Shropshire Local Plan Review, Preferred Scale and Distribution of Development
THE STRETTONS CIVIC SOCIETY
Response to the Church Stretton Preferred Sites Consultation Questionnaire
1. Respondent Information
The Strettons Civic Society
2. Client Name etc
3. Delivering Local Housing Needs: cross-subsidy exception
We do not consider it is appropriate to introduce a cross-subsidy exception site policy in or adjacent to Church Stretton.
The Council has not explained clearly what is proposed and is being unreasonable in seeking support for this change in policy without giving sufficient information about what is intended nor why it is proposing a policy change which appears to be in conflict with AONB policy in the NPPF. The general principle being put forward by the Council appears to be that exception sites (i.e. housing sites outside the development boundary) could include both market and affordable housing. This calls into question the purpose and value of a plan defining site allocations. Current policy MD7a of SAMDev states that new market housing outside centres will be strictly controlled and exception sites under CS11 are limited to those offering local needs affordable housing only. The NPPF, in paragraph 71 gives support to entry-level exception sites but the footnote states “ such sites should not be permitted in … Areas of Outstanding Natural Beauty” The Council’s proposal appears to rely on paragraph 77 of the NPPF, which is concerned specifically with rural housing. It would not be consistent with the guidance in NPPF 71 and 77 to apply this approach in Church Stretton, which is a market town and key centre embedded in the Shropshire Hills AONB. WE THEREFORE OBJECT to the introduction of a cross-subsidy exception site policy in or adjacent to Church Stretton.
4. Cross-subsidy exception: development mix
5. Windfall Development: housing sites
The County windfall estimate appears to be an underestimate and should be increased. The allowance for windfall sites in the Strategic Land Availability Assessment is 299 per annum, excluding years 1-4. This would yield a windfall supply of 4784 dwellings. In the table at paragraph 3.1 of the Consultation the total windfall allowance in the final column is only 2524 and should be increased proportionately.
We think it is appropriate for a windfall allowance to be included in the housing target for Church Stretton. There is continuing scope for windfalls to arise from building in the gardens of large properties, on brownfield sites and the re-development of some sites. We consider the Council’s estimate of windfall is too low and discuss a revision in paragraph 17a.
6. Windfall Development: employment sites
We think It is appropriate for some settlements to include a windfall allowance for employment land.
At the previous stage of the consultation we argued that the provision being sought in Shropshire and Church Stretton was excessive. The fact that the current Preferred Options guideline for 3ha comprises the 1ha allocated site from SAMDev and an additional 2ha from windfall illustrates the difficulty of identifying suitable sites in the town.
Paragraph 8.17of the consultation states:
‘Proposals to develop a minimum of 2ha of additional employment land will be supported on appropriate sites consistent with criteria-based Local Plan policies to deliver the preferred level of employment development in the town’.
Taken at face value, the development sites should be in Church Stretton, which we think is improbable and not necessarily desirable. We think the area for employment land should be widened to the area of the Place Plan. This would carry forward the area-wide policy for Church Stretton in SAMDev S5.3, which refers to around 2ha of windfall development in the ‘wider Church Stretton area’.
17. Church Stretton: Place Plan Area
17a WE OBJECT to the preferred employment and housing guidelines for Church Stretton.
In our response to the Preferred Scale and Distribution of Development Consultation we objected to Shropshire Council’s adoption of a high growth forecast of 28,750 dwellings and prefer the lowest of the FOAHN projections of 25,175. It follows that we consider that the allocation of a target of 250 dwellings to Church Stretton, the only town within the Shropshire Hills AONB, is too great and should be reduced proportionately to 220 .
Another factor is that the allowance for windfall sites is only about 50% of the level which the Council describes as robust based on the historic rate. The windfall allowance for Church Stretton should be doubled from 21 to 41;.
These two changes we propose, i.e a reduction from 250 to 220 in the overall target and windfalls increased from 21 to 41 would result in the following changes to the table below:
Summary of Residential Requirements
Old number of dwellings New number of dwellings
Preferred guideline to 2036 250 220
Completed 2016 -17 9 9
Committed at 31 March 2017 110 110
Requirement to be identified 131 101
To be allocated 110 60
Windfall allowance 21 41
The key change in the table is a reduction in the number of dwellings on allocated sites from 110 to 60.
