5,500. Through working co- operatively with neighbouring authorities part of this need (1,000) will be delivered in those areas. The Local Plan sets a target of 4,500 dwellings to be delivered over the plan period. A Memorandum of Understanding between Lichfield, North Warwickshire and Tamworth local authorities agrees that 1,000 dwellings of Tamworth’s housing need will be met in the neighbouring areas. In rural areas be responsive to local (15) Have you considered whether Not Applicable Not Applicable circumstances and plan housing your plan needs a policy which development to reflect local needs, allows some market housing to particularly for affordable housing, facilitate the provision of significant including through rural exception additional affordable housing to meet sites where appropriate (54). local needs?

(16) Have you considered the case Not Applicable Not Applicable for setting out policies to resist inappropriate development of residential gardens? (This is discretionary)(para 53)

In rural areas housing should be (17) Examples of special Not Applicable Not Applicable located where it will enhance or circumstances to allow new isolated maintain the vitality of rural homes listed at para 55 (note, communities. previous requirement about requiring economic use first has gone).

7. Requiring good design (paras 56-68)

There are no new or significantly different requirements for the policy content of local plans in this section of the NPPF.

8. Promoting healthy communities (paras 69-78)

Policies should plan positively for the (18) Does the plan include a policy or (18) The Local Plan includes policies (18) The content of the Tamworth provision and use of shared space, policies addressing community for increasing the provision and Local Plan is generally consistent community facilities and other local facilities and local services? protection of local community with the requirements of the NPPF. services (70). facilities and local services. Policy CP16 seeks to deliver a network of community facilities in accessible locations across the borough. It also seeks to encourage the dual use of a site and seeks to protect existing education and health facilities and replace the loss of any existing facilities. This is supported by other policies in the Local Plan such as SP1: Spatial Strategy, SP3: Supporting Investment in local and CP1: Hierarchy of Centres also seeks to protect and increase the provision of local services and community facilities in the most accessible locations.

It should be emphasized that the need for the provision of services and facilities is supported by written representations and discussions with stakeholders (i.e. service providers, infrastructure delivery providers), whose requirements were taken into 19 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

consideration during the formulation of the Local Plan’s Infrastructure Delivery Plan.

(19) To what extent do policies plan (19) The Tamworth Local Plan seeks (19) There are no significant positively for the provision and to promote the sustainable differences that affect the overall integration of community facilities development of the borough. The strategy. and other local services to enhance spatial strategy seeks to positively the sustainability of communities and promote a more self contained town residential environments; safeguard through diverting development of against the unnecessary loss of housing, retail, employment and local valued facilities and services; ensure services/community facilities within that established shops, facilities and close proximity to each other and in services are able to develop and the most accessible locations (i.e. modernize; and ensure that housing town centre, local and is developed in suitable locations Neighbourhood centres). It aims to which offer a range of community protect the vitality and viability of the facilities and good access to key existing centres through restricting services and infrastructure? retail and leisure development outside them and preventing alternative change of uses (i.e. residential).

The policies also seek to increase the provision of and safeguard cultural facilities, sports and recreational facilities, and open spaces. Criteria based policy has been included for assessing application for alternative uses to local services and community facilities.

The sustainable urban neighbourhood at Anker Valley aims

to ensure that all the supporting infrastructure for housing growth is delivered to support the sustainable deliver of the site (i.e. a new centre, open space, a new school, etc).

Enable local communities, through (20) Do you have a policy which (20) The Tamworth Local Plan does (20)There is a potential difference local and plans, to identify special would enable the protection of Local not include any policy for allowing between the Local Plan and the protection green areas of particular Green Spaces and manage any Local communities to identify and NPPF. But it is not significant and importance to them – ‘Local Green development within it in a manner designate a site as Local Green does not affect the overall strategy. Space’ (76-78). consistent with policy for Green Space that needs protection through Belts? (Local Green Spaces should the Local Plan. This is due to the fact only be designated when a plan is that the area is largely urban and prepared or reviewed, and be there are limited opportunities for capable of enduring beyond the end additional Local Green Space of the plan period. The designation designation because areas outside should only be used when it accords the urban area fall within the Green with the criteria in Para 77). Belt or are areas at risk of flooding or fall within other environmental designations. Through policies SP8, CP8, CP9 many areas of the Borough have been allocated and designated as Countryside, Open Space, Open Space (parks), playing pitches and sports fields and proposed new parks.

