We’ve scored a spectacular victory, but we’re not home and dry yet, they’re still after industrial land in the greenbelt:
You will recall that when plans were announced in November 2018, we were all horrified to discover that Shropshire Council wanted to take an unprecedented area of land out of the Green Belt for a highly controversial “garden village” estate of 850 houses and 16 ha of industrial development. Even worse, the phase 2 plan was for a further 650 houses, and more industrial and employment sites. The entire site was 410 acres of greenbelt, that’s bigger than Perton, even bigger than High Town. Fortunately – thanks to the extremely well motivated community that supported us – we fought off the residential garden village plans – they have been dropped.
But Shropshire Council still want our greenbelt for industrial expansion. The Hobbins community, many years ago, fought off a chip factory right on their doorstep. We don’t want some stinky industrial plant taking its place, and that’s what will happen in our precious greenbelt if they get this land allocation through.
We kicked off our campaign by urgently rallying support to encourage as many people as possible to complete the Council’s preferred site consultation that closed on 8th February 2019 – responses were overwhelmingly against (not that Shropshire Council took the slightest bit of notice). Since then we’ve been keeping the pressure on, gathering evidence, lobbying our local town and parish council (not that they cared much either), our County Councillors, and in October 2019 we made (the very wise it turns out) decision to instruct lawyers. Richard Buxton Solicitors have been fighting our corner, and worth every single penny, their support and forensic insight has been a game changer.
In February 2020 our solicitor sent a stonking 26-page letter to the Planning & Policy Team at Shropshire Council pointing out the myriad evidential and legal failings of the Stanmore plan. That letter made it plain that if they continued to progress the plan without correcting these failings, they would be acting unlawfully, and they’d be going to court.
Our first big win:
We knew our letter had worried them, as we heard it on the back channels. We then waited anxiously for the 20th July Cabinet meeting, when the next stage of the Local Plan Review would be announced. To everyone’s relief (but Tasley’s) the revised plan was published and the Stanmore Garden Village plan was deleted! Planning law had prevailed! Shropshire Council produced a compare and contrast appendix explaining their decision, and key to their change of heart was :
- Green Belt – The land at the ‘Garden Village’ at Tasley is not located within the Green Belt, whilst the land at the ‘Garden Village’ at Stanmore is. Paragraph 137 of the NPPF states “Before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development”. It is considered that … the proposed ‘Garden Village’ at Tasley would represent sustainable development and is capable of meeting the growth needs of the Town.
What that means is they know they didn’t follow the correct procedure for assessing sites (in fact they broke the law), and they know there are no ‘exceptional circumstances’ for building in greenbelt – this is a whopping policy hurdle that our lawyers had maintained they couldn’t meet. Our lawyers were right. This has nothing to do with whether you like one proposal over another, it’s just how planning ‘works’. How much growth, whether located at Tasley or Stanmore, is a different planning argument, which would require attacking Shropshire’s high growth policy.
This would be very difficult, as that would require undoing an already signed off high growth policy decision. This is made more complicated by the fact that Bridgnorth Town Council – as a statutory consultee – have said ‘yes’ to high growth at all three previous stages of the plan, so in planning terms, the community wants this level of growth. Seeing as Bridgnorth have not recanted on that decision (despite our lawyers writing to them in February explaining how they could do that), and now a big housebuilder is involved, that is a nigh on impossible task.
To everyone’s surprise Shropshire Council in September 2020 also agreed to send the revised plan back out to what is called a ‘Regulation 18’ or ‘Preferred Sites’ consultation, this time with Tasley as the Council’s preferred option for Bridgnorth. In reality this was little more than a box ticking exercise, so that Shropshire Council could say that they had properly consulted residents. They clearly didn’t though, because Shropshire Council took no notice of the 2,500 individual responses to the plan and have pressed ahead regardless. At the time of writing, the plan is now out at the final stage of consultation, what is called a Regulation 19 – or Pre-Submission Draft – Consultation. So called, as it’s the last draft produced before a council submits their proposed Local Plan to the Secretary of State for approval (via an Examination in Public) to adopt it. The examination will consider whether or not the plan is ‘sound’ – which has a very specific meaning in planning terms, and at this point in the development of a local plan there is what is called ‘a presumption towards approval’, or in other words, the scales are now weighted in favour of the local authority’s plan being sound (otherwise why would they submit it to the Secretary of State?!).
