September the 3rd, 2009
Rotherham District Civic Society alerts the public of Greasbrough and Wickersley to the threat to greenbelt land.
Letters of correspondence
27th July, 2009.
Mr. Karl Battersby,
Strategic Director, Rotherham Metropolitan Borough Council
As you know, this Society is not normally reluctant to comment on matters of great public concern within the Borough but we are unable at this stage to reach any conclusion on the three "options" set out in the Core Strategy Revised Options document published in May this year. The problem is that the document contains no evidence supporting any of them and inviting the public to choose between them cannot be regarded as serious consultation.
The introduction (Page 1) certainly includes a reference to five background reports providing "more evidence and detail" but it is not realistic to expect members of the public to find and wade through five technical reports within the very short time allowed.
We have a few questions to which we should appreciate answers. For example, with regard to the increase in the housing "requirement" imposed on Rotherham by the Regional Spatial Strategy, there is nothing in the Revised Options document to show how the new figure was reached by the Government or whether it has been challenged by RMBC.
Was the new requirement simply accepted by RMBC without question and then voluntarily increased with the addition of 2,197 more new homes through the new growth point target? What was the nature of the research which led to the addition of the new growth point?
In the first four years of the Regional Spatial Strategy (2004-2008), new homes were built in he Borough at an average annual rate pf only 400 but the revised RSS target provides for 22,285 to be built in the following 18 years at an average annual rate of 1,238, increased to 1,360 through the new growth point target. What measures are proposed to bring about such a massive increase in the output of the building industry?
Where is it assumed that the capital investment will come from? How many of the 24,482 new homes said to be "required" will be "social housing" and how many owner-occupied? Of course, those questions cannot be answered but demonstrate the unwisdom of attempting such precise forecasts.
In reaching the assumed level of need, the Revised Options (Page 4) refer to population growth and immigration without attempting to define either or to distinguish between them although this is of great social importance. What level of immigration is assumed for the purpose of assessing housing need and from where are the immigrants expected to come? Another relevant question, of course, is: how many houses, bungalows and flats in the Borough are currently unoccupied?
With regard to the need for new employment land, the document gives an estimate of 250-300 hectares and asks members of the public whether they agree. Different industries and occupations create vastly different densities of employment and no-one can really predict the amount of land needed in the next 17 years.
The Revised Options document appears to be not only offering an unquestioning acceptance of Government dictatorship but giving up even more of our precious green belt than has been demanded. In the present circumstances, the only course we can adopt is to oppose all the options and reserve the right to comment if and when relevant information is made available.
LDF Core Strategy Revised Options Document
On the 18th July 2009 I sent to you the comments of the Rotherham District Civic Society on the 18 questions posed in the revised options document.
Mindful of the fact that the deadline for responses has been extended, I would wish to supplement the Society's comments by referring to the matter of Strategic Environmental Assessment.
It is possible, with the new focus on sustainability, that sight has been lost of a more fundamental legal requirement that may have a bearing on the successful conclusion of both the Regional Spatial Strategy and the LDF plan making process. In this I specifically refer to Directive 2001/42/EC on the Assessment of the Effects of Certain Plans and Programmes on the Environment, European Union, 2001.
The categories of development requiring a strategic environmental assessment has been a cause for debate over many years, and was certainly raised by local residents in relation to the previously proposed Thorpe Hesley development.
I accordingly enclose for your information a copy of an article, titled 'All at sea?' from the TCPA's July 2009 journal, which outlines the basis of a legal challenge to the 'East of England Plan'. From my reading of the article it appears that by virtue of Article 5 of the European Directive reasonable alternatives to development should be described and evaluated as part of the plan making process. How this applies at the regional level I am not sure, but certainly in the case of the Rotherham LDF it suggests to me that by including Bassingthorpe Farm in all three options, without a reasonable alternative being included, the Council may leave itself open to a legal challenge under the Directive.
The clear implications of the High Court judgement are that another stage is required in the plan making process i.e. to determine whether erosion of the green belt should occur in the first place. This might take the form of determining whether, for instance, more housing should be built at high density in apartment blocks within the inner urban area, or industrial land should be developed at a much higher job density with some industrial allocations being re-allocated to housing. It might also take the form of considering the minimum level of development needed to satisfy projected housing need, as suggested by the Society in its recent response. The permutations are endless but would seem to require some evidence of assessment as part of the process.
I hope that these comments are helpful to you.
Letter to The Rotherham Advertiser
Number of new homes will exceed agreement
Sir—Your report concerning the "Core Strategy Revised Options" (see Advertiser, June 5) produced by Rotherham Borough Council's planners potentially does a disservice to your readers by underplaying what is involved.
The options provide for up to 33,965 homes, of which 70 per cent would be built on green-field land, but this is double the number of new dwellings projected to be "needed" as a result of the natural growth in the number of households and population. Presumably the additional 18,000 housing units is the result of inward migration from Sheffield, the rest of the UK and overseas. The new community at Waverley has been regularly referred to in your newspaper. The highest growth option also provides another 7,000 housing units at Dinnington, nearly 3,000 at Wath and 2,000 at" Wales/Kiveton Park.
All three options provide for over 7,000 more within Rotherham itself, plus another 3,600 in the Basingthorpe Farm area. Although no detailed plan is included, this development appears to extend from Fenton Road, though the Clough and Car Hill, to New Stubbin.
Up to 1,090 hectares of land could be taken out of the borough's green belt.
Essentially, the borqugh council is planning for an increase of between 20 and 25 per cent in the number of homes in the borough over the next 17 years.
The number of new houses is greater than that built in many of the New Towns of the 1950s. A very high standard of town planning skill will be required to ensure that the borough's environ¬mental character and iden¬tity is not destroyed by these developments.
I would urge local people to become involved in this consultation process and make their views known to the borough council's Forward Planning Team.
It will be no use getting involved in a few years' time when a planning application is submitted for the local farmer's field. Then it will be too late; the die will have been cast.
It is also important that our elected councillors are asked to justify why they bid for New Growth Point status when this results in a much higher rate of growth than that agreed during the last round of public consultation less than 18 months ago.
Equally, our three Members of Parliament should be asked to justify why the Government is imposing a scale of new development on the bor¬ough which probably dwarfs anything that has gone before.
Rotherham District Civic Society
Click here for the Masterplan Consultation on Greenbelt.