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Anna Soubry MP 1 Matter 1 Anna Soubry MP Matter 1: The Duty to Co-operate and other Legal Requirements Q1. I am of the view that Nottingham City Council (a unitary authority) has been in the driving seat and Broxtowe has merely "gone with the flow". I am not aware of "constructive, active and ongoing engagement” with Ashfield or Newark and Sherwood District Councils. Q3. I have a number of concerns regarding public consultation: there has been a profound lack of consultation by Broxtowe Borough Council. I refer to my original submission regarding Paragraph 8, Legally Compliant, Community Consultation, points (a) to (d) inclusive. Q7. I do not believe that Broxtowe Borough Council’s Aligned Core Strategy is consistent with national policy in the NPPF and those sections that deal with Green Belt. Specifically, Paragraphs 79-92 (Protecting Green Belt land), Introduction Paragraph 2, Paragraph 14 and footnote 9. In particular, Paragraph 87 states, “As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.” I believe that there is sufficient evidence to contest the soundness of Broxtowe’s Aligned Core Strategy, as detailed in my answer to Matter 3 Question 1, and to contest that very special circumstances exist in this case. In addition, the plan is inconsistent with policy as stated by the Prime Minister, the Secretary of State for Communities and Local Government and the Parliamentary Under Secretary of State (Planning) as explained below. During Prime Minister’s Questions on 26 th June 2013, the Prime Minister stated that, “The rules about green belt have not changed. A local authority can change the green belt only by taking something out of the green belt and putting something back in, in consultation with local people.” (See Appendix 1) I therefore do not know why Broxtowe Borough Council is proposing development on Green Belt land and ahead of brownfield land. In a letter to me of 7 th August 2013, Nick Boles MP, Parliamentary Under Secretary of State (Planning), states, “Rest assured, the Government’s reforms will protect the Green Belt, promote responsible building and bring power in the planning process back to local communities.” (See Appendix 2) As detailed in my answers on Matter 3, I do not believe Broxtowe Borough Council’s Aligned Core Strategy protects the Green Belt and, as detailed my answer to question 3 above, nor do I believe the Core Strategy grants any power to local communities. Furthermore, in another letter to me of 19 th April 2013, the Parliamentary Under Secretary of State (Planning) states, “even where there is not an up-to-date Local Plan in place the presumption in favour of sustainable development would not apply where the impact of granting permission for development would significantly and demonstrably outweigh the benefits, or where specific policies in the Framework, such as the Green Belt, indicate that development should be restricted. Policy is therefore clear that neither unmet need nor the presumption in favour of sustainable development automatically override Green Belt protection. Provided a local council has given robust consideration to different approaches, has developed its proposal in accordance with the Duty to Cooperate and it’s [ sic ] Plan is sound in the terms set out in National Planning Policy it need not necessarily fail examination even if there remains some unmet need.” (See Appendix 3) On 5 th September 2011, the Secretary of State for Communities and Local Government stated, “Let me give him a clear and unequivocal assurance that the green belt will be protected under this coalition Government”. (See Appendix 4) 1 Anna Soubry MP Matter 1 When the Coalition Government presented the NPPF to Parliament, Greg Clark MP, then Planning Minister, took questions from MPs; in doing so, and yet again, the Government made it clear that Councils are free to set their own housing targets and Green Belt land remains specially protected from development. Below is the transcript of the Parliamentary Question I asked at the time: Anna Soubry (Broxtowe) (Con): In Broxtowe, a Labour-Lib Dem council is planning to build 4,000 houses on green-belt land. People throughout this country love and value our green-belt land. Will this framework continue to protect our green-belt land? Will it strengthen, weaken or diminish the existing protection that our green-belt land has? Greg Clark: Again, one of the points of abolishing the regional bodies is to take away the threat to the green belt that they introduced. They will be removed, and decisions will be taken locally, with national protection for the green belt. (See Appendix 5) Given the above, and the way in which Broxtowe Borough Council has prepared its Aligned Core Strategy, I do not belive that it is consistent with national policy. Q8. There is a marked absence of Neighbourhood Plans because Broxtowe Borough Council refused to consider them until May 2012 and only published an unspecific document in July 2012. I refer to my original submission regarding Policy 2 section 5; Policy 6 and Policies 11, 12, 13. Given the role of Neighbourhood Plans in Broxtowe Borough Council’s Aligned Core Strategy as it stands, I do not believe that there is a commitment to, and therefore an ability to deliver, neighbourhood plans. 