9. Protecting Green Belt land (paras 79-92)

The general extent of Green Belts (21) If you are including Green Belt (21) To support the Tamworth Local (21). There is no major difference that across the country is already policies in your plan, do they Plan’s spatial strategy, a Green Belt will affect the overall strategy. established. New Green Belts should accurately reflect the NPPF policy? review has been undertaken to only be established in exceptional establish the Green Belt boundary for circumstances (82) For example: the area. This was undertaken in accordance with the criteria set out Local planning authorities with Green Lpas should plan positively to Para 82 & 85 of the NPPF. The Belts in their area should establish enhance the beneficial use of the Green Belt defined in the Local Plan Green Belt boundaries in their Local Green Belt. Beneficial uses are listed effectively replaces the Green Belt Plans which set the framework for in para 81. PPG2 set out that ‘Green set out in the WMRSS. New Green Green Belt and settlement policy Belts have a positive role to play in Belt has been identified in the South (83). fulfilling objectives. Para 1.6 of West of the Borough running PPG2 set out the objectives – some alongside the Tame River. Other Boundaries should be set using of these have been rephrased/ minor amendments have been made ‘physical features likely to be amended and ‘to retain land in to align the Green Belt to clear and permanent’ amongst other things (85) agricultural, forestry and related uses’ defensible physical features. has been omitted. The Tamworth Local Plan includes a Ensure consistency with the Local spatial policy to protect, enhance the Plan strategy for meeting identified Green Belt and other environmental requirements for sustainable assets in the area. The green belt development (85). does not include any major settlements and the NPPF guidelines along with policies in the Local Plan and a future Place making SPD will be used to determine planning applications in it.

(22) Does it allow for the extension or (22) The Local Plan places a high (22) There is no major difference that alteration of a building, provided that level of emphasis on the importance will affect the overall strategy. it does not result in disproportionate of protecting the character/openness Guidance within the NPPF will that additions over and above the size of of the Green Belt. The NPPF inappropriate overdevelopment is the original building? (89). PPG2 guidelines along with policies in the discouraged in the Green Belt. previously referred to dwelling. Local Plan and future place making Original building is defined in the SPD will be used to determine Glossary. applications.

(23) Does it allow for the replacement (23) See 22 above. (23) See 22 above. of a building, provided the new building is in the same use and not materially larger than the one it replaces? (89) PPG2 did not have a separate bullet point – replacement related to dwellings rather than buildings. (24) Does it allow for limited infilling (24) See 22 above. (24) See 22 above. or the partial or complete redevelopment of previously developed sites (brownfield land) whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development? (89) (PPG2 referred to ‘major existing developed sites’)

Change from ‘Park and Ride’ in PPG2 to local transport infrastructure and the inclusion of ‘development brought forward under a Community Right to Build Order’ in relation to

other forms of development that are not inappropriate in the Green Belt provided they preserve the openness of the Green Belt and do not conflict with the purposes of including land in Green Belt. (90).

10. Meeting the challenge of climate change flooding and coastal change (paras 93-108) What NPPF expects local plans to Questions to help understand Does your local plan address this How significant are any include to deliver its objectives whether your local plan includes issue and meet the NPPF’s differences? Do they affect your what NPPF expects expectations? overall strategy?

Adopt proactive strategies to (25) Have you planned new (25) A Sustainability Appraisal (25) There is no major difference that mitigate and adapt to climate development in locations and ways (incorporating an SEA) has been will affect the overall strategy. change taking full account of flood which reduce greenhouse gas undertaken throughout the risk, coastal change and water emissions? formulation of the Tamworth Local supply and demand considerations Plan. This has assessed the potential (94). environmental impacts of policies and its recommendations have aimed to ensure that new development is directed to the most sustainable locations and the measures that need to be implemented to ensure that any adverse impacts are minimized or eliminated. The SA recommendations have been incorporated into the plan.

The Sustainability Appraisal (SA) has been undertaken throughout the production of the development plan. It shows how the different spatial options and policies perform against the SA objectives and how it has influenced the content of the development plan throughout the process.

