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David Walker at Park Hall looking at the allocated sites in Shropshire Council Local Plan
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Shropshire Council Local Plan consultation Mark II

Last week Shropshire Council’s Cabinet agreed on the latest stage of the local plan review. Initially, the Shropshire Council Local Plan was locking in the sites previously consulted on last year, ready for submission. However, Cabinet agreed to rerun the ‘Regulation 18’ consultation after controversy about sites in Shifnal, Church Stretton, Much Wenlock, Shrewsbury, Whitchurch, Oswestry and Bridgnorth. Originally the next step was a ‘Regulation 19‘ consultation, which would have been the final step before submitting the plans to the Government and the Planning Inspectorate. After cabinets decision to rerun the ‘Regulation 18‘ the new schedule means a final ‘Regulation 19‘ consultation has been put back until November/December.

David Walker examining Park Hall Development while out delivering a Focus in 2018. Shropshire Council Local Plan was indicating more houses in Park Hall
David Walker examining Park Hall Development while out delivering a Focus in 2018.
In my 2019 Housing Survey residents weren’t happy with the proposal for Park Hall

The Shropshire Council Local Plan will now be subject to consultation for a period of 8-weeks under ‘Regulation 18’, commencing on 3rd of August and closing on 30th of September. This is an opportunity for everyone to have their say on the contents of the Plan. Any objections raised with the council have to be considered afresh with all of the evidence from both ‘Regulation 18’ consultations taken into consideration.

The revised draft plans submitted to Cabinet are now for the period up to 2038 – delays having forced an extension to the plan period. This decision increased Shropshire Council’s target to provide 30,800 additional homes in the county between 2016 & 2038. This also includes accepting 1,500 houses from the Black Country that they are unable to deliver.

The Conservative’s plan to ‘impose more houses on the area’ are still fundamentally flawed:

  • Their targets are too high
  • Their plans for growth are not sustainable
  • They still won’t get enough affordable homes built

I still find it ironic that Deputy Leader, Steve Charmly, falsely accused me of being a developer ‘looking to impose more houses on the area’ during the 2017 local elections, breaking election law in the process. The matter was reported to the police and an apology published in another leaflet. As a key player on Shropshire Council’s cabinet, residents might argue that he is facilitating that himself by endorsing these plans.

240 houses have been allocated to Park Hall in the Draft Shropshire Council Local Plan
240 houses have been allocated to Park Hall in the Draft Shropshire Council Local Plan

Shropshire council has had big issues in the past delivering their old housing targets. So people are rightly cynical about their chances of delivering these overly ambitious targets. As soon as they can’t deliver the overly ambitious target it will become a free-for-all at planning appeals, leaving planners once again out of control. The Conservatives previously failed to establish a 5-year land supply resulting in hundreds of unwanted houses being granted permission at appeal in an uncontrolled way.

Affordable homes

Lack of supply is a factor in making houses more affordable but it isn’t the only factor. Building more houses on its own just won’t work. Building houses in the wrong places, without meeting local need and at unrealistic levels is not sustainable. Providing more affordable homes to rent and buy is vital but that is best delivered by Community Led Housing that meets local housing needs, not by commercial housing developments.

Making sure the right homes are built in the right places is critical. Making sure there are enough affordable houses to rent and buy so local people can stay local is also critical. Building homes must be based on need. That means more use of Community-Led Housing on exception sites with tighter planning controls, and less open market housing schemes which always struggle to meet local needs.

Housing targets are too high

In my resident’s housing survey last year residents in Whittington (results) and West Felton (results) overwhelmingly backed the suggested target by the CPRE of 26,250 new homes. Only 2.9% backed Shirehall’s target of 28,750 new homes.

