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Local plan: last chance to comment on Conservative plans to ‘impose houses on area’

David Walker examining Park Hall Development while out delivering a Focus in 2018
David Walker examining Park Hall development while out delivering a Focus in 2018

The FINAL public consultation on the Conservative’s draft local plan proposals is now out for consultation. The consultation runs until 5 pm on the 5th of February.

This consultation is referred to as the ‘Regulation 19’ consultation. The aim of this round is to allow people to examine and comment upon the legality and soundness of the draft plans.

This is your VERY last chance to comment on the Conservative plans to ‘impose more houses on the area’. Their plans for 30,000 new dwellings is far in excess of the Government’s recommended growth (25,400) and more than The CPRE calculated (18,000). In my housing survey there was hardly any support for this level of growth.

All comments at this stage will be sent to the planning inspector when they examine the soundness of the plan.

Many areas are challenging the soundness of the draft local plan and asking for their sites to be removed entirely. Some sites have been removed more recently. These allocations will have to be absorbed by other settlements if the overall target is retained. Sites have already been added to the plan without consultation.

The Conservative plans are overly ambitious.

If Shropshire Council reallocates housing it will be to settlements that have allocations in the plan already. This is particularly significant for settlements who will become community hubs in this plan, like West Felton.

If the plan is found to be unsound they will have to start again, at vast expense. Settlements will be exposed to more uncontrolled development. This is a very real possibility. Liberal Democrats at Shirehall tried to delay the process to make sure the plans were sound, based on need and not rushed through with poor consultation.

If they undershoot their overly ambitious targets then it wil be open season for developers to build houses all over the area again. A developer will be able to claim their site will fulfil an unmet need. That site could be anywhere. This last happened when the Conservative administration failed to establish a 5-year land supply. That failure allowed developers to ‘impose houses on the area’. It meant housing was built without community support, without the required infrastructure and on site far removed from planned growth areas.

If you want to prevent inappropriate development it is far better to stop allocations appearing in the plan now. If you wait until a developer submits a planning application it will be far harder to stop.

30,000 houses is too many – wrong houses wrong place

The 30,000 target is quite arbitrary. It is not based on local need. Indeed Shropshire Council housing needs surveys (Right Home Right Place) started after sites were chosen without public consultation. How can allocations be considered sound if they put the cart before the horse? Sites have been allocated in the wrong places. For example, in West Felton, the allocated site is not adjacent to community facilities or public transport. Other sites up for consideration were much more sustainable and could be argued were better sites. For Whittington where is the overall strategy to manage housing and traffic growth in the long-term? Park Hall has sites allocated in the plan that were rejected in the Strategic Land Availability Assessment while other sites elsewhere ‘with long-term potential for housing’ weren’t included.

Just allocating sites without strategic vision isn’t good enough. Allocating sites doesn’t get them built. Allocating sites doesn’t fulfil the real need for genuinely affordable homes to rent and buy at all levels of the market. There is more to the housing crisis than just throwing numbers at the problem. Throwing up houses without the jobs and infrastructure to support them just create more problems. A more holistic approach to town planning is required.

The 30,000 target is entirety a political decision by the Conservatives. Building at a very high rate will allow them to grow the tax base without raising council tax. It has very little to do with need.

Two years ago the Conservatives consulted on their growth target:

  • The CPRE’s suggested a target of 18,000
  • The Government’s suggested 25,400
  • Shropshire Council suggested 3 options – all higher than the government:
    1. a ‘Moderate growth’ target of 26,250
    2. a ‘Significant growth’ target of 27,250
    3. a ‘High growth’ target of 28,750

Their higher still target of 30,000 is highly questionable in that context. More so when you consider they have a weak plan for infrastructure needed to deliver this level of housing and support the new business parks.

We all want more affordable homes but they must be sustainable, and built-in the right places based on local need. They need to stay affordable in the long-term. Homes need to be high quality supported by improved infrastructure. They need to be part of a co-ordinate vision to addresses existing problem areas like traffic. This plan leaves a lot to be desired and falls far short of the sound plan Shropshire needs.

The final consultation runs until 5th February at 5 PM

https://shropshire.gov.uk/get-involved/reg-19-pre-submission-draft-local-plan/

This process is overly complicated and, in my view, designed to put people off commenting on the plans. This is nuts. Making the process hard itself impacts on the soundness of the plan. Commenting should be easy! In this day and age, there are no excuses for not making to process as easy as possible.