The Initial Sustainability Appraisal scored each of the spatial options against the 21 sustainability appraisal objectives in order to identify the 26 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

main environmental, social and economic implications of each option. The scores for the options are outlined below: (SA,2008)

Options Initial Sustainability Appraisal Score Option 1: Urban containment and regeneration Option 2: Urban containment and Anker Valley intensification Option 3: Greenfield urban extensions Option 4: Greenfield and Green Belt urban extensions 6

The appraisal concluded that Option 1 was the most sustainable, followed by Options 2, 4 and 3. The positive features of Option 1 were the minimal urban expansion involved and the ability to use existing services and facilities. Conversely, Options 3 and 4 in particular involved more Greenfield land take, were located further away from the town centre and required more additional infrastructure provision. Despite Option one scoring the highest through the appraisal process, it was expected that the final spatial option would involve elements of a number of the options (SA, 2009). Also it should be emphasized that there was no robust credible justification for an Green Belt Urban Extension (i.e. Option 4)

The council’s Proposed Spatial Strategy was the result of considering the responses to the Option report consultation, understanding of the emerging evidence base and the Initial Sustainability Appraisal. It contained an updated Spatial Portrait, Vision and Strategic Objectives, a suite of core policies and one development management policy. The appraisal of the overall spatial strategy and scored it to enable comparison with the four options from the Issues and Options report. (SA, 2009)

The overall spatial strategy focused on the town centre and regeneration with housing need being met in the short to medium term within the urban area and a sustainable urban extension at the Anker Valley; conforming in the main with Option 1 and elements of options 2 and 3. In the longer term, it identified the need for sustainable sites outside the borough boundary to be considered. Employment needs would be met through redevelopment of existing sites and Greenfield extensions along the A5 corridor. In addition to proposing strategic allocations at the Anker Valley, Gungate Precinct and Middle Entry, the strategy identified a site for a community leisure centre in the east of the Borough. In allocating

sites to meet Tamworth’s needs, the Council aimed to protect as far as possible historic and natural assets and the green space network. (SA, 2012)

The overall spatial strategy scored 12, which is the same score achieved by Option 1 from the Issues and Options. It scored positively on the majority of the sustainability objectives and only recorded a negative score on the factors relating to protection of historic and biodiversity assets, green space network and flood risk. This owes much to Tamworth’s unique position of being a small urban authority with a limited supply of land for development, for which there will be competing land uses. (SA, 2012).

The sustainability appraisal considered the impacts of the all the proposed policies (exception of H3 due to further work). Whilst some policies only had one option where there were realistic alternative options, these were also considered against the sustainability criteria. The appraisal framework revealed that Option 1 –Urban containment and regeneration generally scored highest. However, the appraisal showed that the most sustainable option is not always the most deliverable because of the unique

situation that Tamworth finds itself in regarding a shortage of land within a tight administrative boundary. There is competition for land from a number of uses, which puts pressure on green spaces and sensitive designations. It is important to view each policy as part of the overall strategy to achieve the Tamworth Local Plan spatial objectives and not in isolation.

Each housing policy was assessed alongside one realistic alternative option. The total scores for each policy revealed that Option 1 (representing the Council’s preferred policy approach) scored highest in every instance, which provides a sound endorsement that the preferred policy approach is the most appropriate for Tamworth.

The Sustainability appraisal revealed that the preferred policy option relying on Greenfield locations; most notably Anker Valley to accommodate future housing growth generated a neutral scoring on the basis that it did not achieve the objective of making the most efficient use of land.

In the context of opportunities for future expansion of the town being constrained by a tight administrative boundary and environmental constraints (i.e. the flood plain, the

Green Belt, etc) , the preferred option took into account the findings of the Tamworth Future Development and Infrastructure Study (2009), carried out jointly with Lichfield District and North Warwickshire Borough Councils. This examined options for delivering future housing growth outside of Tamworth’s borough boundary and assessed the suitability of a range of broad locations which included undertaking a sustainability appraisal.

Two of the options identified were within the Borough boundary, the remainders were outside. It was considered that the Anker Valley option was the most sustainable option within the Borough boundary to deliver the Spatial Objectives for the town.

Of the other options identified in the Joint Study, land to the East of Tamworth Urban area and west of the M42 was considered to be the most sustainable location to meet Tamworth’s needs. Land east of the M42 was also considered to have sustainability benefits as was land at Mile Oak and land north of the Anker Valley which all scored closely.

To overcome the Sustainability Appraisal’s neutral scoring; the Anker Valley policy has been revised to

incorporate mitigation measures to increase the overall sustainability benefits of these locations. These include improving the linkages and accessibility; particularly through walking and cycling and public transport links to and from the Anker Valley Sustainable Urban Extension proposal, together with providing a neighbourhood centre with community infrastructure and the provision of biodiversity enhancing measures. It is also recognized that this represents the only strategic housing site; the size of which represents the only opportunity to potentially deliver a significant number of affordable housing and range of Units to meet the needs of all the communities in Tamworth.

