Oswestry and District Civic Society

Civic Society news July 2020

20/02058/EIA | Use of land part of existing golf course as a static holiday caravan site with associated roads, drainage and ancillary works | Henlle Park Golf Club Henlle Gobowen Shropshire

Special Award

Oswestry Cemetery

For the new remembrance garden recently commissioned by the Town Council and for the cataloguing of all the graves in the cemetery.

Special Award

Knockin and Kinnerley Cricket Club

For the breadth and diversity of the activities of the club, and for the wide range of voluntary effort.

Milicent Kaye

Sundays in the Park – Neil Phillips and Oswestry Town Council

Like the chicken and the egg history does not remember which came first, Neil Phillips and his Sunday Music in the Park events or the Town Council organised Brass and Silver Band concerts. However they, with the relatively new addition of the international community celebrations (Bulgarian, Bangladeshi), add an excellent new dimension to the life of the town’s park.

These events are inclusive, friendly, and fun. They celebrate popular and foreign cultures in the generous and elegant environment of Cae Glas.

Mayor’s Shield

Shop in Castle Street

An imaginative but low cost improvement of a shop on the outskirts of the Town Centre. Works like this add to the distinctiveness of the area.

Mary Hignet Award

Mrs Barbara Molesworth

Barbara has developed two fantastic gardens, both on Daisy Lane, Whittington. The first house she bought with her husband over forty years ago and then eight years ago she built her own house on some adjacent land. Working closely with her architect Melvin Gough and tradespeople she has created a simple home with a generous multi-faceted garden.

This garden is a small wonder, when the Assessors visited it was full of butterflies, insects and birds. It is also the nursery for many local gardeners who buy her excellent plants for sale most Wednesdays at the Country Market in the Memorial Hall. Last but not least Barbara opens her Gardens for one weekend each year to raise money for Save the Children and a local charity. This she has done for over 20 years and has quietly raised many thousands of pounds.

Highly Commended

Perry Cottage, Rednal

An intriguing and innovative modern house that has been built with a simple and ambitious architectural plan. A house that is both very private and also embraces the nature around it. One of the best executed modern houses in the area.

Highly Commended

Old Five Bells Pub, Willow Street, Oswestry

The refurbishment and development of this Victorian pub building in the town centre has been done to a high standard where some profit has been forgone for both presentation and build quality.

The Assessors saw this project as a good re-working of a decent building in the town that will improve the town centre’s density.

Full Award

High Barn, Ty Draw, Nant Mawr

A sensitive and high quality restoration of an old stone and brick farm building. What impressed the Assessors was both the attention to detail that the owners have ensured but also the level of craftsmanship applied throughout the whole building. The creation of a very spacious and well worked home from a redundant agricultural building is an exemplar for others to follow.

Details of particularly high quality are: the random slating of the roof; the retention of the original beams and trusses; internal plastering and use of appropriate materials.

Commendation

St David’s Church, Welsh Walls, Oswestry

The church of St David’s is a curious and interesting building built as a Welsh speaking Anglican church by the St Oswald’s parish church in the late nineteenth century. It tells us of the resurgence of the Welsh language and a rising Welsh identity; and our town’s place at the cross roads between England and Wales.

By 2000 the building was becoming dilapidated. The owners have both saved it and converted it into a very fine holiday destination.

The society recognises the work done for the restoration of this building and for creating a high quality destination for people to come to Oswestry and support the economy of the town.

Commendation

The Unicorn Nursery – Maesbury School

The Assessors considered that the building had been sensitively refurbished, retaining original window design. New additions for the purpose of the site were appropriate, restrained, and in tune with the character of the building and its site.

The Assessors were impressed that the large oak tree on the boundary of the site had been carefully treated, retaining its spreading lower branches.

Oswestry and District Civic Society

The Unicorn Nursery – Maesbury School

The Assessors considered that the building had been sensitively refurbished, retaining original window design. New additions for the purpose of the site were appropriate, restrained, and in tune with the character of the building and its site.

The Assessors were impressed that the large oak tree on the boundary of the site had been carefully treated, retaining its spreading lower branches.

Summary

The plan cannot be considered to be sound for the following reasons:-

The strategic decision to locate some 27% of all residential development within the rural settlements under the “Hubs and Clusters” policy is

• inconsistent with the zero carbon spatial vision set for the County, and 
• is inconsistent with policy SP3 which purports to support the transition to a low carbon economy.  

This objection demonstrates that rural development will:

• lead to some 9 times more travel than development located in a key centre; 
• cannot be realistically served by public transport; 
• and cannot favour active means of travel, 

all of which fail to meet requirements of policy SP3.  