Pie chart: People overwhelmingly backed the CPRE growth figures. Only 2.9% backed Shirehall's target for the Shropshire Council Local Plan
People overwhelmingly backed the CPRE growth figure of 26,250 new homes.
Only 2.9% backed Shirehall’s target of 28,750 new homes

The main benefits of having an ambitious housing target are:

  • Hugely increased Council Tax receipts from a larger Council Tax Base. More income without the need to raise Council Tax rates. For a cash strapped council that recently flagged the possibility of going bust, this is a big deal.
  • Hugely increased income from Community Infrastructure Levy (CIL) charges on developers

Neither are necessarily a bad thing but the scale of the benefit must be a material factor in their decision to have such a high target – higher than the suggestion from both the CPRE and the Government. It should be entirely based on need but it clearly isn’t – I am cynical these days.

Presently Shropshire Council earns £163m from Council Tax receipts – based on their £1,443.62 share of a band D council tax bill.
There are 144,653 properties in the valuation list, equalising those to Band D equivalent properties equals 113,557.43 properties – and adjustment downwards of 21.5%. This is to allow for different valuations being charged different council tax rates.

Assuming there is no inflation over the plan period and that a similar ratio of house sizes are built by 2038, gives 24,179 band D equivalent new homes – adjusting the housing target of 30,800 downwards by 21.5%.
The 30,800 housing target would net Shropshire Council a cool £34,9m in extra council tax receipts. With compound inflation, it would be a lot higher than that.

Shropshire Council Local Plan –
Policy DP3: Affordable Housing Provision

Shropshire Council Local Plan policy DP3 states:

Opportunities for people to access new homes which are well designed, of high quality,
and the right type, tenure and affordability will be achieved by:
a. Requiring new residential development of 5 or more dwellings in designated rural
areas and 10 or more dwellings or sites of 0.5 ha or more elsewhere to provide onsite affordable housing, in accordance with the following percentages and
geographic areas as defined Figure DP3.1:
i. 10% in the north; and
ii. 20% in the south.
b. Ensuring that only in exceptional circumstances will either an off-site provision or a
financial contribution in lieu of on-site provision be supported on major housing
development;
c. Ensuring applications for development with a requirement to provide affordable
housing secure the interest of a Registered Provider, and that the affordable
dwellings will be transferred to a Registered Provider as soon as possible, and no
later than at completion of 50% of the consented market housing;
d. Ensuring that where affordable housing is to be secured on site[sic], its tenure
comprises 70% social or affordable rent[sic] accommodation and 30% intermediate or
other affordable housing, unless evidence of local need indicates otherwise;
e. Requiring affordable rents to be set at 80% of open market rent and not to exceed
Local Housing Allowance Housing Benefit;
f. Requiring shared ownership to be capped at 80% of the equity share;
g. Ensuring that the affordable housing is indistinguishable from the open market
housing, including by way of character, design, location and size and is consistent
with policies SP5, DP1 and other relevant policies of this Local Plan;
h. Ensuring that affordable housing is appropriately distributed within the site, their
locations maximise opportunities for future residents to access services and facilities
by walking, cycling or public transport and minimises the exposure of future
residents to sources of noise or reduced air quality; and
i. Ensuring new and existing affordable houses are maintained as affordable in
perpetuity.

Shropshire Council Local Plan: 2020 Draft

Broadly this isn’t a bad policy in Shropshire Council’s Local Plan. However, my main gripe remains the delivery of affordable housing. The 10% figure for Northern Shropshire isn’t sufficient on its own. Some places need higher, some places need a lower percentage. This policy generally means each site is allocated a number of affordable units. Developers then appeal the number claiming that the number is not sustainable and get the number reduced. I have long argued that affordable housing should be delivered using housing density not defined numbers. A site can have a density that delivers a number of average houses. Each site gets a bespoke density based on need. If a developer wants to build more large houses then they also have to build more, smaller houses to meet the average density. If they want bigger then they can have them if the overall scheme meets local need.