When the sustainability benefits in terms of supporting town centre regeneration (as a result of its location close to Tamworth Town Centre and supported by the proposed linkages improvements) are taken into account it is deemed that the proposal is able to mitigate against the sustainability disadvantages identified associated with Greenfield development. (SA 2012)

Overall, the SA process and all the other evidence that has been

collected have ensured that the scale of the proposed growth, type and location of it will help reduce greenhouse emissions.

The local plan has also taken into consideration the finding of other evidences such as Staffordshire Biodiversity Action Plan, Cannock Chase Appropriate Assessment and representations of environmental/ conservation groups.

(26) Policies CP14 and SP9 of the (26)Does your plan actively support Tamworth Local Plan actively (26) There is no major difference that energy efficiency improvements to supports energy efficiency new will affect the overall strategy. existing buildings? buildings, as well as within existing buildings.

(27) The Tamworth Local Plan does (27) When setting any local not include any local requirements for (27) There is no major difference that requirement for a building’s building sustainability and is will affect the overall strategy. sustainability, have you done so in a considering using the existing way that is consistent with the national standards. Government’s zero carbon buildings policy and adopt nationally described standards? (95) Help increase the use and supply of (28) Do you have a positive strategy (28)The Tamworth Local Plan has (28) There is no major difference that renewable and low carbon energy to promote energy from renewable included a positive strategy for will affect the overall strategy. (97). and low carbon sources? promoting energy from low carbon/renewable sources.

(29) Have you considered identifying (29) The Staffordshire Countywide (29) The content of the Tamworth suitable areas for renewable and low Renewable/Low carbon energy study Local Plan is generally consistent carbon energy sources, and was undertaken across the sub with the requirements of the NPPF. supporting infrastructure, where this region. This estimated that the would help secure the development 33 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

of such sources (see also NPPF authority is only capable of meeting a footnote 17) small percentage of its energy demand through renewable sources by 2020. Opportunities for renewable or low carbon initiatives will be explored through the development management process and the master planning of strategic sites.

11. Conserving and enhancing the natural environment (paras 109-125)

Planning policies should minimise (30) If you have identified Nature (30) Although Policy CP12 supports (30) The content of the Tamworth impacts on biodiversity and Improvement Areas, have you habitat restoration proposals, no Local Plan is generally consistent geodiversity (para 117). considered specifying the types of nature improvement areas have been with the requirements of the NPPF. development that may be appropriate identified in the Local Plan. The Planning policies should plan for in these areas (para 117)? Policy also identifies sites of biodiversity at a landscape-scale biodiversity importance which have across local authority boundaries been classified under different (117). environmental designations (i.e. statutory sites) and also sets out the circumstances under which development may be permitted.

12. Conserving and enhancing the historic environment (paras 126 – 141)

There are no new or significantly different requirements for the policy content of local plans in this section of the NPPF.

13. Facilitating the sustainable use of minerals (paras 142-149)

It is important that there is a (31) Does the plan have policies for Not applicable Not applicable sufficient supply of material to the selection of sites for future peat provide the infrastructure, buildings, extraction? (143) (NPPF removes the energy and goods that the country requirement to have a criteria based needs. However, since minerals are policy as peat extraction is not a finite natural resource, and can supported nationally over the longer only be worked where they are term). found, it is important to make best use of them to secure their long- term conservation (142).

Planning policy for traveller sites

The CLG ‘Planning policy for traveller sites’ was published in 23 March 2012 and came into effect on 27 March 2012. Circular 01/06: Planning for Gypsy and Traveller Caravan Sites and Circular 04/07: Planning for Travelling Showpeople have been cancelled. ‘Planning policy for travellers sites’ should be read in conjunction with the National Planning Policy Framework, including the implementation policies of that document.

The government’s aim in relation to planning for traveller sites is:

‘To ensure fair and equal treatment for travellers, in a way that facilitates the traditional and nomadic life of travellers which respecting the interests of the settled community’.

Government’s aims in respect of traveller sites are:

 That local planning authorities (lpas) make their own assessment of need for the purposes of planning  That lpas work collaboratively, develop fair and effective strategies to meet need through the identification of land for sites  Plan for sites over a reasonable timescale  Plan-making should protect green Belt land from inappropriate development  Promote more private traveller site provision whilst recognising that there will always be those travellers who cannot provide their own sites  Aim to reduce the number of unauthorised developments and encampments and make enforcement more effective.

