HOUSING

The housing issues were considered at a number of meetings of the Local Plan Advisory Group are set out below.

Report of 9th March 2004

REPORT

To consider certain elements of the policy framework for housing in the plan review in response to comments received on the Key Issues Paper.

BACKGROUND

In July 2003, the Borough Council published its Key Issues Paper as a preliminary consultation exercise pending the review of the adopted local plan (June 2001).

In relation to Housing, a total of 16 Key Issues were identified and views canvassed in order to inform the review process. For the purposes of this report, the responses to the first four questions (ie 2.1 - 2.4) are examined and draw upon research undertaken on the Urban Capacity Study which is now nearing final completion.

The issues raised relate to the following:-

• Relevance of current adopted Local Plan objectives;

• The future of allocated housing sites which remain undeveloped;

• Brownfield development targets; and

• Density targets.

There were over 180 responses on these four Key Issues, the details of which are outlined in the next section together with officer responses and recommendations.

Question 2.1

Are these objectives still relevant in the Plan review? If not, how should they be amended?

Officer response

Whilst there is general support for the housing objectives to be maintained in the plan review, issues are raised in respect of several which need to be updated and amended to reflect current/emerging national policy. The first bullet point for example needs to be amended to address the need to provide for a 10 year supply of housing in line with Structure Plan and Regional Planning Guidance forecasts (Nathaniel Lichfield and Partners, Gough Planning Services, Stoneleigh Planning, Entec). A further issue raised in relation to housing requirements is the need to "plan, monitor, manage" rather than "predict and provide" (CPRE, Shrewsbury Civic Society, English Nature). This is an important caveat to the need to plan for 10 years housing growth and will be addressed via the annual monitoring of housing completions and the sequential release of sites in a phased manner. It is therefore recommended that the first bullet point be replaced by the following:-

• To ensure that there is sufficient housing land available during the period 2006-2016 to provide for the number of dwellings forecast in the Shropshire and Telford and Wrekin Structure Plan and in line with the successor strategic requirements set out in the Regional Spatial Strategy (RSS) for the West Midlands.

• To allow for the phased release of housing land in accordance with a sequential approach, subject to annual monitoring and review.

The second bullet point in the adopted plan refers to the need to provide an appropriate range and mix of housing but includes demands arising from outside of the Borough which as highlighted by Gough Planning Services should already be accounted for in housing forecasts. This is accepted and hence it is recommended that the reference to "some of the expected demands arising from outside the Borough" be deleted.

With respect to the fifth bullet point and the need to promote brownfield sites, it is accepted and recommended that this should also include "buildings" via conversion/repair/refurbishment (English Heritage, English Nature).

It is considered that the sixth and seventh bullet points could usefully be combined to address the need for good quality design, building communities and reducing environmental impacts (Cllr B Morris, Countryside Agency, English Heritage, Mrs P Moseley). It is therefore recommended that a revised key objective should read as follows:-

• To locate new housing where it will have minimum environmental impact whilst securing conservation/design/sustainability benefits and respecting the need to build active neighbourhood communities.

A final issue which features in many responses is reducing the need to travel and promoting lower car parking standards as outlined in objectives 8 and 9, (Economic Wellbeing Group, Councillor J P Jones, Kemberton Consulting, National Farmer's Union, K A Niblett, J D Pitchford, M Quinn, M G Robins, Shrewsbury Housing Forum, Shrewsbury Town Centre Residents Association, Mrs J Waller). In response to the points raised, it is considered that reducing the need to travel should remain a key objective of the future land use planning of the Borough even though it is accepted that the private car will still remain the major mode of travel particularly in the rural area where viable alternatives are limited. The planning system has a key role to play in focusing development on or adjoining transport corridors where alternative modes of transport can be encouraged to develop (i.e. public transport). It is therefore recommended that this key objective be retained in the plan review as part of the core strategy.

With respect to reduced car parking standards, this is a difficult issue and with increases in personal wealth creating higher levels of car ownership, the planning system plays a somewhat marginal role in influencing public perceptions and behaviour towards the private motor car. Therefore, at best, it is acknowledged that the planning system can only seek to minimise car parking provision in appropriate locations (e.g. within or adjoining the town centre or along quality bus corridors) when integrated public transport polices are in place and it is therefore recommended that this be retained as a laudable key objective.

Question 2.2

Should sites originally allocated for housing purposes, which have not yet been the subject of planning applications, be carried forward in the review? If not, which sites and what alternative uses should be investigated.

Officer Response

There has been a wide range of responses to this question and several (i.e. CPRE, Mrs A E Hayward, Church Preen, Hughley and Kenley Parish Council, Hope Conservation Trust, M Quinn) favour the use of former rail land at Ellesmere Road for alternative uses. In terms of re-using the land for rail purposes, this issue was addressed during the Local Plan Inquiry in 1999, but the Inspector concluded that these sites should be developed due to their sustainable location close to the town centre. In response to the railfreight issue, land was protected off Castle Foregate to consolidate an existing operation together with the allocation of land at Battlefield for a new railfreight terminal (Policy T11 of the adopted local plan refers). It is considered therefore that this issue was addressed during the formulation of the adopted plan and there are no changes of circumstances since 2001 that merit any re-examination of the potential to reserve the sites for rail use, though the prospect of de-allocating them in favour of open space/wildlife corridors or community uses should not be ruled out.

With respect to the potential for using the rail sites for relief road corridors (M Quinn), it should be noted that there are no such proposals being planned or explored by the County Council as Highway Authority.

Several respondents (i.e. CPRE, Friends of the Earth, Shrewsbury Civic Society) reference the site at Wood Street, Shrewsbury but this was de-allocated prior to the plan being adopted in 2001 due to flooding problems. Hence, the need for a sequential test for potential sites on the grounds of flooding (i.e. Environment Agency) should already have been addressed via the adopted plan in terms of existing brownfield allocations. Other brownfield sites brought forward following the work done on the Urban Capacity Study will be additional to those allocated in the plan, (Mrs C Wright) but will need to be sequentially tested in relation to any floodrisk.