However, affordable housing is best delivered on exception sites where planning wouldn’t normally be allowed except in exceptional circumstances. This is usually on the edge of development boundaries. If Shropshire Council allocated fewer sites in the Local Plan more could come forward as exception sites and deliver many more affordable homes that the Conservative plan will achieve. This is best delivered with Community-Led Housing where the community decides what it needs and delivers that need.

Contact me if you have any comments about the sites allocated in the Shropshire Council Local Plan

2 thoughts on “Shropshire Council Local Plan consultation Mark II”

  1. Hi I am a resident in Whittington Penybryn Avenue there is a plan to develop the field at the edge of Penybryn Avenue in a location that is currently been surveyed which take no consideration of the residents as they have no faith in what is happening and do not believe these are going to be affordable to local people my daughter is coming up to 29 years old has always saved and worked hard she look at affordable housing that is being build at the castle keep site there is I believe two houses among the forty being built which are so called affordable when she looked at the cost of 170.000 fir acted bedroom house what makes anyone with any level of intelligence think that is affordable for local rural people to purchase they can buy a percentage off-the-peg property and pay rent on the balance and if they can or want in the future buty more of the property but as time goes by the value of the part they can’t afford to buy at the start increases so it will never be a property they will buy or own outright Affordable I would be interested in your views there is a total distruss amongst residents as it will happen regardless of what the residents want or would like and as the developer is partly owned by the council and the parish council get money for every dwelling built they are equally not concerned but just provide lip service to people surly there should be more concern about land being built on In rural areas the surveys that have been conduct are also a joke even though it list the probability of rare species living around the development site the survey misses out many of them and us very vague to say the least and the person must be blind to have missed so many of them at his convenience Ian’s maybe that of others your thoughts would be appreciated

    1. Hi Trevor,

      Sorry for the delay in replying. I felt I needed to do some more research first. I went to see Neil last Friday after several emails about the site. Last Wednesday I also undertook a speed survey on Ellesmere Road and Church Street. The highest speed was 66mph.

      I have now seen the plans for the site. Overall, the proposal gives me several areas for concern. The suitability of the location is questionable. I will blog about that shortly but in summary my concerns are:

      Traffic is a concern with 70 spaces creating potentially 280 extra traffic movements a day through the estate and onto Boot Street / Ellesmere road
      The residents who will be living here will have higher needs for access to services (school,shops, buses etc.) Many may be older. Walking to access services won’t be easy or possible for people with mobility problems. This will add to traffic issues or they will be more isolated. Logically the site would be better situated nearer to those key services.
      Proxitity to the adjacent sites rated as havibg long-term housing potential behind top-street. If the Star site is built this will enviably increase the likelihood of the remaining field over thd bridle path being infilled. Shropshire Council’s own strategic view in the draft local plans, and its predecessors, that housing growth should be on the south of the village. If these fields are developed it will significantly add
      to the existing pressures on Top Street and Boot Street.
      The topography, sewerage, drainage and the ecological impacts don’t lend themselves to a sustainable or affordable development

      I am a big fan of community led housing (CLH) as a means to delivering properly affordable homes to rent and buy. CLH housing schemes are mainly built on exception sites, like the site Star want to build. Star Housing aren’t a CLH organisation though. They are an ALMO (Arms Length Management Organisation) which is semi-detatched to Shropshire Council. CLH organisations are set up and run by the community and not by councils. Therefore, they better placed to reflect and meet the needs of the community.

      The main problem with any affirdable housing is keeping it affordable. Usually they are sold on and tge affordable element goes out of the window. Keeping them permanently affordable for local people is a high priority for me. There are several applications at the moment to remove s106 agreement obligation to keep houses affordable. If they are removed it will be because the houses aren’t needed as affordable homes. Star will say they are needed to justify their site. They both can’t be right.

      Communuties need genuine affordable homes to rent and buy, help to get onto and to move up the ladder, but also the ability pass property back to the community as affordable homes. Just relying on developers to build token affordable homes isn’t enough and it can’t support younger people staying in the community they were brought up in.

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