17b. Proposed Development Boundary for Church Stretton
WE OBJECT to the proposed development boundary for Church Stretton because we consider the proposals to create allocated sites for housing CSTO20 and CSTO21, which would extend the boundary, are not suitable or sustainable. We propose there should be a re-examination of alternative sites which we discuss in paragraph 64 onwards.
17c. Preferred housing allocation site CSTO 20 (part) NW of Gaerstone Farm,
WE OBJECT to the allocation of this site because it is unsuitable for the following reasons:
The development of this site for 40 dwellings would be a significant incursion of urban development into the open countryside of the AONB, which is afforded the highest level of protection against unsuitable development under the NPPF. It would extend the urban area further alongside the B4371 towards Much Wenlock and uphill close to Helmeth Hill, the Woodland Trust’s wildlife and environmental woodland. The site has steep gradients, particularly in the north west and south west parts and even with substantial screen planting on the Helmeth Woods aspect it would have significant and intrusive landscape impact.
Residents would occupy houses over a mile from the town centre and over 1.5 miles from the school up a steep hill with an inadequate footpath, difficult to negotiate with pram or disability buggy and on the opposite side of a busy road; there is no bus route and the town no longer has a regular taxi service so access would have to be mainly by car. This is a poor indicator of sustainability.
A new road access would have to be created from Sandford Avenue up a steep hillside which would require extensive tree felling and obtrusive earthworks which would be detrimental to the Area of Outstanding Natural Beauty
The Council’s site assessment classified this site as ‘Poor’ which is the lowest category.
17d. Preferred housing allocation site CSTO 21, Snatchfield Farm
WE OBJECT to this site because it is unsuitable for the following reasons:
Snatchfield has a history of unsuccessful promotion for housing development. In the mid-eighties a planning application was refused, appealed and the appeal rejected. In the SAMDev consultations there was strong local opposition to development of this site, which is overlooked by housing on three sides, and after further consideration, it was removed from preferred options.
ii) The development of this site for 70 dwellings would be a significant incursion of urban building into the open countryside of the AONB, which is afforded the highest level of protection against unsuitable development under the NPPF.
The proposed road access through existing housing areas is not adequate. From the town centre and A49 trunk road access would be along the residential roads of Watling Street South, Clive Avenue, which is steep, has no footpath and where two cars and a pedestrian cannot pass at the same time; it then proceeds steeply uphill on Ragleth Road, then up the steeper Chelmick Drive for over half a mile, before descending into the valley where Snatchfield Farm lies.
Snatchfield Farm lies in a charming valley that is a finger of green pastureland that provides a pleasant gateway to and from the Stretton Hills and variety to the urban edge of the town; It includes a bridleway, the Jack Mytton Trail, a popular walking route. Development here would impact on the landscape of the AONB and impair one of the town’s tourist features.
64. Further Comments: Discussion of Alternative Allocated sites
WE OBJECT to Shropshire Council’s exclusion of small sites within the AONB from consideration as allocated sites.
We have seen no justification for the 0.5ha threshold for allocating sites within the AONB. Paragraph 68 of the NPPF stresses the importance of small and medium sized sites and encourages the allocation of sites no larger than 1 ha. The Council’s exclusion policy ignores this NPPF guidance and is especially inappropriate in the AONB because it results in proposals for development on unsuitable Greenfield sites . A further reason why we object to this threshold is that the windfall allowance is based on historic completions on sites of less than 5 dwellings. On one hand this method of calculation depresses the windfall allowance because it excludes windfalls on larger sites. On the other hand, in so far as sites below 0.5ha within the development boundary are permitted for 5 or more dwellings within the plan period, more development will occur and the allocation of new greenfield sites in the AONB will have been unnecessary. The logical principle is that the methodology for calculating windfalls and the size criterion for allocations should be consistent.
There is a case precedent for allocating small sites within the Arnside and Silverdale AONB which is outlined in the Appendix.
65. Sites Classified as suitable for housing development
We consider the following three sites should be allocated housing sites. We think it is important to plan the future of the two town centre brownfield sites with great care and therefore urge the Council to review the area restriction so that both can be considered for allocation.
