Craig Tracey, the Member of Parliament for North Warwickshire and Bedworth has responded to Nuneaton and Bedworth Borough Council’s Scoping Report Consultation on the Borough Plan.
Craig outlined his great concern over protecting local Green Belt; he cited the recent report by local authorities in our region to ‘recommend the parcels of Green Belt that can be considered for removal from the Green Belt to facilitate development.’
Mr Tracey pointed to his questioning of the Housing Minister’s last week where the Government’s position was clarified that Green Belt changes can only happen in ‘exceptional circumstances, and one of the features of green belt should be its permanence.’
Craig Tracey MP’s full response to the consultation can be seen below:
Craig Tracey MP for North Warwickshire and Bedworth – Nuneaton and Bedworth Borough Council, Scoping Report, Consultation Response
The National Planning Policy Framework is designed as, “a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities.”(NPPF Para1)
A key element of the engagement of local people in the development of a Local Plan is the consultation process. Therefore, I was dismayed to receive the notification of Nuneaton and Bedworth Borough Council’s consultation on the Borough Plan Revised Submission Scoping Report on 18th October, informing me that my response must be received by 24th October.
I am aware that a number of my constituents also found themselves in the same situation of having been given very little time to adequately respond to what is a very lengthy document. As well as inadequate time being allowed for effective consultation, the document itself does not facilitate wider public engagement due to its highly detailed and technical nature.
A key principle of the Government’s strategy on housing and planning is that local people should be instrumental in shaping the future of their communities. I do not believe that Nuneaton and Bedworth Borough Council have allowed the voices of local residents to have an adequate say in the Local Plan process, this Scoping Report Consultation being the latest example of a longstanding reluctance to engage with my constituents.
Due to the issue of lack of time as outlined above, I have focused my consultation response on one area of the scoping report which is of particular concern to me, the protection of the Green Belt. In Appendix A, Relevant Policies, Plans and Programmes, p.79 of the Scoping Report refers to the Joint Green Belt Study carried out by LUC in 2015 for a number of local authorities throughout the West Midlands, including Nuneaton and Bedworth Borough Council. The Scoping Report lists the key aims, relevant objectives, targets and indicators of the Joint Green Belt Study as, “The recommendations from this study recommend the parcels of Green Belt that can be considered for removal from the Green Belt to facilitate development.”
This statement is of great concern to me as Government policy is to give the highest levels of protection to the Green Belt. In the words of the previous Minister for Housing and Planning, Brandon Lewis, “The Framework makes it clear that inappropriate development may be allowed only where very special circumstances exist, and that Green Belt boundaries should be adjusted only in exceptional circumstances, through the Local Plan process and with the support of local people. We have been repeatedly clear that demand for housing alone will not change Green Belt boundaries.”
I have also questioned Gavin Barwell the current Minister on this issue in the Neighbourhood Planning Bill Committee on 18th October and he reiterated, “…when you want to change the boundaries of your green belt, the NPPF has a very clear presumption against doing that, too. It should only happen in exceptional circumstances, and one of the features of green belt should be its permanence.”
I do not believe that the LUC Joint Green Belt Study demonstrates exceptional circumstances, in fact I regard its methodology as fundamentally flawed and I do not believe that it is suitable for inclusion in the list of Plans, Policies and Programmes that NBBC will consult in the formulation of the Borough Plan. The LUC Study seeks to grade parcels of Green Belt land against one another using review criteria which fundamentally misinterpret the sections of the NPPF which concern Green Belt land. Paragraph 80 of the NPPF lists five purposes of Green Belt land and the LUC Study gives each parcel of Green Belt land a score based upon how effectively it fulfills each of the five criteria.
The five functions of the Green Belt within Para 80 of the NPPF are:
- To check the unrestricted sprawl of large built-up areas.
- To prevent neighbouring towns merging into one another.
- To assist in protecting the countryside from encroachment.
- To preserve the setting and special character of historic towns.
- To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
However, the NPPF does not state that every parcel of Green Belt land is expected to fulfill all of the five functions, according to Para 79, ‘The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open.’
In the words of Gavin Barwell, “The National Planning Policy Framework’s protections cover all Green Belt land equally. Even though most Green Belt was designated to “check the unrestricted sprawl of large built-up areas,” (the first purpose), Green Belt is still valid Green Belt if it is not fulfilling all five purposes. For instance, only some Green Belt protects the setting of a historic town.” Therefore, I believe that the review criteria within the LUC Study are incorrect and this document should not be used to influence the development of the Borough Plan.
In response to my question on this issue, Gavin Barwell went on to state that, “A change to the Green Belt boundary may be made only in exceptional circumstances through the Local Plan process, requiring public consultation. The key policy test is about the purpose and function, rather than the quality of Green Belt land.” The LUC study does not represent an attempt to engage with local people on this sensitive issue nor does it provide evidence of exceptional circumstances, I believe it is an attempt to subvert the spirit of the NPPF to threaten local areas of Green Belt which my constituents have told me they value highly.
If Nuneaton and Bedworth Borough Council wish to recommend parcels of Green Belt that can be considered for removal, this should be done through open dialogue and clear consultation with local people. The timing and presentation of this Scoping Report Consultation indicate that the Council needs to improve significantly in this area of Local Plan development.
Gavin Barwell also went on to say, “However, when deciding whether a Green Belt boundary needs adjustment in a particular location, the local planning authority will have to make a judgement on which piece of land to propose for de-designation. In that context, having a clear understanding of the quality of the green belt land may be useful. For example, much Green Belt is agricultural land, and elsewhere in the Framework we ask local authorities to give preference to poorer farmland over best and most versatile farmland. We also expect local authorities to be looking to enhance landscapes, visual amenity and biodiversity in its Green Belt.” If the Council wishes to look at the quality of areas of Green Belt within the Borough, I believe that further work would be needed to establish an effective criteria upon which to judge that quality to ensure that the mistaken interpretation of the NPPF within the LUC Study is not repeated.
I would also urge the Council to bear in mind Brandon Lewis’s statement which I mentioned above, “We have been repeatedly clear that demand for housing alone will not change Green Belt boundaries.” As Nuneaton and Bedworth is an already very developed Borough with precious few areas of Green Belt, I believe that protecting these is very important, particularly in light of the statements elsewhere in the Scoping Report which highlight the lack of green infrastructure.