Stoneleigh/Gough Planning both raise issues in relation to housing targets. Both contend that the figures being put forward on the basis of Structure Plan forecasts could be amended upwards, but in view of the primacy of the Structure Plan as a "saved" plan under the new procedures and in the absence of any definitive Regional Planning Guidance (RPG) forecasts pending the approval of the Secretary of State, it is considered inappropriate at this point in time to consider any revision to the figures outlined in the Issues Paper. This may change at the review stages of the LDF as the policies are monitored. Post 2011 there is little or no justification for increasing the build rate for Shrewsbury or for allowing a continuation of Structure Plan rates as the RPG strategy is clearly focussed on regenerating the Major Urban Areas in the West Midlands as oppose to responding to market demands for housing in the Shire Counties. Hence, the 10 year supply figures should be retained pending any revisions to RPG.

On the specific issue as to whether sites allocated for housing purposes in the adopted plan should be carried forward in the plan review, there appears to be mixed views. On the one hand, there is a body of opinion, preferred principally amongst developers /agents that the sites should be de-allocated and should take their chance in future via the submission of individual planning applications in the form of windfalls. This is a logical approach, but would technically take them out of the recommended windfall threshold (i.e. 0.4 hectares or less) and hence would not necessarily be favoured over and above other allocations which are made on brownfield sites in the urban area.

The counter-argument is that the sites should be carried forward in order to take the pressure off releasing other sites, principally greenfield allocations on the periphery of the town. What is evident is the need to review the deliverability of the sites and to assess the prospects of them being fully developed within the remainder of the plan period (i.e. by mid 2006). Interestingly, no responses have been received to this question from the landowner/agents responsible for the sites and in order to seek clarification on the issue of deliverability, letters have been circulated to all relevant parties to request a detailed assessment of when the sites are going to be brought to the market and dwellings constructed.

In order to assess the suitability of continuing with the allocations, it is timely to examine in more detail progress on each of the sites allocated in Policy HS1 of the adopted local plan:-

Site (a) RSH Hospital North, Racecourse Lane (Capacity: 80 dwellings, Area 3.0 hectares)

This site has not been delivered and has not been the subject of any planning applications since the local plan was adopted in June 2001. Since that time, a development brief has been approved by the Borough Council (April 2003) which provides supplementary planning guidance on the future of the site. The brief envisages a mixed use development, but includes the potential conversion of Shelton Hospital for up to 150 residential units and new accommodation for 330 key workers to serve the hospital campus. To date, there has been no progress on any of the elements of the mixed use scheme though the NHS Executive did highlight in 2002 that the Public Private Partnership (PPP) would release its assets to the market over the next 3-5 years (i.e. 2005-2007). An update will be provided at the meeting of any correspondence received.

Site (b) RSH Hospital South, Mytton Oak Road (Capacity 90 dwellings, Area 3.22 hectares)

Similarly, this site has not been delivered and no planning applications have been received. The site was the subject to a development brief prepared and approved as supplementary planning guidance in May 2002. Whilst some decanting of services has been taking place, officers have received uncorroborated accounts that that the site is going to be needed for operational health care purposes, so an update on the deliverability of this site is imperative. Any correspondence received on this issue will be reported to the meeting.

Site (c) Former TA Centre (Riding Stables), Coleham (Capacity: 37 dwellings, Area: 0.36 hectares)

This site is now under construction for 56 sheltered units on behalf of McCarthy and Stone. The development is the result of an appeal decision which was upheld by the First Secretary of State following a refusal in 2001.

Site (d) Eye, Ear and Throat Hospital, Muirvance (Capacity 34 dwellings, Area : 0.26 hectares)

This conversion was completed in 2001 by Shropshire Homes and is now occupied.

Site (e) Ellesmere Road, Railtrack (Capacity : 100 dwellings, Area : 3.88 hectares)

Situated to the west of Ellesmere Road on former railway sidings/goods yard, the site was the subject of a development brief approved in December 1998 as supplementary planning guidance. Regrettably, the site has not been brought forward despite its highly sustainable location and protracted negotiations with what is now Network Rail have failed to determine when the site will be developed. However, it is understood that an outline planning application is due to be submitted very soon. Some assurances have been given that various technical studies in respect of contamination, noise attenuation etc are now complete but the site has yet to be offered to the market. Further information will be provided at the meeting to update on any correspondence received.

Site (f) Ellesmere Road - Rail Property Ltd - Capacity 50 dwellings , Area 1.67 hectares)

Similar to site (e), this site seems to be caught up in the internal bureaucracy of what was formerly British Rail (now SRA). This site was also the subject of a development brief prepared and approved in December 1998 as supplementary planning guidance. The brief proposed a mixed use scheme combining residential and employment with access via Castle Foregate. Situated in a highly sustainable location close to the town centre, the site has obvious advantages despite some limitations created by flooding, and should by now have been offered to the market. It had been expected that following a detailed flood risk assessment of the site that it would be brought to the market last Autumn. However, a further update will be provided at the meeting in the light of any correspondence received.

Site (g) St Michael's Street- British Gas site (Capacity : 88 dwellings, area : 2.5 hectares)

This site has now been fully developed by Wimpeys at a relatively high density (i.e. 35 dwellings/hectare) and has facilitated the release of additional housing land to the north of the site formerly occupied by Oakleys.

Site (h) Spring Gardens - MEB/BT site (capacity : 135 dwellings, area 4.5 hectares)

The site is being assembled by an agent (Pemberstone Ltd) and was the subject of an outline planning application in 2003 for a mixed use development comprising of predominately residential but also commercial/retail uses. It is envisaged that the site capacity will exceed the original 135 and with frontage land not originally identified in the local plan should result in about 200 houses being constructed on the site. The original outline application is still held in abeyance pending the signing of a S106 agreement in relation to such matters as affordable housing, open space etc. This site was also the subject of a development brief prepared and approved in December 1998 as supplementary planning guidance, but implementation has been protracted mainly as a result of British Telecommunications PLC who still have an operational presence on the site in the form of a transport depot. It appears therefore that the redevelopment of the site is stalled pending a relocation of the BT depot, but further information will be provided at the meeting in the light of any correspondence received.