What are the plans now?
The Council’s proposed plans for the County and all the supporting documents for the plan and the Consultation can be found at: https://shropshire.gov.uk/get-involved/reg-19-pre-submission-draft-local-plan/ Be warned, this is the planning equivalent of War & Peace!
The full supporting evidence base can be found here: https://shropshire.gov.uk/planning-policy/local-planning/local-plan-review/evidence-base/
As you can see, the ‘Garden Village’ which will take Bridgnorth’s ‘development needs’ (supposedly!) has shifted to Tasley, and the purple areas around Stanmore represent 11.5ha of extra employment allocations to expand Stanmore Industrial Estate. Those allocations are greenbelt, and they are not justified.
The new local plan is over 500 pages long, with literally thousands upon thousands of pages of evidence nobody’s ever seen before, some of it is still a mess (for instance, after all this time we still haven’t seen a finalised economic plan that justifies this insanity). As you can appreciate, since September the professionals supporting us have had to wade through all of this, and try and marry up which policy supposedly supports the allocation of this land, and then pick it apart. They’ve then had to do it all again for the Reg 19 consultation, watching out for any sneaky changes or amendments. You’ll be unsurprised to learn that these policies (for economic growth, for instance) do not support taking any land out of the greenbelt. Please see the responses in the downloads on our Consultation Guidance page for the layman’s explanation and our argument against this new plan.
Our argument still largely hinges on what are called ‘Exceptional Circumstances’, these are very special reasons, or exceptions to the normal planning rules that allow development in the greenbelt. A lack of exceptional circumstances are ultimately why Stanmore Garden Village was dropped. And yet, here we go again, with Shropshire Council taking a punt to get some land in the greenbelt. Luckily for us, expansion of industrial estates is not an exceptional circumstance! The National Planning Policy Framework, the national ‘rules’, say that:
“Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations”.
This time, Shropshire Council have produced a special document outlining what they say are the exceptional circumstances for Stanmore: https://shropshire.gov.uk/media/16828/green-belt-revised-exceptional-circumstances-statement-december-2020.pdf Their arguments for Stanmore can be found on page page 46. In a nutshell, they are arguing expanding Stanmore is in line with their growth strategies for the county and the town, in particular:
- Stanmore Industrial Estate is considered a ‘centre of excellence for engineering and advanced manufacturing’ … it is considered to be a key employment location associated with Bridgnorth and one of the most successful centres for employment in Shropshire.
- Historically, Stanmore Industrial Estate had a stock of units available for immediate occupation, however due to high demand it is understood that there are currently limited opportunities on the site to accommodate this demand
- As a result, there is limited development potential on the site to meet the needs of existing or new businesses over the medium- to long-term within the Local Plan review period. This limitation to the future development potential of Stanmore Industrial Estate will constrain the site’s ability to contribute towards the County’s and Bridgnorth’s economic growth policies.
Therefore, they say the Exceptional Circumstances are:
- Having considered other reasonable options, including utilising suitable brownfield opportunities and underutilised land, and optimising site density, it is considered that whilst there are other locations associated with Bridgnorth where employment development can and will occur, it is not considered that these alternatives are directly comparable to the Stanmore proposition, and do not represent reasonable alternative options.
- Other locations would primarily represent opportunities to establish new centres for employment and these are unlikely to appeal in the same way to existing businesses on Stanmore Industrial Estate and other businesses in the key sector present on Stanmore Industrial Estate, given that a key part of its appeal is its existing reputation and the cluster of existing businesses in the engineering and advanced manufacturing sector which create ‘critical mass’.
- Removing this land from the greenbelt would only result in ‘moderate harm’ which when taken in consideration with all the ‘benefits’ makes it justifiable over the long term.
Of course, this isn’t true, and Shropshire Council are merely trying to wangle some land through. Their arguments are largely flannel to back fill the justifications for decisions they’ve clearly already made.
Fortunately for us, Shropshire Council’s own policy (the catchily titled ‘Item 2 of Policy DP25’) says that: “The Green Belt will be protected against inappropriate development, as defined by national policy … development proposed in the Green Belt must also be able to demonstrate that: a. It is not inappropriate development (as set out by national policy) and does not otherwise conflict with the purposes of the Green Belt; or b. Very special circumstances apply.” The NPPF says (para. 145) that: “A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt.” There are then a number of exceptions to this general definition, but the expansion of industrial estates is not one of them!!
