Core Strategy Policy Directions
CPRE Shropshire
Protecting Shropshire
Shropshire Council is currently developing the Local Development Framework, which will guide planning in the county until 2026. On 9 August it issued the Core Strategy Policy Directions documents for public consultation.
1 October 2009. CPRE Shropshire response to Core Strategy Policy Directions
In its response to Shropshire Council's consultation on the Core Strategy CPRE raised strong concerns about the level of housing proposed and policies for renewable energy. CPRE broadly agrees with the policies on development of Oswestry but remains concerned that Shrewsbury is destined to be overdeveloped.Spatial Vision
There is much to support in the paper's vision for Shropshire, especially on the emphasis to be given to rural regeneration. The vision for Shrewsbury, on the other hand, spells disaster with its proposals for rapid growth in housing and employment. We note that there is a partnership approach to create a Shrewsbury vision (p 38) and would like to know what environmental interests are represented in the partnership, given the importance which the paper attached to environmental issues.We are very disappointed with the vision statement: "Shropshire: Innovative, beautiful and community focused" which borders on meaningless jargon. CPRE would like to suggest: "Economically dynamic, whilst caring for the historic environment and the legacy of previous generations."
We note that our earlier comment relating to spatial vision in the Issues & Options consultation "Shrewsbury should not be classed as "a strong sub-regional centre within the West Midlands", a role better suited to Telford & Wrekin" has been completely ignored.
Oswestry: Direction for Growth
It is CPRE's view that the developments set out in the Core Strategy for Oswestry are on the whole acceptable.
There is general agreement that the south eastern side of Oswestry is the most suitable area for development; however the Core Strategy is vague about where additional housing will be placed, particularly as the site is considered suitable for 750 houses only. It is important that the smaller villages are not used as sites to absorb the balance of housing, but that Gobowen and St Martins (Local Centres) should absorb the greater part of the shortfall.
We remain concerned that housing will be built before additional jobs are created. It is important that the Market Towns do not develop into commuter, dormitory towns.
We support the emphasis on affordable housing but feel that greater stress should be placed on positioning them in communities with good supporting services and that apart from exceptional circumstances they should be built in villages, which have at least both a shop and a school. It therefore follows that protection of schools in rural villages should be a sine qua non.
Employment Land Provision
As noted below, the strategy is dominated by housing. But it is essential that new housing should be balanced by local employment opportunities; this would help to reduce unsustainable commuting out of the county. The figure for net out-commuting of 12,000 (page 51) is reprehensible and is to be attributed to the failure of previous plans to secure a housing/employment balance. We suggest that the wording of the fifth bullet pint on page 53 be amended to read "Identify a specific indicative Employment Requirement for Shrewsbury to meet employment needs of the existing population and so reduce out-commuting, and aim to achieve a balance of employment to housing provision to take account of future growth."
Insofar as it is appropriate for a planning document to arrange it, there should be greater emphasis on high value-added employment, better training and education opportunities. This would improve wage levels and assist the economy without greater adverse impact on the environment.
Centres outside Shrewsbury
The strategy on retail provision should encourage rural shops and foster town centre businesses. The strategy document foresees further out-of-town shopping centres. These are damaging, and policy should follow the sequential approach, with the LDF making it clear that out-of-town retail development will only be permitted as an exception.Tourism and culture
The value of tourism to the economy is well established and the strategy rightly promotes it. It does not, however, take sufficient note of the adverse impact of development policies elsewhere in the strategy.Overall scale, distribution and phasing of housing development
On Page 67 we are given a housing requirement of 25,700 for the period 2006-2026 from the current RSS Phase 2 Revision Preferred Option.
CPRE finds it impossible to justify this number of houses based on the highlighted figures in the extract from West Midlands West Housing Market Area - Strategic Housing Market Assessment 2008 Final Report.
- The aim of RSS Phase 2 was to direct most development to the major urban areas in order to achieve their regeneration. How can this justify a population increase of 8.4% in Shropshire whilst the MUA grows by only 4%. How can it justify housing growth of 22.8% in Shropshire whilst the MUA grows by only 16.9%?
- When the West Midlands West Housing Market Area - Strategic Housing Market Assessment 2008 Final Report predicts a population increase of 23,900 in Shropshire over the 25 years 2001-2026, how can the draft Core Strategy (Page 17) predict an increase of 48,800 over the 25 years from 2006-2031?
- When the current level of occupation of the average household is in the order of 2 persons, how can a population increase of 23,900 call for an increase of 26,725 houses?
