Other Comments

Issue: Open space

68. I welcome that there is a 'Retained green open space (RGOS)' between and Lowertown. Please can you tell me what this means and what protection this gives against residential planning applications on this land. A recent planning application PA12/7435 - land adjacent to Granite Court was refused. Is this land now legally protected against development? As a Lowertown resident, I am very concerned that that Helston should not spread further north. Officer response: The comments received concerning the retained open space and I can advise that although the land will not be legally protected, the framework is a tool that can be used by planning officers to help inform them when determining planning applications. Action: Ensure comments are relayed back to steering group for Helston Town Framework.

Issue: Transportation

20. Helston needs a green transport strategy! Compared to other Cornish towns Helston appears not to suffer from congestion. Road improvements should therefore not be a priority in the short term. The aim should be in improving access to the town centre with the emphasis on bus/cycling/walking in order to reduce congestion, pollution, energy use and noise. 29. There are no plans either for additional roads to relieve the already congested traffic. 34. The overwhelming need is for an improved B3297 road. At present all road traffic heading down the A30 towards Helston has to go either through or through , both choices creating congestion and frustration. Improvements to B3297 do not need to be major, just enough to enable two wide vehicles to pass without needing to stop or reverse, plus a new piece of road linking to the A30 without going through a built-up area. This upgrade would, I submit, be by far the biggest single contribution to the future prosperity of the town of Helston and its surrounding area. It would repay its cost many times 58. Already priced and designed by Highways [ref. Peter Tatlow] Residents of Cross St have demanded that Penhellaz Hill is closed to through traffic excepting emergency vehicles, cyclists, horses and Pedestrians. The ward County Councillor and Town Council are in receipt of a petition supported by local residents.[over 50 signatures] using Penhellaz Hill , Cross St and Church Hill to access the A394 Road. On street parking is already in short supply. This affecting commerce. U4 is one of the last remaining open spaces and should be retained as such. The access road appears to be un - adopted. There may indeed be no vehicular right of way. Consideration be given to an “A394 – B3297 – Trewennack” link road to reduce all traffic on the through town routes permanently. Current one way system in Godolphin Road /Wendron St appears to not only cut off the town centre from its large population centres in the east of the town but also renders it difficult for fast emergency response to the town centre from the east , the Police station is trapped in a one way system ,the fire station also has an extended route , as inevitably do ambulances. The current system also makes the bottom of Wendron St very noisy and polluted with vehicles straining to get up the hill, surely it’s better to work with gravity than against it! I would propose two way traffic from Turnpike to Cades Pk and a reversal of traffic flow in Wendron St., this would eliminate much of the noise and pollution which currently makes Wendron St an unpleasant place to shop or walk. Obviously this would necessitate Coinagehall St becoming primarily one way “down hill” which would also allow for space to create proper bus stops, herringbone parking and introduce more on street short stay commercially friendly free parking. Opportunity for an archeological inspection of the site of the Chapel of our Lady ,gaol and the Duchy Officers House which once stood in the middle of Coinagehall St near the junction with Lady St. Perhaps even eventually using this site for the creation of a public transport hub site etc. Construction of access slip roads on the A30 to create a junction with the B3302 Mellanear Rd or Wheal Alfred Rd at which would finally create a viable road route to/from Helston and The Lizard as well as removing traffic which currently has to access the district by routes through Truro, Redruth, and Hayle, benefiting all four towns. Some further upgrades to the Hayle – Helston route would be inevitable. This could be a HGV preferred route into the area for commercial and airport access. There is also a substantial area of derelict land at the rear of Penview Crescent , currently brownfield derelict garages , this should be identified as a potential development site, it has good vehicle access To Penview Cres.and also good pedestrian access to Meneage St. I spoke to Matthew Brown at the Helston Framework meeting day at Helston One stop shop. 59. Improved links to the A30 are urgently required. The Redruth- Helston road is seriously inadequate for use by heavy vehicles. Officer response: Comments noted; in respect of concerns relating to transportation, work is currently underway on the transport modelling for Helston and accordingly these comments will be fed through that process. This work will lead to the development of a Transport Strategy for the town, to compliment the Town Framework. However, it is very unlikely that significant new/improved links to the A30 could be created due to the scale of costs that such works are likely to generate, without any known funding streams Action: Relay comments back to Transportation.

Issue: Town Centre

20. I agree that re-vitalising the town centre must be the No.1 priority. The role of Town Centre Manager is key to this. Recent schemes/events and publications to draw ordinary Helstonians the short distance into town do work, please keep it up! Can we please charge out of town retailers the 'correct' rates? Officer response: Comments noted. Action: Ensure comments are relayed back to steering group.

Issue: Heat Mapping Assessment

20. The Urban Extension Assessment Report states that 'it was not deemed necessary or essential that the Heat Mapping Assessment would form part of the Helston Town Framework.' I strongly disagree; this omission is a grave misjudgement and contradicts the reports aims for objective assessment. This is an essential first step if Helston is to contribute to council’s targets for future reductions in fuel and energy use and the expansion of renewable energy generation. Officer response: Comments noted. Action: Ensure that comments are relayed to relevant managers.

Issue: Sustainability Appraisal

20. There is no evidence or information in the Urban Extension Assessment Report that this has been undertaken. This is required by legislation and it is disappointing that this has been side stepped at consultation stage. Officer response: Comment noted; however, a Sustainability Appraisal has been undertaken as part of the Town Framework process. . Action: Ensure that the Sustainability Appraisal is made publicly accessible.