In addition local planning authorities should:

 Include fair, realistic and inclusive policies  Increase the number of traveller sites in appropriate locations with planning permission, to address under provision and maintain an appropriate level of supply  Reduce tensions between settled and traveller communities in plan-making and decision-taking  Enable provision of suitable accommodation from which travellers can access education, health, welfare and employment infrastructure  Have due regard to protection of local amenity and local environment

Policy A: Using evidence to plan positively and manage development (para 6)

What the policy for traveller sites Questions to help understand Does your local plan meet the How significant are any expects local plans to include to whether your local plan includes policy’s expectations? differences? deliver its objectives what the policy expects Do they affect your overall strategy?

Early and effective community (32) Has your evidence been (32) A sub regional Gypsy and (32) The content of the Tamworth engagement with both settled and developed having undertaken early Traveller Accommodation Local Plan is generally consistent traveller communities. and effective engagement including assessment was undertaken by with the requirements of the NPPF. discussing travellers accommodation Research Team at Birmingham needs with travellers themselves, University in 2008. The Gypsy and their representative bodies and local Travellers communities and support groups? representative bodies were consulted to assess their accommodation needs across the sub region.

This study was the basis for formulating a policy for addressing the needs of the Gypsy and Traveller communities, who have been consulted throughout the various stages of the formulation of the Local Plan.

Following the publication of the NPPF and the change in the national policy requirement, the council along with Lichfield District Council have commissioned the University of Salford to update the GTAA.

Co-operate with travellers, their (33) Can you demonstrate that you (33/34) A sub regional GTAA was (33/34) The content of the Tamworth representative bodies and local have a clear understanding of the commissioned and completed in Local Plan is generally consistent support groups, other local needs of the traveller community over 2008. with the requirements of the NPPF. authorities and relevant interest the lifespan of your development groups to prepare and maintain an plan? up-to-date understanding of likely (34) Have you worked collaboratively (35) The Gypsy and Traveller (35) The content of the Tamworth permanent and transit with neighbouring local planning Accommodation Assessment (2008) Local Plan is generally consistent accommodation needs of their authorities? and its update will provide a robust with the requirements of the NPPF. areas. evidence base to inform the plan and make planning decisions. (35) Have you used a robust evidence base to establish accommodation needs to inform the preparation of your local plan and make planning decisions?

Policy B: Planning for traveler sites (paras 7-11)

Set pitch targets for gypsies and (36) Have you identified, and do you (36) A potential supply of sites for (36) See response in 32 above travellers and plot targets for update annually, a supply of specific, Gypsy and Traveller’s will be drawn travelling showpeople which deliverable sites sufficient to provide from the SHLAA on an annual basis, address the likely permanent and 5 years worth of sites against locally to meet the local requirement over transit site accommodation needs of set targets? Have you identified a the plan period. travellers in your area, working supply of specific, developable sites collaboratively with neighbouring or broad locations for growth for lpas (8) years 6-10, and, where possible, for years 11-15. (9)

Consider the production of joint (37) Have you identified constraints (37) As part of the plan making (37) See response in 32 above development plans that set targets within your local area which prevent process, all the constraints (such as on a cross-authority basis, to you from allocating sufficient sites to accessibility to public transport or provide more flexibility in identifying meet likely future need? If so have local facilities, flood risk, green belt, a sites. you prepared a joint development tight administrative boundary) for plan or do you intend to do so? Is delivering housing and employment the reason for this clearly explained? in different parts of the area have been identified. These constraints would also apply to identifying and delivering Gypsy and Traveller community’s sites.

Throughout the plan making process, no sites have been brought forward to the Council to be considered as sites to meet the needs for the Gypsy and Traveller community. The lack 3 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

deliverable sites is a significant constraint. The Council will work with the Gypsy and Traveller community when potential sites become available, along with landowners and other stakeholders.

Relate the number of pitches and plots to the circumstances of the specific size and location of the site and the surrounding population size and density.

Protect local amenity and environment.

Set criteria to guide land supply (38) Has an up-to-date assessment (38) The 2008 GTAA is being (38) See response in 32 above. allocations where there is identified of the need for traveller sites been updated. need. carried out? If an unmet need has been demonstrated has a supply of specific, deliverable sites been identified based on the criteria you have set?

(39) Where there is no identified (39) Policy CP7: has been included in (39) See response in 32 above need, have criteria been included in the Tamworth Local Plan. This sets case applications nevertheless come out criteria by which applications for forward? Gypsy and Traveller sites will be assessed.

Ensure that traveller sites are (40) Have your policies been (40) Policy CP7 of the Tamworth (40) See response in 32 above sustainable economically, socially developed taking into account criteria Local Plan is generally consistent and environmentally. a-h of para 11 of the policy with criteria set out in Planning policy for Traveller sites’.