The anomalies highlighted above confirm our conviction that the basis for the ever rising housing targets passed down by the government is neither logical nor sound. Following the consultations in late spring of 2006 when the then County Council adopted their "Fourth Way" proposal CPRE concluded that a figure of 19,840 dwellings was justified for Shropshire. Since that time we have not been convinced that any further change is necessary or justified. We therefore advocate a lower overall total of 19,840 for the period 2006-2026.
One of the key aims enshrined in Chapter 3 of the Regional Spatial Strategy was "a step change in the Government's approach to sustainable communities". The fundamental element of this step change was to reverse the movement of people and jobs away from the Major Urban Areas. Nowhere in the Policy Directions document is this fundamental policy mentioned in order to set the role of Shropshire within the overall context of the West Midlands. CPRE object most strongly to this omission since it should be a guiding principle.
The paper rightly postulates a wider distribution of new housing throughout the county, and specifically in the rural hinterland as a means to meet local need and stimulate the rural economy. However, the strategy is dominated by targets imposed from above, without any real appreciation of the impact on Shrewsbury and market towns. In the Section 4.4 consultation on housing levels, Shropshire County Council warned of the impact if infrastructure and environmental constraints were not respected - and that was for lower levels of housing than those now set out.
We agree that the release of land for housing should be carefully phased and monitored. In the event that annual targets for the provision of housing are not met - for whatever reason, but most probably economic difficulties - then the deficit should not be carried forward to later years. This is an important principle and should be enshrined in policy.
We are suspicious of the principle of "flexibility" in housing provision. This too easily becomes a pretext for inappropriate development and reference to it should be dropped, lest it provide developers with an argument in the event of a refused application going to appeal.
Affordable housing policy
We agree with the proposed strategy for affordable housing. However, we do not believe in setting targets (page 71 bullet point 2), rather, that housing should be provided on the basis of established need with priority for rural communities. The criteria for affordable housing should be adhered to and must not be the pretext for housing development on sites which would not normally be approved.Environmental networks
We support the policy direction on Environmental Networks.Waste management infrastructure
CPRE has no problems with the stated policy direction. Nevertheless we are surprised that there is no mention of the "waste hierarchy", nor any commitment to policies which would lead to a reduction in the quantity of waste generated. It would seem to us that both of these matters are important factors in any comprehensive waste policy.Strategic planning for minerals
We welcome the Policy Direction under 5.51. However, we do not consider that due regard for nearby residential amenity is adequately covered, nor is the policy in the current Minerals Local Plan adequate in regard to Coal Bed Methane.- 1. Renewable energy. We object strongly to the idea that suitable sites for wind energy should be identified. The residents in an identified area would have nothing specific to comment on until an application is submitted. Whatever their views might be, the fact that the site had been identified would give it a presumption of approval (5.54).
- 2. We support a criteria-based approach, but all depends on the criteria. These would need to provide protection for environment and heritage, and the well-being of the residents of the area concerned. They must apply to all schemes whether large or small. (5.55)
- 3. The evidence base statement i about climate change is highly controversial. Putting wind turbines up in Shropshire would make absolutely no difference to the progress of climate change.
- 4. We question evidence base statement iv that wind resources in Shropshire are good. In the county council study "Harvesting the Wind", they were considered very poor in relation to other areas. There have been advances in technology since then, but in relation to other areas, Shropshire's resources are still comparatively poor even if development (with the aid of generous subsidies) is now economically feasible.
- 5. While we support some forms of renewable energy, it is important that environmental assets should be protected ( i of "You've told us").
- 6. We deplore the decision not to take forward the concept of stronger protection of Shropshire's landscapes with tougher policies (i of "Alternative Options considered but not taken forward").
While CPRE support energy conservation and some forms of renewable energy, we object to the proposed strategy which appears to be based on meeting externally imposed targets. It is disingenuous to use the term "larger renewable energy schemes" when wind turbines are the only sort of generation available to meet those targets.
- 1. Transport and accessibilityWe support the policy directions proposed with one important exception. Whilst it is clear that investment in transport networks is needed to support our economy, this is presented as completely separate from the policy commitment to reduce transport emissions. Reduction of carbon emissions is a core part of the West Midlands Regional Strategy and national commitments to reduce carbon emissions from 1990 levels by 34% by 2020. Unless this commitment is integrated into the heart of the Councils's strategy, it will not be achieved. For example: Shropshire County Council (July 07) show an estimated rise in CO2 emissions from road traffic in the town of 13% if the NWRR is built.
- 2. We therefore ask that the commitment to the NWRR within the policy to support economic growth is deleted and that an additional commitment to explicitly take into account the need to reduce carbon emissions is integrated into this statement.
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CPRE Shropshire, 11 Chestnut Grove, Ludlow, Shropshire SY8 1TJ
07771 801681. cpre@cpreshropshire.org.uk
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