CSTO 1 Burway car sales, 0.09 ha and CSTO 2 Crown carpets, 0.07ha
The two sites are adjacent and for the purpose of development can be considered as a single site. The buildings are or are expected to become redundant and available; the site is classified as suitable for housing ; the buildings appear to be C19th build and are dilapidated so it will be practicable to demolish them and clear the site for redevelopment. The initial assessment by the Council indicates that 10 dwellings could be built, but we consider it is an ideal town centre location for affordable homes and low-cost market homes and that it could comfortably accommodate 20 apartments. Because of its location the provision of garages and car parking spaces can be minimal and can be located at the rear or within a courtyard design. It is close to shops and other town centre amenities, is within walking distance of the school and the open countryside of Rectory Wood and the Long Mynd. It is unusual for feature sites, such as this, to become available in the town centre and special care should be taken in its design and appearance in the street scene.
CSTO 17 Fire station, police station & BT building, Sandford Avenue, 0.26ha
The buildings are or are expected to become redundant; they are C20th build and appear to be in reasonable or good condition but are unlikely to be suitable for conversion to housing use so it will be practicable to demolish them and clear the site for redevelopment. In many respects this site is similar to CSTO1 & 2 because it is in a prime town centre location close to shops, school and other amenities such as the Town Park and Community Centre. The initial assessment by the Council indicates that 8 dwellings could be built, but we consider it is an ideal location for affordable homes and low-cost market homes and that it could accommodate 20 apartments. Because of its location the provision of garages and car parking spaces can be minimal and the rear access road facilitates parking at the rear or within a courtyard design similar to the adjacent Sandford Court. Special attention should be given to the design and appearance of the development because it will feature prominently in the street scene of the town’s main shopping street.
CSTO 8 Woodbank House, South of town off the A49, 0.38ha
This site was identified as suitable under SAMDev but not scheduled as an allocated site; it was expected to be developed as windfall but that has not happened yet. The Council assesses it as having the potential for 11 dwellings.
We have included it in our proposals for allocated sites to provide some back-up should the numbers suggested on other sites prove, on closer examination, to be over optimistic.
The site is adjacent to CSTO 4 which we consider below and so provides the opportunity for common development.
66. Sites classified as Not Suitable for Housing Development
The following sites should be re-considered in order to meet our proposed target of 60 allocated sites.
CSTO 35 Springbank Farm & campsite, 1.83ha: adjacent to undetermined Academy housing application
There is a current application for 6 houses on the campsite which has not yet been determined (17/01212/OUT).
Shropshire Council has classified this site as unsuitable for two reasons. First, it lies outside the current development boundary and it would be contrary to Local Plan policy to allow development on land classified as open country within the AONB. Second, the access route runs through Flood Zone 2 and part of the site is within Flood Zone 3. It lies between the SAMDev allocated employment site to the east, (15/01277/OUT, between the farm and the railway) and to the west, the undetermined housing application on the Academy playing field adjacent to Shrewsbury road (15/01276/FUL, modified by subsequent applications). The first reason given for the Not Suitable classification – that it lies outside the current development boundary - is difficult to sustain bearing in mind that the two sites that are the preferred options of the Council are outside the current development boundary, but the Council proposes to extend the boundary to include them if its proposal is confirmed. The second reason given – the Flood Zone classification - can probably be overcome by suitable mitigation measures, such as raising part of the road on an embankment. Flooding does not appear to have been a serious historic problem at Springbank Farm, its campsite or Meadow Bank; nor was the risk of flooding considered to be insurmountable when the employment site, which would use part of the same access route, was designated.
The Society considers this site should be examined afresh. We think that Springbank Farm should be considered as an allocated site under the current Local Plan review. Its sustainability rating is good. It would lie between the allocated employment site to the east, the Academy playing fields to the south and the allocated housing site to the west. It would form part of the proposed extension of the developed area of the town to the north along the centre of the valley and would be less damaging to the landscape of the town and the Shropshire Hills AONB than the suggested sites at Snatchfield or Gaerstone which would spread urban development further up into the Stretton Hills. The Council indicate that the site is suitable for 55 dwellings.