It has been demonstrated that the Sustainability Appraisal on which the strategy rests lacks credibility due to poor professional quality 

The aspirations of the rural development policies are not supported by any clear evidence.

There are preferable means of meeting the needs for development land.

Introduction

1. The Oswestry and District Civic Society has made a consistent objection to the strategy on which the local plan has been based.  In brief, it is the Society’s view that so far as it seeks to locate residential development in rural settlements, it fails to meet policies requiring reductions in carbon emissions.  Detailed support for this can be found in the submissions made at the consultation on strategy, and in the submissions made to the preferred sites, which are appended.
2. For the area in which it is interested, the Society contends that some 400 to 500 dwellings proposed in the plan would be located where their accessibility to employment and frequently accessed major service locations could not be reasonably expected to be undertaken by public transport, and therefore the development pattern encourages the use of the private car, and delivery patterns which fail to minimize carbon emissions.
3. Furthermore, by application of the Council’s own growth projections, the Society has demonstrated that, in principle, it would be possible to plan within the A5 strategic corridor for a modern settlement in which the major local employers and residential areas were linked together by attractive high frequency, economic and low carbon public transport services, and that this would be a sustainable means of accommodating all the development proposed in villages, with little adverse effects on rural settlements.
4. It is a matter of regret that the planning authority have consistently failed to give this matter serious consideration stating that they have a preference for an incremental approach to planning – that is, field by field, with no strategic aim or vision for this strategic corridor.

Submission as to the Reg. 18 Draft

1. The plan as developed previously simply set out to carry forward policies for the allocation of land.  It is a highly welcome and overdue development that the Plan now brings in a suite of strategic policies, in particular those which respond to the Climate Emergency, Shropshire’s response to which is detailed in para 4.114 of the plan. Policy SP3 sets out a strategic approach to climate change.  The Civic Society has been pointing to the need for such policies to be at the foundation of local planning during the whole period of development of this plan, and before. 
2. Previous submissions made during consultation on this plan showed that:

1. Strategies which allow for more rural development than necessary to meet local need to serve local employment do not comply with policies requiring development to be sustainable.
2. All options in the draft Strategy imply significant development in rural areas, beyond that required to meet local need, and are therefore all contrary to Government Policy, and cannot be supported.

1. The Government Policies referred to were those which required planning to respond to the threat posed by Climate Change.  Those policies are now included as strategic policy SP3 in the plan.  It follows that the plan is now internally inconsistent, and therefore cannot be judged to be “sound”.

 Further Details – 1 Sustainability Appraisal

1. In relation to development outside urban areas, the Society concluded:

1. that the Sustainability Appraisal is of very poor quality, and cannot be taken to support the Strategy it purports to appraise; 
2. that development in Hubs and Clusters has not been shown by any evidence to be sustainable; 
3. and further, what evidence there is shows that development in these rural settlements is unsustainable.

1. The principal failings of the Sustainability Appraisal are:

1. That it fails to compare carbon emissions between available sites;
2. That it takes an absolute approach, asking the question “does development of this site meet the threshold for sustainability as defined by the chosen measures”, rather than asking the question “would development of this site be more sustainable than others”, such that the cumulative result of all development would provide the most sustainable overall development pattern.
3. That in important respects, notably the efficiency of public transport as a competitive alternative to the private car; and the societal conditions offered to households and members of households without access to a private car, the appraisal fails to make a realistic assessment.

Further Details 2 – Zero Carbon

• The Sustainability Appraisal considers that a site which is within walking distance of a peak hour bus service has an appropriate degree of access to be sustainable.  The plan now states that communities will be safe and healthy as Shropshire moves positively towards a zero carbon economy; all residents will be able to access well-designed, decent and affordable homes in the right location.  To achieve this Policy SP3 requires that development should be reducing carbon emissions by 1. a. Minimising the need to travel and maximising the ability to make trips by sustainable modes of transport, It follows that for a home to be in “the right location” it must meet these two policy requirements.