Policy C: Sites in rural areas and the countryside (para 12)

When assessing the suitability of sites in rural or semi-rural settings lpas should ensure that the scale of such sites do not dominate the nearest settled community?

Policy D: Rural exception sites (para 13)

If there is a lack of affordable land to (41) If you have a lack of affordable Not applicable Not applicable meet local traveller needs, lpas in land to meet local traveller needs in rural areas, where viable and your rural area have you used a rural practical, should consider allocating exception site policy, and if so, does and releasing sites solely for it make it clear that such sites shall affordable traveller’s sites. be used for affordable traveller sites in perpetuity?

Policy E: Traveller sites in Green Belt (paras 14-15)

Traveller sites (both permanent and (42) Have you made an exceptional (42) As part of the formulation of the (42) The content of the Tamworth temporary) in the Green Belt are limited alteration to the defined Green Tamworth Local Plan, a large level of Local Plan is generally consistent inappropriate development. Belt boundary to meet a specific, evidence (such as the Green Belt with the requirements of the NPPF. identified need for a traveller site? Review, the SHLAA, Tamworth Has this alteration been done through Future Development and the plan-making process and is it Infrastructure Study, Southern specifically allocated in the Staffordshire Housing Needs and development plan as a traveller site SHMAA update, Sustainability only Appraisal) have explored whether it is appropriate or sustainable for the Green Belt to accommodate any form of development.

They have concluded that the Green Belt is not suitable for any development due to constraints such as flood risk, environmental designations, and poor access to public transport or local facilities. It should be noted that the Sustainability Appraisal has concluded that the alternative sites outside the Green Belt are the most appropriate for accommodating the development needs of the area.

Policy F: Mixed planning use traveller sites (paras 16-18)

(43) Have you considered including (43) The GTAA is currently being (43)The content of the Tamworth travellers sites suitable for mixed updated. When this is completed, the Local Plan is generally consistent residential and business use (having council will work with stakeholders to with the requirements of the NPPF. regard to safety and amenity of the identify deliverable sites to address occupants and neighbouring the accommodation needs of gypsy residents)? and traveller community.

(44) If mixed sites are not practicable (44) See the above response (44) See above response. have you considered the scope for identifying separate sites for residential and for business purposes in close proximity to one another?

(45) Have you had regard to the need (45) The GTAA undertaken in 2008 (45) See above response that travelling showpeople have for indicated that there is no need for mixed-use yards to allow residential travelling show person yards in accommodation and space for Tamworth. storage of equipment? NB Mixed use should not be permitted on rural exception sites

Policy G: Major development projects (para 19)

(46) Do you have a major (46) No development proposal which requires the permanent or temporary relocation of a traveller site? If so has a site or sites suitable for the relocation of the community been identified (if the original site is authorised)?

Plan-making

Local Plans (paras 150-157)

What NPPF identifies in relation Questions to help understand Which parts of your local plan Does your local plan meet the to the development of local plans whether your local plan includes address this issue NPPF’s expectations? How what NPPF expects (reference and brief summary of significant are any differences? content, plus any other relevant evidence)

Each local planning authority should (47) Are you able to clearly justify the (47) The policies within the Tamworth (47) The content of the Tamworth produce a Local Plan for its area. use of additional DPDs if this is the Local Plan will be supported by a Local Plan is generally consistent Any additional DPDs should only be approach that you are pursuing? limited number of SPD’s. These with the requirements of the NPPF. used where clearly justified. SPDs include the Town Centre SPD, Place should be used where they help making SPD, Wilnecote applicants make successful Regeneration Corridor SPD and a applications/aid infrastructure Planning Obligations SPD. delivery/not be used to add unnecessarily to financial burdens This approach is justified by a on development (153) number of factors such as the need to promote the regeneration of Wilnecote and the Town centre, which are central to achieving the overall strategy of the Local Plan. This will also promote economic growth, as well as provide greater guidance to help applicants submit successful applications.

Whilst the infrastructure obligations SPD will provide a greater level of guidance in relation to what contributions are required, when, how to enable applicants to these factors into consideration when submitting 11 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

their applications. This will help aid infrastructure delivery.

Overall, the SPDs will assist the implementation of the plan and will provide more detailed guidance and help deliver the regeneration and growth of the town.