Site (i) St Julians Friars/Town Walls (Capacity 90 dwellings, area : 1.2 hectares)

Following protracted negotiations, this key site is now being redeveloped and should be completed and occupied within the plan period (i.e. before mid 2006).

Site (j) Shelton Rough (Capacity: 17 dwellings, area : 1.7 hectares)

Originally allocated in the 1985 Shrewsbury Urban Area Local Plan, this site has now been developed by Shropshire Homes and is fully occupied.

Site (k) Kendal Road, off Whitchurch Road (Capacity : 25 dwellings, area 0.7 hectares)

The land identified in the adopted local plan provides an adjunct to the residential enclave between Whitchurch Road and Kendal Road adjoining the former MAFF buffer depot. Some re-configuration of the residential proposal has been approved following a detailed application by Morbury Homes (part of Morris Holdings) for 24 dwellings but the approval is pending the signing of a Section 106 Agreement in relation to affordable housing/open space/noise attenuation. It is however anticipated that the scheme will be delivered within the next 12-18 months.

Site (l) Land off Oswell Road, Underdale (Capacity: 20 dwellings, area 0.8 hectares)

A relatively small site in the Underdale Ward, this site is the remaining parcel of a larger allocation identified in the 1985 Shrewsbury Urban Area Local Plan. Planning consent has been granted subject to a Section 106 Agreement, but this has yet to be signed. Further information will be provided at the meeting to advise on any correspondence received on this site.

Site (m) Land off Pelham Road, Upton Magna (Capacity 15 dwellings, area: 2.78 hectares)

Outline planning consent was granted for this site on appeal in 1998 but to date no progress has been made. In order to provide a more sustainable planning framework for what is a relatively large rural housing allocation, a development brief was prepared and approved as supplementary planning guidance in June 2001. The brief proposed an additional 10 affordable housing units to the 15 granted on appeal together with the consideration to add a further phase to the scheme (i.e. post 2006) of another 15 units. The landowners, Sundorne Estates, together with the Parish Plan Committee in Upton Magna are currently deliberating upon a "Poundbury" type approach to the development of the site but as yet no pre-application discussions have been held with officers and no draft proposals have been advanced. An update will be provided at the meeting in the light of any correspondence received from the landowner/agent.

Site (n) Cross Houses Hospital, Cross Houses (Capacity : 25 dwellings, area: 1.0 hectares)

This site is currently being redeveloped by Persimmon Homes for a mixed use scheme involving employment uses, 24 dwellings in the converted main hospital block and 68 new dwellings within the site. It is envisaged that the site will be completed and ready for occupation within the next 12 months.

To summarise the critique, unless correspondence from landowners/agents provides a categoric re-assurance that sites will come forward and be developed before mid 2006, doubts must remain about the deliverability of the following sites within the plan period:

• RSH North - Racecourse Lane

• RSH South - Mytton Oak Road

• Railtrack - Ellesmere Road

• British Rail Property Board - Ellesmere Road

• MEB/BT - Spring Gardens

The total capacity of these sites amounts to 330 dwellings in the adopted local plan which is just over one years supply of housing. The options available to the Council are therefore :

1. To retain the allocations in the plan review;

2. Proactively bring the sites forward using CPO powers;

3. To de-allocate the sites in favour of other uses; or

4. To de-allocate the sites and let them take their chance as "white land", despite the fact that they are all over the recommended windfall threshold of 0.4 hectares.

It is recommended that in order to maximise the delivery of brownfield sites for residential purposes, the local plan allocations be carried forward into the review plan but that they are subject to annual review/monitoring. If they have not been brought to the market during the early stages of the plan review period, the Council should seriously consider invoking its Compulsory Purchase Order (CPO) powers or de-allocate the sites in favour of other uses.

Question 2.3

Should the Plan set a target for brownfield development? If so what should the percentage of brownfield development be?

Officer Response

Whilst there is a wide divergence on what percentage of new housing should be developed on brownfield sites in the Borough, there is a general consensus that the plan review should establish a target. Some respondents qualify their views by requesting that any target figure should be based upon the results of the Urban Capacity Study which is being reported to the Local Plan Advisory Group under a separate agenda item. There is clearly a strong correlation in determining any target figure between what can be achieved via brownfield sites allocations, as evidenced by the Urban Capacity Study, together with robust assessments of windfall allowances on smaller sites. These will to a large extent pre-determine what can realistically be achieved in the Borough prior to considering the scale of greenfield development needed to sustain the levels of housebuilding outlined in the Regional and Structure Plans. A further issue is the need to monitor performance on an annual basis to ensure that targets are being met and there are further linkages to Best Value Performance Indicators, one of which (BVP1 106) measures the performance of local authorities in delivering housing on previously developed sites. As outlined in the Key Issues Paper (July 2003), the Borough Council has achieved a very high rate (ie 73%) of brownfield development during the period 2001-2003 but it is acknowledged that this cannot be realistically sustained during the plan review period and in any event has been too heavily influenced by high rates of windfall development and reflects the low take-up of brownfield site allocations identified in Policy HS1 of the adopted local plan (June 2001). From initial assessments, it is estimated that the percentage figure for 2004 will be in the range of 70% - 75% but again will be heavily biased in favour of non-allocated windfall consents throughout the Borough and is also likely to demonstrate a lower than average housebuilding rate in the Borough compared to previous years.