Minimising the need for travel

1. The policy requires that the need to travel should be minimised.  Much of that must derive from the location of development, and its accessibility to frequently visited  destinations – workplaces, shopping, schools. Whilst there is little information as to workplaces, local knowledge allows broad estimation of location of shopping, education, service and socializing areas between development located in the Hubs and Clusters around Oswestry, and development located in the core of Oswestry. 
2. From the National Travel survey it can be seen that over a year, a person will make, on average 536 trips, of which 35% are for shopping purposes, 27% commuting, 5% on business, 17% for personal business (eg visiting service providers) and 15% socializing. Taking as an example the site designated as a sustainable urban extension, and comparing it with those rural sites which are not seen as being of neutral effect  it is demonstrable that rural development increases the overall amount of travel per household.
3. These factors are tabulated in Annex A.   Whilst there must be a significant range in the estimates provided, this analysis shows that development in the hubs and clusters is not of small impact in its conflict with Policy S3.  For the factors analyzed, which account for nearly 70% of household travel, a household in a rural area is likely to produce around 9 times the amount of travel than one located in Oswestry itself.  The 564 dwellings proposed in the rural areas surrounding Oswestry are likely to lead to over 6 times the amount of travel than the 800 dwellings proposed to be located in the SUE.  This is not a minimal conflict with policy, it is a stark illustration of the failure of the planning authority to appreciate the impact of a policy of “rural rebalance” which has never been closely analysed for its benefits, and for which the only justification in this plan is a Sustainability Appraisal of dubious professional quality, which in the most part is not based upon any actual evidence.

Maximising the use of sustainable transport

1. Then the policy requires that the ability to make trips by sustainable means of transport should be maximized.  It must be recognized that a household will generate trips at all times of the day for a variety of purposes.  Sustainable means of transport encompass bus, cycling and walking, and for longer distances rail.

Bus

1. It will be seen from the settlement analysis which accompanied the objection to the preferred sites consultation that most minor hubs and clusters were served by a single 

route providing a single bus in the peak hour in each direction, with services stopping early in the evening.  In common with the rest of the country, rural services have been in decline, and there is little being done in Shropshire to stem the decline.

1. Services from community hubs show an inability to serve the employment centres in Oswestry, Shrewsbury and Wrexham.  As examples, take the hub villages of Kinnerley and Knockin, West Felton, and Weston Rhyn.  

1. These services suffer in competition with car based modes:
   1.  impossible for many destinations away from the routes themselves, 
   2. In most cases are slow, and in all cases will be slower when terminal connections are taken into account;
   3. Are costly, even taking into account terminal car parking costs.
   4. Do not permit flexibility in working hours.
2.  In any locality outside major urban areas it is difficult for public transport to provide services to scattered workplaces.  For more centrally located services such as shopping and secondary education, which may constitute up to 50% of all household trips, public transport can be a far more effective mode.  But this can only happen if dwellings are located close to frequent and short public transport routes, as can be achieved within an urban area.  Oswestry has a reasonable range of “town” services, which enable access to the town centre and main supermarkets.  These tend to run on a 30 minute frequency.  Because of the short distances involved there is a far better prospect of these services providing an effective means of transport, particularly if development is further concentrated in the town.
3. Every dwelling located in the rural areas has little chance of being served by effective bus services for shopping trips, and where school bus services cannot penetrate, car journeys are the likely alternative.  The average distance for rural sites proposed in the plan for weekly shopping trips to supermarkets in Oswestry is of the order of 9km; and to secondary schools  the same.  By contrast, the distance from the centre of the major housing site in Oswestry, the aptly named Sustainable Urban Extension (SUE) is 0.5 km to a major supermarket, and 2 km to the secondary school.

Cycling

1. A core planning policy of the NPPF, and Government cycling policy requires patterns of growth to be actively managed to make “the fullest possible use of…cycling”.   The Plan’s Policy SP3 1.d requires the Prioritising (of) use of active travel through the creation and enhancement of walking and cycling links within and between new developments and from new developments to existing neighbourhoods and community facilities 

1.  The majority of cycling trips are for short distances, with 80% being less than five miles and with 40% being less than two miles. In 2013, 109 cyclists were killed in Great Britain, representing 6% of road deaths that year, a higher proportion than their modal share of 2%. Cyclists also accounted for 14.5% of seriously injured road casualties in 2013.  It follows that to make the fullest possible use of cycling the active management of patterns of growth must enable the provision of safe facilities, and short distances.  The pattern of growth locating a high proportion of new dwellings in rural areas fails to do this.  In fact it actively works against cycle use, due to distance, the dangerous nature of the A5 and A483 for cycling, and the absence of good quality cycle ways.  Many routes involve gradients which militate against the use of the bicycle.
2. These policies cannot be fulfilled for a quarter of the additional population under the plan’s proposals.  Once again, the plan is inconsistent internally. Conversely, the Society’s proposals for the A5 corridor are ideally suited to the provision of cycle communications, with short distances over level topography.  