Local Plans should: (48) Have you objectively assessed (48) At the outset of the formulation (48) The content of the Tamworth  Plan positively development needs and planned for of the Local Plan, it was clear that the Local Plan is generally consistent (para 157) them? area is expected to experience high with the requirements of the NPPF. levels of growth and it would be There are no significant issues that difficult to meet all of the will impact the overall strategy. 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.

The assessment of Tamworth’s development needs are supported by a large level of evidence of evidence such as a SHLAA, SHMAA, ELR and consultation responses etc have been collected and analysed to objectively assess the development needs of the area, throughout the plan making process. Therefore, the Local Plan has set to determine the maximum levels of housing/employment growth to address the needs of the area in the

most appropriate and sustainable way (i.e. via weighing up social, economic and environmental considerations of the options, simultaneously).

(49) If you can’t meet them in your (49) The Council has worked closely (49) The content of the Tamworth area, have you co-operated with with the neighbouring authorities (as Local Plan is generally consistent others on meeting them elsewhere? well as other stakeholder such as with the requirements of the NPPF. (para 182) infrastructure providers, local There are no significant issues that communities) at the outset of the will impact the overall strategy. formulation of the plan to identify and address any cross boundary issues. They were consulted throughout the plan making processes and in some instances the evidence base was commissioned in conjunction with them. A summary of this is provided below: Housing In 2007, the WMRSS set a housing requirement of 2900 dwellings for the area. The Local Plan evidence base established a need for 5,500 over the plan period. However, it clearly acknowledged that Tamworth will not be able to meet its needs within its own boundary and a proportion of the need (1000 dwellings) will be met within the neighbouring areas. The council has continuously worked with the neighbouring authorities to reach an agreement that their Development Plans will allocate housing land to meet this need 13 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

An agreement has recently been reached between the neighbouring authorities and a Memorandum of understanding has been signed which outlines the duties of all parties in relation to delivering a proportion of Tamworth’s housing requirement in their area. (Para 5.15 of the Tamworth Local Plan) Transport The town is located at the heart of a motorway network (M42/6, A5) and has good public transport links with the wider area. It also strong travel to work patterns with neighbouring authorities and the wider West Midlands region. The Council have worked with neighbouring Authorities, County Council and infrastructure providers to enhance these links (i.e. Frequency of Trains, connections at Wilnecote Station, Drayton Manor) particularly to the A5 corridor which are required to ensure safe ease of movement and facilitate growth. Work was also undertaken in relation to the A5 corridor. It was seeking to promote a joint up approach between different stakeholders to address capacity of A5 and environmental issues (i.e. via Gailey, Staffordshire – Towcester). (See Paras 7.15 & 7.6 of the Tamworth Local Plan).

Environmental The Local Plan proposals could potentially impact on Cannock Chase SAC. Based upon the recommendations in Cannock Chase’s Local Plan evidence based documents, Local Plan Policy CP12 has included mitigations measures to offset any potential adverse impacts on this environmental designation. Employment A number of strategic broad locations for employment are located on the boundary of the area, it has been established through the Employment Land review that the employment needs of Tamworth can be met within the Borough. The council is part of the Greater Birmingham and Solihull Local Economic Partnership (LEP) and is also working with the Neighbouring Stoke on Trent and Staffordshire LEP. The council has worked with a large number of public/private sector organizations, to identify and address strategic issues facing the area and sub region (i.e. increasing economic growth, creating jobs, attracting new businesses and investment into the area.

Using a proportionate evidence base (paras 158-177) What NPPF identifies in relation Questions to help understand Which parts of your local plan Does your local plan meet the to the development of local plans whether your local plan includes address this issue NPPF’s expectations? How what NPPF expects (reference and brief summary of significant are any differences? content, plus any other relevant evidence) Defence, national security, counter-terrorism and resilience See para 163 Ensuring viability and (50) To what extent has your plan (50) A viability study has been (50)There does seem to be a small deliverability been assessed to ensure viability, undertaken on The Tamworth Local difference between the expectations taking into account the costs of any Plan, this takes into account the of the NPPF and Local Plan. The sites and scale of development requirements likely to be applied to requirements set out in policy: such identified in the plan should not be development, such as requirements as affordable housing. In addition to An updated viability study could be subject to such a scale of for affordable housing, standards, this an affordable housing viability undertaken to ensure that obligations and policy burdens that infrastructure contributions or other and policy study (2010) was obligations/other policy burdens do their ability to be developed viably is requirements? undertaken to ensure that the not impact the viability of potential threatened (173) threshold and targets are not schemes and ensure that unreasonable. developers/landowners will earn competitive rate of return.

