Shropshire Wildlife Trust Response to Consultation – important read!

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Shropshire Wildlife Trust have submitted an excellent response to the county-wide Preferred Sites consultation, making a strong case for the protection of countryside and green spaces.  It makes powerful reading, highlighting the impact on the county, on Bridgnorth (and all other sites across Shropshire), as well as drawing attention to the serious failings in the Council’s Sustainability Review, where they have ignored several national objectives, and failed to use the correct criteria.  These failings are rather damming given the Government’s focus on improving emissions.

You can download it here as a 6 page PDF: SWT Response to Preferred Sites Consultation

In particular, about Bridgnorth they say:

Bridgnorth Place Plan Area

Again the guidelines reflect the overly high levels [of new houses] that are being suggested for the county.

The encroachment into, and development of, the Green Belt in and around Stanmore Country Park and the extension of the development boundary is of great concern.

We cannot agree with the mixed use allocation P54 (part); P56 (part); P58a; STC002; STC004 (part); STC005; and STC006 or the safeguarded land.

  • The Green Belt release sites will result in either High, Moderate-High or Moderate levels of harm
  • There is a lack of regard of the impact of the Ancient Woodland and it’s setting, (contrary to NPPF, Lawton Review, A Green Future: Our 25 Year Plan to Improve the Environment
  • It is not clear what the “exceptional circumstances” are beyond achieving an unsustainable level of growth.
  • If there are truly exceptional circumstances then there should be far greater detail of the “improvements to the ‘environmental quality and accessibility’ of remaining Green Belt”. This should include a significant buffer area to ancient woodland.
  • Contrary to the aims of sustainable development these sites in the Green Belt would be likely to produce communities that would be heavily reliant on car travel. See our comments regarding issues with the Sustainability Appraisals.
  • The country park has been managed for over 20 years, with input from the local community and provides a site much valued by the people of Bridgnorth for its wildlife interest.

Also, the SWT emphasise:

Local Green Space

The NPPF states that communities should have the opportunity to designate Local Green Space through both local and neighbourhood plans. The current Shropshire approach to only consider this in Neighbourhood Planning removes this opportunity from the vast majority of Shropshire and in particular from Shrewsbury itself which is likely to see the greatest level of growth and where the value of the green network (including the sites within it) has been recognised within, and is seen as an important component of, the Big Town Plan.

As the NPPF states that “Local Green Spaces should only be designated when a plan is prepared or updated” we would like to see subsequent consultations include a request for sites that communities feel might meet the criteria.

Sustainability Appraisals

The Sustainability Appraisals appear to have a number of failings. Not all the initial objectives appear to be translated into the criteria used for assessment and even then one of the criteria relating to public transport does not appear to have been applied. Surely the omission of:

  • Encouraging the use of sustainable means of transport
  • Reducing the need of people to travel by car
  • Reducing carbon dioxide emissions

is a major flaw.

Given the role green space and infrastructure can play in providing sustainable transport networks, carbon capture, etc. this also has an impact on how proposed developments may impact or enhance ecological networks.

We also note that some preferred sites were apparently promoted after the SAs were completed and have still been included with a caveat that a SA will be undertaken at a later date. This does not allow for a fair assessment of the sites by those wishing to respond to the current consultation.

Mapping of Environmental Assets

The revised NPPF (para 174) requires that plans should:

  1. Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and
  2. promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity.

We do not feel that the Environmental Network map in the current Local Plan is adequate and there appears to be no process for measuring the net gains for biodiversity at a meaningful level.

There is also no evidence that the existing Environmental Network map has informed the selection of sites as ‘core areas’, ‘buffers’ and ‘corridors’ are all included with often no reference to them in the site guidelines.

Master planning

We would like further clarity on how master planning of a number of the allocated sites is envisaged. Given the apparent limitations of the sustainability assessments and use of environmental mapping our concern is that the sites once allocated will not be adequately guided by master plans. They will have gathered a certain momentum and expectation for delivery of housing numbers.

Our experience from the current and previous plans has been that many ecological elements are reduced or omitted altogether as developments progress through the system.

Level of public participation

It is very evident that only a very small proportion of the population are aware of the consultation and many of those that are find the process very hard to participate in. We appreciate that it is hard to engage people in these consultations and to adequately explain the process but more needs to be done if the results are expected to truly reflect public opinion.

Failure to address this will result in further lack of confidence in the planning system.