From the synopsis provided above, it is evident that the following issues need to be addressed:-

1. The non-delivery of allocated brownfield sites in the adopted local plan;

2. The lower than average rate of housebuilding in the Borough;

3. The high rate of windfall development on non-allocated sites;

4. The potential for brownfield site allocations of over 0.4 hectares arising from the results of the Urban Capacity Study; and

5. The contribution that future windfall development on sites of 0.4 hectares or less should make to overall housing requirements in the plan review.

The options arising from (i) are that sites are de-allocated, a question which was raised in the Key Issues Paper (June 2003) under Q 2.2, or that the local planning authority becomes actively involved in using its compulsory purchase powers.

With respect to (ii) the lower than average performance has undoubtedly prompted a more creative and proactive approach to residential development, particularly on brownfield sites, but is not necessarily favouring the large volume housebuilders whose track record or experience of smaller developments may be relatively limited. Again, the non take up of allocated housing sites in the adopted local plan has influenced the delivery of residential units and links back to the issue raised in (i).

On the issue of high rates of windfall development on non-allocated sites in (iii), this is having something of a dual effect. On the one hand, the local planning authority is maximising the development of brownfield sites, thereby reducing pressure on greenfield development, but on the other, there are potential disbenefits in terms of the loss of commercial/employment sites in favour of housing which is at the present time a high value land use. Several areas of the town have now taken on a residential character where once there was a greater balance of mixed uses. With a permissive local plan policy (ie Policy HS2) which advocates potential windfall housing development on all sites up to a threshold of 1 hectare, the opportunities in the urban area of Shrewsbury and indeed in the 'Key' villages has been significant and have been generally difficult to resist on policy grounds. It is therefore timely to consider a more rigorous approach by reducing the windfall threshold to sites of 0.4 hectares or less in line with current Government advice in PPG3: Housing and 'Tapping the Potential' and to make specific allocations as a plan-led approach to sites above this threshold.

This leads on to issue (iv) in respect of the potential for brownfield site allocations on sites over 0.4 hectares arising from the results of the Urban Capacity Study. From a desktop study of the potential sites identified in the Urban capacity study (estimated capacity 10,100 dwellings), a shortlist of 23 sites have been identified as being worthy of more detailed consideration, therefore from the preliminary results, it is recommended that the potential sites identified in Appendix 1, having an estimated capacity of 610-1020 dwellings in total, be investigated as possible site allocations in the local plan review.

The plan also needs to make a realistic and robust allowance for the contribution that windfall sites of less than 0.4 hectares will make to the overall housing requirement during the plan period. In this case it is appropriate to draw on evidence from past rates of windfall development which have been significant and to analyse the contribution made by sites of less than 0.4 hectares. It has been assumed that there will be a potential contribution of 10% from the estimated 5100 dwelling capacity of sites of less than 0.4 hectare identified in the urban capacity study i.e. about 500 over a ten year period. Therefore, in this regard it is recommended that a windfall allowance be made for 50 dwellings per annum on sites of 0.4 hectares or less, which grosses up to 500 for the ten year period 2006-2016.

Finally, the plan review needs to make an allowance for those 5 sites originally allocated in the local plan which have not yet been the subject of detailed planning applications (see Q2.2). On a density range of 30-50 dwellings/hectare, the sites have the potential to deliver 500-800 additional dwellings.

In summary therefore, there is the potential to deliver the following during the plan review period (i.e.2006-2016):

• Brownfield sites in excess of 0.4 hectares : 610 -1020 dwellings

• Brownfield sites (i.e. windfalls) less than 0.4 hectares : 500 dwellings

• Brownfield sites (i.e. unimplemented local plan allocations) : 500-800 dwellings

TOTAL CAPACITY ð 1610-2320 dwellings

With a total housing requirement of 3500 new houses over the plan review period (i.e. 10 years) it is recommended that a minimum of 50% of all new housing be developed on brownfield sites. This should be subject to annual monitoring and review throughout the plan review period with the potential to increase the percentage to further reduce the pressures on greenfield sites within the Borough.

(NB: To view subsequent Report refer to the Urban Capcity Study)

Question 2.4

Should the Plan set a density target to ensure that developers make the best use of land and if so, what level would be appropriate?

Officer response

The general feeling amongst respondents is that setting density targets may be too prescriptive and not take fully into account the particular circumstances prevailing on a variety of sites. This could range from tightly developed areas such as the town centre where densities have been traditionally high to suburban locations where land values have enabled lower net densities with more generous open space/parking/landscaping areas.

Research suggests that densities have been historically lower than the PPG3: Housing requirement of 30-50 dwellings per hectare. Indeed, the averages in the Borough have been less than 30 dwellings/ha in the urban area and only 16 dwellings/ha in the rural area since 1996/97. However, during the last two years, densities have averaged 35 dwellings/hectare in the urban area which probably reflects the high level of brownfield, windfall development in the town where developers have sought to maximise the development value of sites.

In the light of this, it is considered inappropriate to set specific targets, but if pressures are to be reduced on greenfield land, the local planning authority should at least "seek to" achieve higher densities, though it is acknowledged that this will vary from site to site. In this regard, it is recommended that the plan review should include policies which seek to achieve an average of 30 dwellings/hectare in the rural area and 40 dwellings/hectare in the urban area (Including the town centre). This should be a realisable objective, but will be subject to annual monitoring/review. In the case of individual housing allocations, specific density targets may be appropriate which would be assessed against the normal planning criteria of residential amenity, open space, car parking, landscaping, infrastructure, access, etc.RESOLVED:

Pending further reports on the remaining issues highlighted in the Key Issues Paper in respect of housing, it is recommended:

1. That the first bullet point in the housing objectives be replaced by the following:

• To ensure that there is sufficient housing land available during the period 2006-2016 to provide for the number of dwellings forecast in the Shropshire and Telford and Wrekin Structure Plan and in line with the successor strategic requirements set out in the Regional Spatial Strategy (RSS) for the West Midlands.

• To allow for the phased release of housing land in accordance with a sequential approach, subject to annual monitoring and review.