(51) In so doing to what extent has it (51) The viability testing study agreed (51) Also the viability study will need taken into account the normal cost of notional residential and commercial to assess whether cumulative impact development and on-site mitigation development schemes in several of local standards/affordable housing and provide competitive returns to a localities within each district, and does not impact the overall willing land owner and willing undertook research, and carried out a deliverability of the plan. developer to enable the development range of development appraisals, to be deliverable (173)? and sensitivity analysis and testing.

For the residential schemes different scenario types were tested on brownfield and greenfield notational development sites with a mix of dwellings and affordable housing provision.

On the notional brownfield sites, an allowance has been made for dealing with land remediation/contamination costs, however the cost will vary considerably upon the extent and type of remediation, but the assessment is taken on an average allowance assuming that a portion of the strata will have to be removed and replaced with clean inert material.

The assessments have assumed a notional rate of return for the landowner, at 15% for commercial developments and 20% on residential developments.

(52) To what extent have the likely (52) The viability testing study agreed (52) See the responses above. cumulative impacts on development notional residential and commercial in your area of all existing and development schemes in several proposed local standards, localities within each district, and supplementary planning documents undertook research, and carried out a and policies that support the range of development appraisals, development plan, when added to and sensitivity analysis and testing. nationally required standards been This also took into account local and assessed to ensure that the national standards. As there are no cumulative impact of these standards adopted SPDs or other DPDs, these and policies do not put have not had to be factored into the 17 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

implementation of the development costs of development. plan at serious risk, and facilitate development throughout the economic cycle (174)?

Examining Local Plans (para 182)

What NPPF identifies in relation Questions to help understand Which parts of your local plan Does your local plan meet the to the development of local plans whether your local plan includes address this issue NPPF’s expectations? How what NPPF expects (reference and brief summary of significant are any differences? content, plus any other relevant evidence)

Authorities should submit a plan for Positively prepared The Tamworth Local Plan has been The Tamworth Local Plan meets the examination which it considers is positively prepared. NPPF’s expectation. sound, including being …. The Council has worked closely with the neighbouring authorities (as well as other stakeholder such as infrastructure providers, local communities) at the outset of the formulation of the plan to identify and address any cross boundary issues. They were consulted throughout the plan making processes and in some instances the evidence base was commissioned in conjunction with them. A summary of this is provided below:

Housing In 2007, the WMRSS set a housing requirement of 2900 dwellings for the area. The Local Plan evidence base established a need for 5,500 over the plan period. However, it clearly acknowledged that Tamworth will not be able to meet its needs within its own boundary and a proportion of the 19 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

need (1000 dwellings) will be met within the neighbouring areas. The council has continuously worked with the neighbouring authorities to reach an agreement that their Development Plans will allocate housing land to meet this need An agreement has recently been reached between the neighbouring authorities and a Memorandum of understanding has been signed which outlines the duties of all parties in relation to delivering a proportion of Tamworth’s housing requirement in their area. (Para 5.15 of the Tamworth Local Plan) Transport The town is located at the heart of a motorway network (M42/6, A5) and has good public transport links with the wider area. It also strong travel to work patterns with neighbouring authorities and the wider West Midlands region. The Council have worked with neighbouring Authorities, County Council and infrastructure providers to enhance these links (i.e. Frequency of Trains, connections at Wilnecote Station, Drayton Manor) particularly to the A5 corridor which are required to ensure safe ease of movement and facilitate growth. Work was also undertaken in relation

to the A5 corridor. It was seeking to promote a joint up approach between different stakeholders to address capacity of A5 and environmental issues (i.e. via Gailey, Staffordshire – Towcester). (See Paras 7.15 & 7.6 of the Tamworth Local Plan). Environmental The Local Plan proposals could potentially impact on Cannock Chase SAC. Based upon the recommendations in Cannock Chase’s Local Plan evidence based documents, Local Plan Policy CP12 has included mitigations measures to offset any potential adverse impacts on this environmental designation. Employment A number of strategic broad locations for employment are located on the boundary of the area, it has been established through the Employment Land review that the employment needs of Tamworth can be met within the Borough. The council is part of the Greater Birmingham and Solihull Local Economic Partnership (LEP) and is also working with the Neighbouring Stoke on Trent and Staffordshire LEP. The council has worked with a large number of public/private sector organizations, to identify and address strategic issues facing the area and sub region (i.e. increasing economic 21 Planning Advisory Service Local Plans and National Planning Policy Framework: LPA Self Assessment

growth, creating jobs, attracting new businesses and investment into the area. Refer to response to Q49 for further details.