The allocation of this site would provide an opportunity to undertake a fresh examination of the undetermined housing site (15/01276/FUL etc.) which we have argued is a badly designed application and to replace this unsatisfactory site with land to the north of the Ashbrook development identified as CSTRO14 in the SAMDev Preferred Options March 2012. This substitution would be likely to yield a worthwhile increase in housing provision and provide an opportunity to create a better designed estate.
67. Sites classified as Not Currently Suitable but With Potential
Bearing in mind that the Council’s Preferred sites, Snatchfield and Gaerstone, were originally placed in this category we have considered others in the group.
CSTO 4 SW Churchway Business Centre between railway & Continental Fires, 1.14ha.
This elongated site at the southern edge of development in the town, between the A49 and the railway would use the same access off the A49 as Continental Fires. It is assessed by the Council as having the potential for 34 dwellings. It came forward as a Samdev proposal but was not designated as an allocated site and has not since been the subject of a planning application.
As a housing site it would have some of the features of the Street Meadow developments to the north in that it would be placed between the A49 trunk road and the railway. Improvement measures could include the reinforcement of a tree screen alongside the A49, the creation of a safe area in the centre of the A49 for southbound traffic turning right into the site and the extension of the 40mph speed limit to the south along the A49.
This site is adjacent to CSTO 8, Woodbank House, which is discussed above and so provides the opportunity for common development.
68. Other sites classified as not currently suitable but having potential
We considered the following sites and ruled them out mainly because our objections to them are similar to our objections to the Snatchfield and Gaerstone sites; they would be highly visible intrusions into the open countryside of the AONB or would be a new development of direction of the town intruding into the AONB. They are:
CSTO 6 Gaerstone Farm off Sandford Avenue, 2.10ha, potential 63 houses
CSTO 7 Hazler Hill Farm off Hazler Road, 1.14Ha, potential 34 houses
CSTO 11 Off Burway Road between houses and Rectory Wood, 1.83ha, potential 55 houses
CSTO 14 Off Cunnery Road, putting course below Long Mynd Hotel, 0.46ha, potential 14 houses
CSTO 27 Sandford Avenue, near Leasowes, 0.37ha, potential 11 houses
CSTO 29, Between Clive Avenue and Kenyon Road footpath to Ragleth Woods, 0.35ha, potential 28 houses
CSTO 33 Watling Street North, SW of lake on New house Farm, 1.90ha, potential 57 houses
CSTO 34 Watling Street North, southern field adjacent to A49 on a prominent knoll, 1.75ha, potential 53 houses
1. . WE OBJECT to the exclusion of small sites within the AONB from consideration for allocation. We think it important for Shropshire Council to comply with guidance in paragraph 68 of the NPPF and seek sites, especially brownfield sites, no larger than 1ha for allocation. Sites CSTO 1, 2, 8 and 17 fall into this category.
(Para. 64 and Appendix)
2. WE OBJECT to the guideline target of 250 dwellings for Church Stretton and propose that it be changed to 220.We propose that the target for allocated dwellings should be reduced from 110 to 60 and the estimate of windfalls should be increased from 21 to 41. (Para 17a)
3. WE OBJECT to CSTO 20, NNW of Gaerstone Farm, potential 40 houses and CSTO 21, Snatchfield Farm, potential 70 houses mainly on the grounds that they would be highly damaging intrusions into the open countryside of the AONB. (Paras. 17c & 17d)
4. WE OBJECT to the proposed change in the development boundary that has been proposed to accommodate the Gaerstones and Snatchfield sites that are the Council’s preferred options.(17b)
5. .WE RECOMMEND the closer examination of the following as having potential as allocated sites: (Paras. 64 & 65)
CSTO 1 & 2 Burway Car Sales and Crown Carpets, affordable or low-cost market homes 20 dwellings
CSTO 17 Police & Fire stations etc. affordable or low-cost 20
CSTO 8 Woodbank House 11
CSTO 35 Springbank Farm 55
CSTO 4 Churchway Business Centre 34
6. WE OBJECT to the introduction of an exception site policy in or adjacent to Church Stretton.