Specific policy areas in Whittington Division

The draft local plan document with these sections:

S14 Oswestry Place Plan area page 242

S14.2. Community Hubs: Oswestry Place Plan Area – page 246

S14.3. Community Clusters: Oswestry Place Plan Area – page 252

This map covers the Oswestry area of North Shropshire
S14. Oswestry Place Plan Area Inset Maps.pdf

The accompanying sustainability appraisal
Sustainability Appraisal – Appendix O. Oswestry Place Plan Area Site Assessments.pdf

I have analysed their assessment in the Sustainability Appraisal. When they did the Strategic Land Availability Assessment (SLAA), without public consultation, they rated all of the sites. As part of their evidence base to demonstrate the soundness of their plans Shropshire Council scored each site against 15 criteria, giving each site an overall score.

Each site was then assigned a rating of Good, Fair or Poor (see section 2.23). They used a common approach to score every site. However, the rating was only based on the scores within each settlement. Site allocations with identical objective scores have often been given different ratings. Worse still sites with a good rating ratings have been passed over in favour of sites with poorer ratings. That is nuts.

They say this is to reflect comparison within communities as originally intended. However, that doesn’t explain not picking from the most sustainable sites. By not following an objective appraisal and using a subjective assessment they have undermined the whole appraisal

I have redistributed the ratings based on scores across the whole place plan area (see sheet 2)

Whittington – 70 new dwellings page 251

Whittington Site Allocations
Whittington Site Allocations: WHN024

In Whittington Shropshire Council has allocated site WHN024. Shropshire council’s sustainability assessment gave this site a rating on -6 (Fair). 14 sites had a better sustainability score than this site. 12 had a worse score. Objectively there were more sustainable sites they could have chosen.

West Felton – 60 new dwellings page 250

West Felton site allocation: WEF025

In West Felton, Shropshire Council has allocated site WEF025. Shropshire council’s sustainability assessment gave this site a rating on -5 (Good). 10 sites had a better sustainability score than this site. 15 had a worse score. One other site had the same score.
Objectively there were more sustainable sites they could have chosen.

Park Hall – 240 new dwellings page 244

Park Hall Site Allocations
Park Hall Site Allocations: PKH002, PKH011, PKH013, PKH029, PKH031, PKH032

In Park Hall Shropshire Council has allocated sites PKH002, PKH011, PKH013, PKH029, PKH031, PKH032. Shropshire council’s sustainability assessment gave these site a rating on -2 (fair), -6(fair),-5 (fair),-1 (fair), -4 (fair), -4 (fair), -2 (fair) respectively with a combined score of -1 (fair). Two other sites in Park Hall and two more in Oswestry had a Good ratings but weren’t allocated.

Elsewhere in Oswestry Place Plan area

Site being picked with a lower sustainability rating isn’t just restricted to Whittington Division. It is across the whole of the place plan area. If I owned these sites I wouldn’t be happy. Some of which may choose to challenge the allocations based on sustainability. For example:

  • Gobowen: GRW009 was allocated (score of -1 and rating of fair) when GWR001 (score of 4 and rating of Good) wasn’t allocated.
  • Knockin: KCK009 (-7 rating) allocated with KCK003 (-3) and KCK011 (-4) not allocated

Overall 104 sites that Shropshire council gave a Good rating. 3 were allocated.
Of the 120 sites rated as fair 13 were allocated.
54 sites were rated as Poor. None were allocated.
Arguably only 3 out on 16 allocated sites getting a Good rating isn’t very good at all. There is plenty of room to allocate the same number of dwellings by choosing more sustainable sites.

How to comment

Here is a simple guide for how to send in your comments on the draft local plan. Shropshire Council have provided a guidance note here: Representation Form – Guidance Note.pdf

You will need to fill in both Part A and Part B forms to comment on the plans

Part A is about you

You will only need to fill in this form once if you are making more than once comment on the plans

Part B is for your views

Important: Fill in a separate Part B form for every policy area that you need to comment on. The forms imply you can only comment on the soundness. However, you can comment on any area of the local plan.
If you have previously commented at an earlier stage you will need to repeat those comments as only comments from this stage are being sent to the planning inspector.

Q2 add your policy area of interest

Q3 tick whether you think that policy area is legally compliant and sound

Q4 If you answer ‘no’ in Q3 frame your comments around whether the plans are legal and sound for the policy area of concern.

Q5 add your changes that would make it legally compliant & sound

Q6 say whether you want to speak at hearing and say why in Q7

Use extra sheets if needed.

Post handwritten forms to Shropshire Council, Planning Policy & Strategy Team, Shirehall, Abbey Foregate, Shrewsbury, Shropshire, SY2 6ND
or email electronic forms to Planningpolicy@Shropshire.gov.uk

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