2 Anna Soubry MP Matter 2: The Spatial Strategy and Housing Policy Q3iii. Despite the revocation of the Regional Spatial Strategy for the East Midlands in March of this year, Broxtowe Borough Council has not reviewed its housing target of 6,150. Q3iv. I would refer to my answer to Matter 3 Question 1 and my original submission regarding Paragraph 8, Soundness, Section B. I would argue that the available data is not reflected in Broxtowe Borough Council’s target figure of 6,150 houses; since the publication of the June 2012 Core Strategy, the results of the 2011 Census reveal a 1.9% growth in population in the Borough and a 13.7% growth in Nottingham. As the 2011 Census results show, Broxtowe’s population in 2011 was 109,500 having increased from 107,500 in 2001. As paragraph 4.5 of the Housing Background Paper Addendum May 2013 [CD/BACK/01] states, “the population of Broxtowe and Rushcliffe is significantly less than previously estimated”. Q6. I do not believe the distribution of sites is consistent with an emphasis on urban concentration and regeneration; in fact Broxtowe’s Aligned Core Strategy proposes the contrary, as evidenced by a Green Belt site (Field Farm) being listed as a strategic site whilst sites on brownfield land, such as the former Kimberley Brewery site, are not. Q24. I believe it is inappropriate to identify Green Belt land for housing and in particular to identify Green Belt land for housing in preference to brownfield land. I do not believe that Field Farm is suitable to be identified as a Sustainable Urban Extension and a Strategic Site, to be delivered within the next five years or at anytime. Equally, I do not believe that land in the vicinity of the proposed HS2 station at Toton should be designated as a strategic location. I refer to my submission to Broxtowe Borough Council’s Aligned Core Strategy, Proposed changes February 2013, specifically paragraphs 3-8 inclusive. Q25. I believe brownfield sites should be given priority. Broxtowe’s Aligned Core Strategy does include the brownfield site of Boots and Severn Trent Land, but it does not include the former Kimberley Brewery site and there is an absence of development proposals on brownfield sites in Beeston Town Centre. It should be noted that there is a 10 acre brownfield site on High Road, Chilwell, for which Broxtowe Borough Council is resistant to allow development of housing, business and community facilities* and I refer to my original submission regarding Policy 2, Section 3(d). *The site is owned by my constituency office landlord, Mr Simon Barton. 3 Anna Soubry MP Matter 3: The Green Belt Q1. Yes. Several pieces of information lead me to doubt the adequacy of a target figure of 6,150 houses for Broxtowe. I believe the figures as stated in the Core Strategy do not reflect Broxtowe’s own housing need. I refer to my original submission regarding Paragraph 8, Soundness, Section B: One way in which the RSS figure of 6,150 is not relevant is that the Regional Strategy was prepared using 2004-based Household Projections. I believe these are outdated and therefore inaccurate. This is emphasised by the fact that since the publication of the June 2012 Core Strategy, the results of the 2011 Census reveal a 1.9% growth in population in the Borough and a 13.7% growth in Nottingham. As the 2011 Census results show, Broxtowe’s population in 2011 was 109,500 having increased from 107,500 in 2001; this leads me to further doubt the relevance of a target figure of 6,150 for Broxtowe. In addition, the Housing Background Position Paper shows that it would ostensibly be credible to have a lower predicted housing figure than predicted in the Core Strategies (HBPP, p.7 Table 1). Moreover, the conclusion in the Housing Background Position Paper was reached on a predicted population of 111,800 in 2010, a figure stated in the Core Strategy (2.71). There is no basis, evidential or otherwise, upon which the overall housing target has been divided between the component Councils. This lack of supporting evidence leads me to doubt that the Aligned Core Strategy, in its current form, is positively prepared or justified. Since my submission in July 2012, I appreciate that work has been undertaken with regards to comparing the Census 2011 figures, namely the Housing Background Position Paper Addendum May 2013 [CD/BACK/01] and paragraph 4.5 states, “the population of Broxtowe and Rushcliffe is significantly less than previously estimated”.
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