CPRE Shropshire
Protecting Shropshire for Sixty Years

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Summary

There is much in the Core Strategy to commend it, including an awareness of the need to protect environmental assets, to promote a prosperous rural economy, to save energy, and to encourage a pleasant living environment. These ambitions, however, are undermined by the promotion of a rate of growth, which can only impact on the quality of life throughout the county and particularly in Shrewsbury. We believe that the Core Strategy fails the test of soundness on the following grounds:

Conformity with the West Midlands RSS. The Core Strategy fails to acknowledge the “step change” central to the RSS approach to sustainable communities, which is aimed at reversing the movement of people and jobs away from the Major Urban Areas.

Shropshire Community Strategy. The Core Strategy fails to adequately take account of Shropshire Community Strategy Priority 3.3 concerning young people. This is a serious omission given the demographics of Shropshire and the importance of young people in sustainable communities and a viable economy.

Adjacent authorities. The complementary role of Telford and Wrekin as a settlement for employment and high housing growth is barely acknowledged in the Core Strategy. Telford & Wrekin is surrounded by Shropshire on three sides and its employment, retail economies, transport and ecological systems are inextricably linked with those of central and east Shropshire.

Minerals. The Core Strategy is in conflict with MPS1 with respect to sand and gravel extraction in the area of the Shropshire Hills AONB.

The Core Strategy is also unsound in that many of its policies are inconsistent with each other. These are detailed below.

Environment: Strategic Vision and Policy CS2

We are disappointed that Shropshire’s natural and historic environment is relegated to last in the Strategic Vision. As the text of the Core Strategy acknowledges, the natural and historic environment makes a central contribution to the quality of life of people in the county. It would be consistent with this recognition for “the County’s greatest asset” to be featured at the beginning of the Strategic Vision.

The Environment is similarly tagged on last in policy CS2 (paragraph 4.27). The natural and historic environment is central to the quality of life in Shrewsbury and should at the very least feature in the Vision for the town (paragraph 4.14).

Housing Growth: Policies CS1, CS10

The Core Strategy in unsound due to the conflict between housing targets and West Midlands RSS step-change policy. 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:

2.7 In spatial terms, it is particularly the outward movement of people and jobs away from the MUAs which is increasingly recognised as an unsustainable trend and one which provides the Region with a key challenge. The trend is seen as increasing the pressures on the environment, encouraging development of Greenfield sites, increasing the need for car-based travel and creating dangers of abandonment and greater social polarisation within the Region (Extract from the WMRSS: Chapter 2. Towards a More Sustainable Region).

The representative of Wolverhampton City Council at the RSS Phase II review EiP confirmed the link between housing availability and out-migration; there had been a substantial drop in the number of people moving out of Wolverhampton owing to the sharp decline in housing construction in Telford during the recession.

The Core Strategy outlines a strategic approach to accommodate growth on greenfield sites in response to in-migration, with inevitable car dependent travel resulting. This is a breech of the WMRSS step change policy.

The Core Strategy strategic approach can only encourage outward migration from MUAs and excessive commuting. The Core Strategy envisages such high levels of commuting to Telford and the MUAs that a Shrewsbury Parkway rail station is deemed necessary to cope (Policy CS7). Again, this is a clear breech of the WMRSS step change policy.

The Core Strategy states that Shropshire’s population is projected to grow to 329,600, and projects an increase in households to 152,300 by 2026 (page 9). This suggests that each newly built household will be occupied by only 1.37 people, compared to just under two at present. This decline in household size is unduly pessimistic and does not take account of the ambitions to retain and increase younger people in the county, as outlined the in Strategic Vision and the Shropshire Community Strategy (especially Priority 3.3).

The WMRSS gives indicative annual housing targets for Shropshire (paragraph 5.7). Paragraph 5.12, however, proposes exceeding these targets. The only reason given for this higher delivery rate early in the plan period is that potential sites are available. There is a grave danger that housing will outstrip local need and employment, fuelling inward migration and commuting to Telford and the MUAs. Housing supply should be based on a rolling review of need, not speculative targets. If housing market conditions do not rapidly improve, an early rush to provide housing is likely to secure lower financial contributions to affordable housing.

In contrast, paragraph 4.10 states that “it is expected that [housing] proportions may be skewed towards the urban areas in the early plan period [and] that the proportion in rural areas may initially be depressed, reflecting the change in approach to a community-led and community benefit focus.” This takes an unduly pessimistic view of community acceptance of affordable rural housing and fails to address the urgent need for such housing highlighted throughout the Core Strategy. The statement may also direct planning officers’ priorities away from rural areas during the early part of the plan period. The Core Strategy would be more sound is this statement was removed.

The influx of army personnel from Germany was raised at the RSS Review. The Head of Planning in Telford, Michel Barker, made it clear that housing provided for them would count against local plan targets, not be an extra. Paragraph 4.13 needs to be reworded to make it clear that this housing will be within the overall housing targets stated in the Core Strategy.

Transport: Policies CS2 & CS7

Core Strategy policies CS2 & CS7 promote the NWRR. This is inconsistent with other policies and the Shropshire Community Strategy.

The Spatial Vision claims that construction of the North West Relief Road in Shrewsbury will “help reduce car dependency”. This is not credible and no evidence is given that this road will promote public transport, cycling and walking. Paragraph 4.26 states that building of the NWRR is subject to approval of the “business case, planning permission and necessary land acquisitions”, yet the council has made it clear through local media that whether it will proceed is dependent on a public consultation to be held in April 2010. “Consultation feedback will be considered by the council in August before deciding whether to submit a Major Scheme Business Case for the road to the Department for Transport” (http://tinyurl.com/yglewkj).