1. That the words 'some of the expected demands arising from outside the Borough' be deleted from the second bullet point.

2. That the fifth bullet point be amended to include 'buildings'.

3. That a new objective be added to read:

4. To locate new housing where it will have minimum environmental impact whilst securing conservation/design/sustainability benefits and respecting the need to build active neighbourhood communities.

5. That in order to maximise the delivery of brownfield sites for residential purposes, the local plan allocations be carried forward into the review plan but that they are subject to annual review/monitoring.

6. That the potential sites derived from the Urban Capacity Study and identified in Appendix 1 of the report, having an estimated capacity of 610-1020 dwellings in total, be investigated as possible site allocations in the local plan review.

7. That a windfall allowance be made for 50 dwellings per annum on sites below 0.4 hectares which grosses up to 500 dwellings for the 10 year period 2006 - 2016.

8. That a minimum of 50% of all new housing be developed on brownfield sites.

9. That the remaining housing objectives are retained subject to consideration of the remaining key issues in respect of housing.

Report of 1st June 2005

Question 2.5

How can the Plan ensure that in achieving higher density development, environmental quality is not compromised?

Officer Response

The issue of development density focuses attention on residential use but affects all forms of development due to over-intensification and town cramming. Therefore, the impact of density on townscape and environmental quality should be addressed through general development principles considering the scale, layout, design and landscaping of proposals in relation to the size, shape, topography and location of development sites especially to consider the design and 'greening' of residential developments in relation to PPG3 Housing (2000). However, the dual emphasis in PPG3 on re-developing brownfield land in preference to greenfield land and the need for efficient use of all residential land raises residential density as a strategic issue for Local Development Frameworks.

PPG3 requires densities of between 30 to 50 dwellings per hectare, the development of mixed communities with a range of house types and sizes and the effective use of sustainable development locations. In addition, it is imperative to make effective use of residential land especially greenfield land where this supplements the brownfield housing land supply. The negotiated delivery of affordable housing in relation to PPG3 and Circular 06/98 will also require the effective use of residential land and so guidance on residential density in the Development Plan Documents of the Local Development Framework should be informed by the strategic affordable housing needs of the borough. PPG3 also advocates a greater intensity of residential development at places with good public transport accessibility (e.g. town centres or public transport corridors) to maximise the benefits of sustainable development locations.

The historical pattern of development since 1996 has delivered relatively low densities with a marked difference between Shrewsbury (average of 30 dws/ha) and the rural Borough (average of 15 dws/ha). However, urban densities are expected to increase with the increase of residential conversions and the emergence of apartment developments especially in the town centre. In the rural area, the more targeted settlement hierarchy of the Borough Local Plan is expected to increase rural densities as developments approved under the adopted local plan are built out.

Therefore, there is the option to seek different densities for residential development across the Borough and to use guidance on residential density in the Development Plan Documents of the Local Development Framework to support other strategic objectives. The Development Plan Documents of the Local Development Framework should consider the isse of residential density in relation to locational considerations (i.e. to maximise opportunities within settlements), the type of land being proposed for development (i.e. to make effective use of land especially greenfield sites) and the need to ensure that the benefits of sustainable locations are fully realised especially through the creation of mixed communities and the delivery of affordable housing.

The Development Plan Documents of the Local Development Framework must also ensure that its strategic objectives protect the historic, landscape and environmental assets of the Borough. These objectives must be supported by development control policies whose principles promote new development that enhances the settlements and rural areas of the Borough and protects the amenities and environmental qualities enjoyed by its residents.

Question 2.6

Should we be considering using brownfield sites for open space uses? Do you have any specific examples?

Officer Response

Identification of the brownfield land resource in the Borough is required by PPG3 to ensure the reuse of urban land and buildings primarily for residential development. However, identification of the location and capacity of brownfield land will also facilitate development for other land uses (e.g. employment, retail, commercial leisure and recreational or open space uses). In considering the use of brownfield land for open space there are two key considerations within national planning guidance. On the one hand, urban capacity studies must seek to identify redevelopment sites from vacant land not previously developed and therefore might identify sites suitable for open space use. On the other hand, PPG17 Planning for Open Space, Sport and Recreation advocates the use of brownfield in preference to greenfield to meet the regeneration needs of the borough. Therefore, brownfield land can be a potential source of open space to supplement the existing provision across the Borough.

In considering opportunities to use brownfield land in this way, the objectives and policies of the Development Plan Documents of the Local Development Framework should take account of three strategic considerations: the local supply of brownfield land to meet their general development requirements, evidence of the need for and supply of open space and recreational facilities and issues relating to the suitability and viability of reclaiming brownfield sites for open space use.

The purpose of identifying the brownfield land resource is to provide a supply of urban land and buildings for residential use as the most sustainable development option. Having satisfied the need for residential development from this source it is desirable to continue to use the brownfield land resource to meet the needs for other forms of development to make effective use of urban land in preference to greenfield land. Therefore, open space use is likely to represent a lower priority when utilising the brownfield land resource except where provision of open space and recreational facilities is secured within a development (e.g. in a residential development).

The use of brownfield land to provide open spaces must also be based on an assessment of the current provision of recreational facilities and open spaces in order to address deficiencies across the Borough. The use of brownfield land for open space will therefore be dependent on suitable brownfield opportunities lying within accessible locations in areas with an identified shortfall in open space. The use of brownfield sites will then be based on the suitability and viability of the land for recreational or open space use. The character of many brownfield sites would challenge their suitability due to: the impacts of previous use (e.g. redundant building cover and ground contamination), their current dereliction and the need for substantial clearance, reclamation and future management and the impacts of flood risks. In particular, the reclamation and management of brownfield sites for open space and recreational use could be restricted on the basis of economic viability especially where extensive measures are required to remove contamination.

These requirements might question the opportunities for bringing forward brownfield sites for open space except through the development process where open space or recreational facilities are proposed within broader development schemes that make more effective use of the brownfield land resource.