Walking 

1. The NPPF a nd Policy SP3 likewise require active management of growth patterns to favour walking.  There is no possibility of developing walking as a means of communication when development takes place in isolated small communities.  It is true that walking as a rural recreation is fostered by such organisations as Parish Paths partnerships, but this does not depend upon new development, and walking for recreation is equally available to residents of development located in Oswestry.
2. Car ownership in Shropshire is high, but that does not mean that every person has a car available.  In the rural areas those without a car can be isolated and dependent upon others – such as the community car schemes operated under Shropshire Council’s auspices.  For those without a car, a home in a rural village is unlikely to be in “the right location”.
3. There are further disadvantages to the location of additional residential development in urban areas so far as the satisfaction of this policy is concerned.  Whilst villages do offer social facilities which are supported by existing rural development, the towns provide a wider range, particularly for the young.  For this section of society, there is greater attraction to be found in the towns, where more sophisticated leisure facilities will be found.  Rural development will lead either to these facilities being denied to young people, with attendant social cost, or lead to parental “taxi” services, again running counter to the intentions of policy S3.

Purported benefits of Hubs and Clusters

1. The Strategic Approach, set out in Policy SP2 states: Recognising the rurality of much of Shropshire and the importance of ensuring the long-term sustainability of rural communities, growth in urban areas will be complemented by appropriate new development within Community Hubs, which are considered significant rural service centres; and to a lesser extent Community Clusters, which consist of settlements with aspirations to maintain or enhance their sustainability.
2. The policy of seeking to ensure long term sustainability of rural communities has been in operation since the adoption of the Core Strategy (2011), at least.  Any observer can see that it has turned many villages into dormitory settlements. Whilst sustainability in terms of retention of services may have been enhanced, there has been no systematic gathering of evidence to demonstrate that these policy aspirations have been achieved. Nothing underpins the necessity to carry this policy in to the future beyond political whim.  
3. On the other hand, this evidence given in this submission shows that there are severe adverse sustainability characteristics attaching to the policy.

An alternative approach

1. The Society therefore concludes that the development pattern proposed by the draft plan fails to meet the strategic policies set in the plan in recognition of the climate emergency, and Government policies having the same thrust.
2. The Society has been making these points to the planning authority since the local plan review was initiated.  In order to make a positive approach to these concerns it made a public presentation on the need for long term planning in the A5 corridor to respond to the climate emergency.  It demonstrated that the same rate of provision for residential development, if better located could tie the whole are together in a manner which favoured service by modern guided public transport pods of the type now being supported by Government as demonstration projects.
3. This approach has the formal support of the two major local councils, Oswestry Town and Selattyn and Gobowen. 
4. Unfortunately, the Planning Authority has not given this approach any credence, their only response to the Society being by a portfolio holder that the Council preferred incremental planning to a long term strategic approach, a view not dissented from by senior officers at the time.

Conclusion 

1. The Society submits that the above evidence is a clear demonstration that the policies within the plan for rural settlement are contrary to the aims of the plan and to its strategic policies, in so far as they purport to respond to the climate emergency.  Furthermore the Society has demonstrated that the development and transport needs of the A5 Corridor could be satisfied in a manner which would greatly further the policy requirements of Policy S3. 
2. The analysis presented in this submission would, if applied to the county as a whole, demonstrate that most rural development is not sustainable, and would not comply with Policy S3.
3. In the view of the Society, the plan is not sound, and should not be taken further until a development pattern can be proposed which is compatible with the “positive move towards a zero carbon economy”.

David Ward

September 2020

Annex A

Relative amounts of travel comparing Oswestry Sustainable Urban Extension and sites located in surrounding settlements.

This table makes estimates of travel for all purposes except commuting and business.  It therefore refers to 68% of the travel propensity of an average household.

Factors have been applied to give an estimate of trip numbers per household: 

S = 536 x 0.35 (from the NTS) x 0.5 ( that is half shopping trips to neighbourhood shop, half to main supermarket and town centre shops) x 2 (approx. average household occupancy) = 187.6

E = 175 (no of school days pa)x 0.18 (% households having 10-19 year old –from ONS)=31.5

0 = 536 x (.17 +.15) (From NTS)x 0.5 (that is half of all service and personal trips made elsewhere than Oswestry)x 2(approx. hh occupancy)  = 171.5

A Vision and Plan for a Sustainable Future

A Neighbourhood Plan for Oswestry:

https://docs.google.com/presentation/d/1aUZeAJEG-ERHO90U-dvbQGhX5bkzM2_P/edit?usp=share_link&ouid=117313634966030126336&rtpof=true&sd=true

https://docs.google.com/document/d/1H9JqIl7A-mwTspeSwdgj0ATeSU2wqu_H/edit?usp=share_link&ouid=117313634966030126336&rtpof=true&sd=true