They make in particular four recommendations (below).
Sir Michael Spicer and Harriett Baldwin today said,
"At the root of our criticism lies the fact that we believe that housing targets should be set locally, by the District Council as advised by the Parishes, and not by an unrepresentative Regional Assembly."
Spicer/Baldwin's response to region's housing targets
Recommendation 1 - involve the parish and town councils directly in the consultation process.
The Regional Spatial Strategy is driven by Gordon Brown's top-down approach to developing housing targets and this does not help build support in the communities themselves for housing targets that can sound very large. A better approach would be to work from the bottom up and ask all of the parish and town councils for their housing needs as reflected in their parish plans and this would make the whole process more acceptable to the communities. Most of our communities welcome some growth; many villages have primary schools that are not currently at capacity and all communities express a desire to see more affordable housing to accommodate the desire of young people to remain within the communities where they grew up.
Recommendation 2 - use much longer term average historic periods to project forward the population growth for the region.
The Housing Demand Paper from the West Midlands Regional Assembly bases the population growth for the region on an estimate of net inward migration of 11,000 per annum. In fact Figure 1 in Section 2.19 of the earlier consultation shows that this high level of international inward migration has only occurred since 2001. This reflects the enlargement of the EU and the current government policy towards migration. The Regional Spatial Strategy projects this level forwards to 2026. All projections are subject to the quality of the underlying assumptions, but a more reasonable length of time to use for such a long term projection might be the average level of the last 13 years in Figure 1, which is 6,000 per annum, or approximately half of your underlying assumptions.
Over the last ten years, Malvern Hills District Council area has accommodated approximately 2,500 new homes. This rate of growth, if extrapolated forward until 2026, is entirely consistent with a housing allocation for Malvern Hills District Council of 4,900 homes. It is also possible to build almost 90% of these homes on previously developed land. We are supportive of this level of projected building in the District, provided the infrastructure is available to support it. We strongly object to the recent suggestion from the WMRA that 3,650 homes from the City of Worcester Allocation should be built in Malvern Hills, as this will mean that only 52% of homes will be able to be built on previously developed land and we will lose 135 hectares of green field land.
The West Worcestershire constituency also contains five wards from Wychavon - Bredon, South Bredon Hill, Elmley Castle and the Combertons and Pershore. Only in Pershore and Bredon is there any real opportunity for new housing. The relevant Town Council and Parish Council should be consulted on this.
Recommendation 3 - the infrastructure is already over capacity and this needs to be addressed before growth can occur.
Very little growth can be accommodated in West Worcestershire without addressing infrastructure "pinch points". West Worcestershire's main population centre is Malvern. It is a potential strategic employment growth site in the report and Qinetiq is an important employer in an international context. However, access to Malvern is constrained by the limited number of crossing points on the River Severn and the report from the South Worcestershire Councils highlights this. Any growth needs to be predicated on improved access to the Western part of the County, particularly an additional crossing of the River Severn needs to be considered. The Southern by-pass is often congested and urgently needs to be "duelled".
The local Acute hospital is in Worcester, and this is often operating at capacity. This needs to be addressed in the strategy.
A new hospital in Malvern is also urgently needed to take some pressure of the Worcester Royal. Pershore and Tenbury Wells are well served by their community hospitals.
Tenbury High School and the Chantry have no Sixth Form provision and rely on capacity in Worcester and Ludlow. More Sixth Form capacity is needed.
Recommendation 4 - rural areas will never be able to enjoy fast and efficient public transport without significant investment in the railway network.
Rural West Worcestershire is completely reliant on the car. Car sharing and lift sharing schemes operate on an informal basis, but the County Council scheme is not used extensively. The only train service in the constituency is the line from Pershore to Worcester and Malvern. This service suffers from unreliability, largely due to the need to double the track through the Cotswolds. Before the Beeching cuts there was a railway line from Bewdley to Tenbury; from Worcester to Bromyard; from Tewkesbury to Malvern. If you are serious about public transport infrastructure that reduces dependence on the car, we should be investing in reopening these branch lines, many of which are still in existence.