Question 2.7

How should the plan promote the development of a range of house types to meet the needs of various sections of the local community?

Officer Response

The responses received generally supported the need for mixed developments with a range of house sizes, types and tenures, including affordable housing to meet local needs. Many respondents accepted the need for policies to be included in the new Plan to promote mixed developments, including specification of the mix in development briefs for allocated sites. There was also general agreement that policies should be based on housing needs assessments and surveys. Some respondents took the view that the private sector market would, on its own, by responding to demand, ensure that a range of house types to meet needs would be provided, and that this was not a matter for planning policy. Agents for developers also held the view, not surprisingly, that larger sites provided the best opportunity to secure a mix of housing.

The reality for the Council, as Local Planning Authority, is that it does need to include policies on housing balance and mix, and these must be based on assessments of need and the current stock, as set out in PPG3 (as being amended) and considering the officer response to Question 2.5. There will be an increasing onus on developers to provide a mix of housing, including affordable housing. The Council has an up to date Housing needs Assessment, with additional information on housing stock being produced. This information is an important part of the Evidence Base for the Development Plan Documents of the Local Development Framework. It will be appropriate for the Core Strategy to flag up the issue of housing mix and to include a related Key Objective and Core Policy.

Question 2.8

Should greenfield development be concentrated in a major extension to Shrewsbury or through a larger number of smaller sites around the edge of the town?

Officer Response

The responses to this question are considered under Question 2.9.

Question 2.9

How should the Plan promote sustainable viable rural communities?

Officer Response

The responses to Questions 2.8 and 2.9 draw out the issues and options relating to future housing development strategy for Shrewsbury and the Borough as a whole:

• Degree of concentration of development in Shrewsbury

• Scope for development in the rural areas and the degree to which this development should then be concentrated in the main villages with existing facilities and services, including good transport links to Shrewsbury, and the degree to which development in the rural areas should be restricted to affordable housing for local needs. Which villages? How much development would be needed to impact on the viability of facilities and services? Need to protect character of villages and parts of the Urban Area from over-development. Possible alternative approach of creating major new or expanded villages on good transport routes;

• Creating/maintaining sustainable communities in the urban and rural areas;

• Prioritisation of housing development to brownfield sites;

• Need for new greenfield sites in Shrewsbury, depending on the overall level of development planned compared to the capacity for development on brownfield sites;

• Merit of spreading any greenfield development required in Shrewsbury between a larger number of smaller sites (capitalising on existing facilities/services/investment, less environmental/landscape impact and easier integration, more diversity of development, more local developers involved) or of concentrating on one or more large developments (enabling provision of infrastructure, co-ordinated development of housing, employment and community facilities, phasing);

• Strategic factors to be considered in assessing development options - e.g. accessibility from A5 and to/from town centre and housing/employment areas, presence of existing facilities/services or scope to provide major new infrastructure, landcape impact and other environmental considerations.

The context for considering these issues is set firstly by national planning guidance, stressing sustainable development and communities, and then by the policies of the Regional Spatial Strategy, which identifies Shrewsbury as a Sub-Regional Focus for development, will set new housing and employment land targets, and will continue to prioritise the use of previously developed land. The policies of the Joint Structure Plan also remain relevant to the extent that they have not been superceded by the Regional Spatial Strategy.

Having regard particularly to the policies of the Regional Spatial Strategy and the Joint Structure Plan, potential Housing Scenarios and related key policy assumptions were explored in the Report of the Planning Policy Manager to LPAG on 13^th December 2004, and summary information from this report was shared with Housing Stakeholders invited to the Workshop held on 27^th January 2005. Relevant information and issues relating to Shrewsbury are highlighted in the draft Statement of Shrewsbury's Sub-Regional Role considered by LPAG on 3^rd February 2005. Key conclusions/recommendations from the meeting on 13^th December 2004 were:

• that a housing target requiring an additional 4,746 additional dwellings from 2004 to 2021 over and above existing commitments of 1,804 dwellings be put forward as the preferred scenario, with an appropriate distribution between Shrewsbury and the rural areas of the Borough to ensure full conformity with the Regional Spatial Strategy. This compared to a scenario based on using current Structure Plan proportions to disaggregate the County housing target which would require a lower target of 3,528 additional dwellings from 2004 to 2021 which, it was considered, would not be high enough to enable Shrewsbury to fulfil its role as a Sub-Regional Focus;

• that an appropriate urban:rural split of new housing development would be 75%:25% (close to the historical pattern, consistent with sustainable development principles and enabling Shrewsbury to fulfil its role). This would translate into 3,560 dwellings in Shrewsbury and 1,186 dwellings in the rural areas over the period 2004 to 2021;

• that the results of the Urban Capacity Study be endorsed, indicating that 3,960 dwellings should be allowed for to come forward for development on brownfield sites between 2001 and 2021 - on a combination of allocated sites and windfall sites - leaving XXX dwellings (to be confirmed) to be found from greenfield sites across the Borough;

• that, consistent with the indications of the Urban Capacity Study, the Core Strategy should set a target of 80% of new housing development to be delivered on brownfield land over the Plan Period;

• that a windfall allowance of 170 dwellings per annum (mainly on brownfield sites) should be accepted, totalling 2,890 dwellings from 2004 to 2021, leaving 2,432 dwellings to be provided for on allocated sites.

These provisional figures illustrate that there are decisions to be taken in terms of overall development strategy, particularly with regard to the housing dimension, both for Shrewsbury and the Borough as a whole. Mindful of the principles of sustainable development and the need for a strategic approach reflecting the policies of the Regional Spatial Strategy and the Joint Structure Plan, the framework for this needs to be provided by the Borough's Settlement Hierarchy. This was a topic considered by LPAG at its meeting on 11^th October 2004, when a Report of the Planning Policy Manager was presented. A Settlement Hierarchy based on the facilities and services present and the size of settlements was considered, with the following categorisation identified as appropriate for use as a cornerstone of spatial strategy of the Development Plan Documents:

• Shrewsbury Urban Area

• Main Service Villages: larger villages (14) having at least 5 of the key facilities/services

• Local Service Villages: smaller villages (18) having at least 2 of the key facilities/services

• Other Villages: small villages (26) having at least 1 of the key facilities/services

The Settlement Hierarchy provides a framework to co-ordinate development policies, with most new development guided to the Urban Area and the larger villages with appropriate facilities and services.