Shropshire Council has built an unnecessary dependence around the NWRR into the Core Strategy. This is in direct conflict with policy CS1:

“New development… respectful of local character, and planned to mitigate, and adapt to, the impacts of climate change.”

The plans for the NWRR are also in conflict with policy CS5 and with Strategic Objectives 8, 9, 10, 11 and 12. The reliance on the NWRR is at the expense of a broader vision for sustainable transport in the county in conflict with policy CS7. Promotion of the NWRR also conflicts with Priority 2 of the Shropshire Community Strategy.

On page 42, the first bullet point of the last paragraph of policy CS2 is in clear conflict with the third bullet point as the NWRR cuts through an area of great environmental sensitivity.

Shrewsbury Parkway is designed to support dormitory living in Shropshire and commuting to elford and the West Midlands MUA. This is in direct conflict with the RSS & Strategic Objectives 8 & 9.

No consideration is made of the transport viability of community hubs in policy CS4. This is essential to ensure compliance with Strategic Objectives 8 & 9 and the sustainability of the hubs.

Economic Development, Enterprise and Employment: Policy CS13

There is no obvious relationship in the Core Strategy between provision of employment land (CS13), local need and provision of housing (CS10). The dangers are both under-provision leading to excessive commuting to Telford and the MUAs, and over-provision leading to commuting in the other direction.

Waste Hierarchy: Policy CS19

Policy CS19 acknowledges the waste hierarchy, but in paragraph 7.20, states that “national energy policy is clear that we should actively promote opportunities to recover the energy value of biomass waste”. To meet Strategic Objective 9 and to prevent any confusion about priorities in waste management, for example the promotion of energy generation at the expense of recycling, the policy should clearly state “any proposal for waste treatment facility must not prevent waste disposal options further up the waste hierarchy from being fully exploited”. This statement should be part of the policy, not the accompanying explanation.

Paragraph 7.22 states that “most modern waste management facilities are enclosed within buildings”. The policy should state that all new facilities should be enclosed in order to minimise their impact on the landscape and neighbourhood to meet the ambitions of Strategic Objectives 10 and 11.

Minerals: Policy CS20

It is not acceptable to quarry for sand and gravel within the Shropshire Hills Areas of Outstanding Natural Beauty. MPS 1 is quite clear that planners should “not permit major mineral developments in… Areas of Outstanding Natural Beauty” (MPS1, paragraph 14). Showing “broad locations for future working of sand and gravel” within the AONB in Figure 11 is tantamount to an invitation for them to be considered for extraction. While these areas remain on the plan, the Core Strategy fails the test of soundness by being in conflict with national policy MPS 1.

Young People: Strategic Vision and all Policies

The needs of the elderly are rightly recognised in policies, but there is no explicit planning for young people. The following points illustrate the importance of young people in planning strategy outcomes:

• Page 9 recognises the “higher than average out-migration of young people”
• Paragraph 3.1 states “in Shropshire, we need to plan [to] encourage more young people to remain in, or move to, the area”
• Paragraph 6.2 accompanying policy CS13 states “key concerns include the need to attract and retain young people.”
• Priority 3.3 of the Shropshire Community Strategy states: “Children and young people are encouraged to reach their full potential, and decide on Shropshire as their place of choice”.

This need to plan for young people is not carried forward into the Strategic Objectives, and is absent from all polices with the exception of CS8. This is a serious omission in the Core Strategy given the growing demographic imbalance within the county, and the importance of its economy, schools and community life.

Definition of Local Needs: Policies CS1, CS3, CS4, CS5, CS7, CS11, CS13, CS19 & CS20

“Local needs” for affordable housing is not defined in the document. A robust definition is essential for successful implementation of the Spatial Vision and policies CS1, CS3, CS4, CS5, CS7 and CS11. A robust definition of “local needs” for housing will also help local acceptance of affordable housing development.

“Local need” should be more precisely defined in relation to policy CS13, paragraph 6.7. Elsewhere, for example in policies CS19 & CS20, the term “local need” should be replaced with, for example, “Shropshire need” or “regional need”, or “within 30 miles”, to make clear the spatial dimensions of the anticipated need served by the policy.

Definition of Sustainable Urban Extension: Policies CS2 & CS3

Two sustainable urban extensions are proposed for Shrewsbury and one for Oswestry. The Core Strategy fails to define what makes an extension sustainable, including integration with the existing townscapes; provision of facilities such as shops and schools; public transport, cycling and walking links; and integration of green infrastructure with the existing landscape. The danger is that if this is not spelt out at policy level the extensions will become mere housing estates with minimum provision of local facilities and poor integration with the existing settlement.

Adjacent authorities: Telford

The Core Strategy makes very little reference to planning policies in Telford. Yet Telford and Wrekin is surrounded on three sides by the county of Shropshire. The complementary role of Telford and Wrekin as a settlement for employment and high housing growth is barely acknowledged. Everyday experience shows that the employment, retail economies, transport and ecological systems of the two planning areas are inextricably linked. The Core Strategy specifically fails to take account of the Telford & Wrekin Core Strategy Development Plan Document, adopted December 2007 and sound until 2016.