Employment expansion argument:
As Henry Carver has said many times, there is not a shred of evidence that any extra business land is needed.
He’s pointed out over and over again, that “Telford, just 15 minutes down the road, has 400 acres ready to go and 350 acres after 2031 and has the advantage of M54 logistics, a mainline rail station and it is an impressive industrial hub with lower rates. Bridgnorth, by comparison, has poor logistics with no major infrastructure and no evidence of future funding being made available for improvements.” If you were going to locate big business anywhere, it would not be in Bridgnorth. This is not a failing, it’s just the way of the world. Bridgnorth has other strengths and assets, particularly tourism and related jobs.
We already know that Bridgnorth has over 40 acres sitting empty, and that land has been unused for over 15 years. And yet in this latest version of the plan, Shropshire Council have inexplicably increased the employment allocation from 28ha to over 40ha (100 acres) but they still haven’t evidenced it, we still haven’t even got a copy of the fabled economic plan!
We’ve surveyed the land at Stanmore twice, and we know that what was the Coram building of 48,000 ft2 has been empty for two years. It will probably be divided up into 10 units as it would be unlikely to be rented as one large unit. There are also empty management offices c2,500ft2, and 3 other empty small and medium-sized units, at c2,500-5,000ft2.
Shropshire Council say, “Stanmore Industrial Estate now has undeveloped land for less than 40,000 sq ft (3716 m2) of new buildings and that this land is likely to be fully developed before 2025”. But this is not true. Stanmore has two plots undeveloped land inside its boundary. One of 3.5 acres adjacent to Media house that is grassed, and 3 acres at the back of the site that is concreted only. Both these two plots have been empty for 25 years, with no planning applications. If the Estate office is getting 7-8 enquiries per week pre-COVID – as they claim – why have these two plots not been developed? And why do they need to take more land out of the greenbelt?
Furthermore, Stanmore needs to be seen in the overall context of development land available in Bridgnorth, particularly as the Hickman family own 16ha at Tasley and around 3h at Chartwell that have not been developed. If the Hickmans had confidence in demand these sites would have been developed. Tasley has not been developed at all and Chartwell has been on the market for 20 years and has only been half developed, with T&G and latterly a petrol station. This is strong evidence of a lack of demand, as only 10% of the available land in Bridgnorth has been developed at all since 2000. Why do we need more?
Also, it’s worth pointing out that the Hickmans live in a Guernsey tax haven, all their money is off shore, they don’t pay a penny of tax in the UK. Agricultural land is worth £10,000 an acre, but by getting sites allocated in a local plan, that changes its planning designation, and thus its value increases to £250,000 acre (even if its sitting empty). That’s a nice balance sheet enhancing exercise, without ever lifting a shovel!
Finally, Bridgnorth has lost not gained jobs over the last 5 years, particularly with the closure of Coram (70 jobs). Sadly, Grainger and Worrell, who employ over 50% (700 approx) of Stanmore’s employees, and take up 40% of their space, are unlikely to emerge from COVID unscathed. Particularly since their specialty is components for diesel and petrol engines, and the automobile industry is changing so rapidly and moving to electric. They are an important employer in the town, but with the approaching economic downturn, it’s hard to see how Shropshire Council’s claims that GW needs space to expand stacks up. They also control the Marches Training Centre, which is struggling for students. This is further hampered by poor logistics from Telford and Wolverhampton where most of the students live. It would have flourished more in Wolverhampton or Telford.
It is simply not true that Stanmore industrial estate is bursting at the seams, or that Bridgnorth needs more employment land. Shropshire Council’s business and employment arguments have more holes than Swiss Cheese!
Time is running out for us to stop this madness, there is no real argument for taking any land out of the greenbelt at all. With one more big push, we can save Bridgnorth’s greenbelt in its entirety, so that it’s here for future generations to enjoy.
We have until just 26th February to lodge our objections in this latest round of Consultation. You can read our arguments against this allocation, and get involved and submit your own response (pre-prepared, all you’ve got to do is sign and send it) on our consultation guidance page.