As regards housing development at Shrewsbury, responses received were mixed as to the most appropriate strategy, first of all as to the scale of development and then to the pattern/location of development. However, the Council's Strategy needs to reflect Shrewsbury's role as a Sub-Regional Focus. As discussed at the Housing Issues Stakeholders' Workshop, there is a case, in view of this, for the development rates for the Borough for the 17 year period from 2004 to 2021 to be at least as high as for the previous 17 year period, with the majority located in Shrewsbury - the preferred scenario set out above represents a level of growth 15% above the previous 17 year period, whereas the scenario based on existing Structure Plan proportions would be 6.5% lower. However, there are clearly a range of potential growth options.

The options for pattern/location of development depend on the level of growth and the need for new infrastructure. Having regard to the comments received, the lower impact option, building on existing infrastructure, would be to bring forward a number of smaller sites dispersed around the town (through both allocations and windfall, brownfield and greenfield), provided that this produced a sufficient number of houses. However, higher levels of growth might require and justify opening up new, larger, greenfield areas for development linked to the provision of new infrastucture.

For the rural areas, a structured approach based on settlement hierarchy remains logical and consistent with the aims and policies of the Regional Spatial Strategy and the Joint Structure Plan. The options are more to do with the number of levels identified/categorisation, and then the amount/type of development encouraged at each level, rather than the basic principle. However, the concept of new/major expanded villages has been put forward, which could be seen as an alternative to either development spread between a number of villages or to opening up new, larger areas in Shrewsbury. However, this option does not appear to have support in either the Regional Spatial Strategy or the Joint Structure Plan, which broadly refer to scale of development appropriate to size and role of settlements and supporting services and facilities, rather than major expansions, with the Structure Plan also concerned about the impact of development on the character and setting of villages. The Regional Spatial Strategy specifically states that "it is not envisaged that any new villages will need to be developed" (para.5.17).

For both the urban and the rural areas, housing development can not be seen in isolation, with the need being to promote balanced and sustainable communities. Overall development strategy needs to consider how employment development and the provision/support of facilities, services and infrastructure is to be planned as an integrated approach and as a key part of the spatial strategy for the Borough. Guided by the underlying principles of the Spatial Vision, and having regard to the responses received on the Key Issues and to the Evidence Base being developed for the Local Development Framework, it is proposed to develop a series of potential development strategy options, to be the subject of sustainability appraisal, as part of the process of identifying and developing the Preferred Options of the Core Strategy.

Question 2.10

Are the locational restrictions on residential conversion of rural buildings appropriate?

Officer Response

The consideration of objectives and policies for the redevelopment of rural buildings must be undertaken in the context of national and regional policy that forms the basis of the Development Plan Documents of the Local Development Framework. For the redevelopment of rural buildings this is established primarily by PPS7 Sustainable Development in Rural Areas requiring local authorities to focus most development in or next to existing settlements to create thriving, inclusive and sustainable rural communities and to protect the open countryside except for promoting a diverse and adaptable agricultural economy. This guidance establishes the framework for rural development strategies and is supported locally by Regional Planning Guidance for the West Midlands that requires the Local Development Framework to regard Shrewsbury as a sub-regional focus and the primary development location in the borough.

Therefore, the requirements of national policy for a sustainable pattern of rural development that facilitates the rural economy, the anticipated limits of the regional spatial strategy and development targets and the need for rural residential development to satisfy local needs particularly to provide affordable housing across a range of tenures would limit the opportunities for the Local Development Framework to significantly change the locational restrictions on conversions of rural buildings up to and beyond 2011.

This national and regional guidance should result in the majority of development being located in Shrewsbury (e.g. 75% of future residential development), the identification of a suitable settlement hierarchy to focus rural development on existing settlements to satisfy local needs and to focus rural conversion policies on the needs of the rural economy (and the agricultural economy in particular) as advocated by the SABC Employment Land Study.

RESOLVED:

i The comments and conclusions set out in the Report on more detailed policy issues be noted for consideration in the preparation of the appropriate Development Plan Documents;

ii In particular, that the use of the brownfield land resource, the density of development and the provision of open space should have regard to issues of sustainability in the Development Plan Documents

Report of 11th October 2004

Question 2.11

Should the current threshold of 25 units be reduced?

Officer response

Policy HS8 sets out the current Local Plan policy with regard to seeking an element of affordable housing on residential developments of 25 dwellings/1 hectare or more in Shrewsbury Urban Area. The majority view of those responding is to seek to reduce the current threshold of 25 units before a requirement for affordable housing can be negotiated, though there is a view expressed by some of the housebuilders/agents (Goldfinch Ltd, Gough Planning Services, Kemberton Consulting, Network Rail) that the threshold should not be amended. Other agents, however, (Entec, Taylor Woodrow, Persimmon Homes Ltd) concede that the threshold should be re-examined once the Housing Needs Assessment has been completed and to be in line with new Government guidance, when published. As stated in Section 2, the Government published a consultation paper on a proposed change to PPG3 in 2003 'Influencing the size, type and affordability of housing', which put forward a revised general threshold size of 15 dwellings/0.5 hectares, with scope to justify seeking affordable housing on smaller sites, particularly in rural areas. This issue is considered further below and in sections 4 and 5 of this report, leading to a recommendation that lower thresholds are justified for both urban and rural areas.

Question 2.12

Should sites be delivering more or less than the current 30% affordable housing?

Officer response

There is a general consensus that the 30% target figure in the current Local Plan Policy HS8 is about right, although this is prior to the availability of the evidence contained within the Housing Needs Survey, which is reported later on. Notwithstanding the majority view, there are some views expressed in relation to a "minimum" 30% (Friends of the Earth) or an "average" 30% (CPRE, Mr E Higginbottom, Shrewsbury Civic Society), whilst a number of respondents put forward the case for a higher percentage in the rural areas (including Bomere Heath and District Parish Council, Gough Planning Services, and various individual respondents). Existing Government guidance (the Rural White Paper) already states that in small villages there is no reason why 50% should not be sought, subject to evidence of need and financial viability. These issues are considered further below and in sections 4 and 5 of this report, leading to a recommendation that higher targets are justified for both urban and rural areas.

Question 2.13

What threshold should be established for provision of affordable local needs housing on open market sites within the main villages?

Officer response

Contrary to some of the views expressed in response to Q2.11 and Q2.12 in respect of the Urban Area, the rural context has elicited a strong desire to provide more affordable housing both through the lowering of site thresholds and higher targets, up to as much as 100% on all sites (Gough Planning Services, Mrs H Woodman). The site thresholds advocated in the responses vary in the degree to which they should be reduced, generally in the range of 5-10 dwellings (Bomere Heath and District Parish Council, CPRE, Friends of the Earth, Mr E Higginbottom, Housing and Environmental Strategy Manager, Leighton and Eaton Costantine Parish Council, Severnside Housing, Shrewsbury Housing Forum, Shropshire Homes, Tetlow King Planning, Mr E H Williams).

As outlined in the response to Q2.11 and explored further below in considering the results of the Housing Needs Survey, there is a case for reducing thresholds on the basis of needs as identified in both the Urban and Rural Areas. However, it is clear from the responses that there is strong support for adopting a lower threshold in the rural area and Government guidance already supports this where there is evidence of need (Rural White Paper 2000). The threshold which would be appropriate is considered further below in the context of the potential yield of affordable housing and viability, with there being a case for all sites of two or more dwellings but concerns as to the viability of the smallest sites.

Question 2.14

Should small scale proposals outside of the main villages provide affordable local needs housing on a 1 for 1 basis?

Officer response

To a large extent, the responses to this question follow on from Q2.13 insofar as they relate to the possibility of adopting a 50% quota (i.e. one for one) in the rural area specifically for affordable housing, as encouraged in the Rural White Paper. However, the responses are more circumspect on this potential approach and several (Friends of the Earth, Hope Conservation Trust, Shropshire County Council) refer to the experiences of South Shropshire District Council in their attempts to implement such a policy. The key issues remain potential yield of affordable housing versus viability of development and therefore deliverability. Whilst there is a general consensus on the need for affordable housing in the rural areas, it is accepted that provision by negotiation through the planning system is problematic given the small size of sites coming forward. The issue is explored further below in considering the results of the Housing Needs Survey.

Question 2.15

Should the location of rural exceptions schemes be more flexible? If so, how?

Officer response

Policy HS7 sets out the criteria for rural exceptions sites in the current Local Plan, including that the developments should be immediately adjoining settlements with a development boundary (HS3) or settlements eligible for small scale development under Policy HS4.The responses to the question are mixed, but suggest support for the principle of exceptions sites, particularly within and on the edge of villages, but a recognition that few sites have come forward, suggesting a need for greater flexibility and a more promotional approach. There is an issue that affordable housing should logically be located in /adjoining settlements with facilities and not on isolated rural sites (which may be put forward if greater flexibility is accepted). Balancing this is the problem of the availability of sites in and adjoining such villages, particularly given landowners' "hope values". The consultation draft revision to PPG3: Housing (2003) put forward the concept of allocating sites on the edge of rural settlements exclusively for affordable or local needs housing, as opposed to an "exceptions" policy, which could help to address the problem. This is alluded to in the response from Severnside Housing, but concerns are raised with regard to land values, added to the potential issues arising from single type/tenure developments which do not provide for an appropriate range of size, type, tenure and affordability, contrary to the "balanced housing market" philosophy outlined in the housing objectives of the adopted Local Plan.

It would seem appropriate for there to be some reconsideration of the policy when the revised Government guidance is issued, but otherwise for exceptions sites to continue to be linked to settlements with an appropriate range of facilities and services. The review of the Borough's Settlement Hierarchy, considered elsewhere on the agenda, will be relevant to this issue.

Question 2.16

Should there be a requirement for affordable housing within sheltered housing schemes? If so, what level of provision do you consider is appropriate?

Officer response

With the exception of a number of developers/agents (Goldfinch (Estates) Limited, Kemberton Consulting for Morris Property), the majority view favours the need to address the affordable housing requirements of the elderly in sheltered housing schemes, many of which have been developed in recent years by the private sector. It is accepted that the requirement should always be based on evidence of need, but this issue is addressed in the recently commissioned Housing Needs Survey.

RESOLVED:

It is recommended that the recommendations set out below be noted for further consideration on receipt of the consultant's report on good policy and practice and new Government guidance on securing the provision of affordable housing through the planning system. These draft recommendations should also be aired at the planned Stakeholders' Workshop on housing issues.

1. That the Council aims to maximise the amount of affordable housing that is secured through the planning system;

2. That a target be set of 500 affordable dwellings for the Borough to be achieved over a 5 year period;

3. That threshold site sizes of 15 dwellings/0.5 hectares for Shrewsbury Urban Area and all sites of 2 or more dwellings for villages with appropriate facilities, to be identified through the Settlement Hierarchy, be specified in the Council's affordable housing policy;

4. That an affordable housing target of 50% to be applied to sites above the threshold size be specified in the Council's affordable housing policy;

5. That the affordable housing policies and Supplementary Planning Guidance be clarified with regard to the consistent application of occupancy and needs criteria, and that procedures and practice be tightened to ensure that monitoring and control can be exercised with the aim of securing the benefits of the affordable housing provided beyond the initial occupiers.