Issue: Housing

The number of 900 new homes seems excessive for the size of the town as at present there are no plans for sufficient extra school places that are bound to be needed. Also there are no plans either for additional roads to relieve the already congested traffic. 34. If 625 families currently need affordable homes, increasing at 60 families per year, the need will have risen to 1825 families over 20 years. Taking the maximum figures proposed, 900 houses in Helston and another 900 in the Lizard Community Area and assuming that as many as half of these will be affordable, we shall still have 925 families needing homes in 2030. In other words, we shall have planned for our housing situation to get 50% worse over 20 years. This is intolerable and must not be allowed to happen. I propose 900 houses in Helston with 50% affordable and 1200 houses in the Community Area with 80% affordable. Even this arithmetic means we shall only reduce the need for affordable homes from 625 families to 415 over 20 years, but at least it’s heading in the right direction. And it would help many of the smaller villages remain viable with their own primary schools, post offices, etc. 59. It must be doubtful whether continuing to build so many more houses is really sustainable or desirable especially in times of recession. It will inevitably lead to overstretched infrastructure and to social and employment problems, as well as changing the over-all character of the town. However, the sites identified for housing in the framework following your careful analysis of the available options are clearly the best and most logical locations.

Officer response: Comments noted; those comments will be fed back to the Local Plan Team whom deals with the projected levels of growth for the twenty year plan (20-10-2030). Action: Relay comments back to Local Plan Team.

Issue: Education

29. A fourth junior school is badly needed already and a small provision of just 60 extra places each at St Michaels and Nansloe School seems like a drop in the ocean compared to what maybe needed if Helston's population is to be increased by 2-3000 people in the next few years. Most people buying these new houses are likely to be young families and young couples. The main Helston Secondary School already wants to expand and pupils from the surrounding area come there as well as Helston pupils. Using land from the existing school site for housing and developing an alternative site for a new school in an area which could reduce traffic congestion through the town may be an option. At least one of these HX areas could be used as a further green open space for public use instead of 3 more high density developments. 59. Education: The proposed levels of house building will probably require more new school places than indicated. Officer response: Comments are noted. The scale of growth proposed, 2-3000, is above our predictions; furthermore whilst the new housing may well be occupied by families, we need to reconcile this with a general trend within the community of an aging population, where demand for school places will be less. We currently estimate that, in total, there is demand for 1 primary school place for every 9 dwellings within a community. This would suggest demand for approximately 100 new places. As part of the Town Framework process, work is underway by the Education team in establishing what is needed for the plan period with specific regard to capacity, expansion etc. Action: Ensure comments are passed on to the Education team.

Issue: Other

36. While it is to be applauded that a retained green space between Helston and Lowertown is incorporated into the HTF, the question arises as to why Helston’s eastern, western and southern flanks are being denied similar protection. Without such protection, it seems inevitable that the unfettered, badly-planned, scattergun cheap urban sprawl that has come to be a feature of what used to be a town of unique historic character will continue unconstrained to the east, west and south sides of the town. With the HTF setting the tone for Helston’s long-term future it is critical that those in whom the town’s residents have placed their trust pause for considerable thought before simply taking the line of least resistance and allowing yet more layers of shoddy development to be added to the town’s outer fringes. They have it in their power to rescue the town from its slow descent into becoming a prime example of bad planning, cheap design and even worse design execution, an image which will come to characterise and haunt the town for decades unless those drawing up the HTF take this opportunity to reverse the tide now. Should those charged with drawing up the HTF accept the above comments as valid, the question then arises: How is the town to incorporate the required new housing into the plan without expanding the town’s boundaries into surrounding green field sites? The answer can be seen in the existing residential sprawl that has been allowed to swamp the town with no apparent thought given to imaginative design or best use of available land. What can be best described as housing barrack construction currently makes up a sizeable percentage of Helston’s dormitory areas and gives every impression of the building brief of the time requiring contractors to do no more than cover selected parcels of land with concrete boxes having no other function than to remove the less fortunate from the town’s housing waiting list. If such areas were being considered for new housing projects today, would we be approaching the problem in similar fashion? One would sincerely hope not. Instead, one would hope we might be applying a degree of imagination to the scheme not only to make far better use of the land available but to build a sense of community into the scheme, something which is in serious short supply in the barrack housing areas as they now stand. It is for this reason that a more radical alternative to Helston’s current housing issue is urged for consideration under the HTF - i.e. the wholesale re-development of existing areas of neglect, blight and sheer bad planning in order to better-utilise the land available, make the housing stock both sustainable and inspirational and, through the re-design of existing residential sites to maximise their housing potential, obviate the need to expand the town on to green field sites. Other towns have done/are doing this (see Camborne). Why not Helston with the cost being covered out of the millions the European Union is making available to Cornwall via its deprived areas regeneration fund? Only as an absolute last resort, once all other options have been fully considered and exhausted, should those charged with responsibility for overseeing Helston’s future consider expanding the town boundaries on to existing green field sites. Until such considerations have been conducted, these sites should be accorded similar protection to the green buffer zone area separating Helston from Lowertown, an area which, for its sheer amenity value, should be extended under the HTF to cover all existing woodland bordering the public path linking Helston to Lowertown along the Cober valley. Developments to the east of this path have already begun encroaching into this woodland area which, being home to many ancient remnants of the Cober valley mining industry is also of major historic value to the town. Unless protected under the terms of the HTF, there remains the very real danger of this invaluable and historic green space being decimated by housing developments extending right up to the banks of the Cober river itself. Officer response: Comments noted. Whilst the principle of seeking to limit use of Greenfield sites is supported, unfortunately the demolition of existing housing to replace it with higher density schemes is generally financially unviable, which represents a key aspect that the Town Framework will be judged upon. Funding sources such as the European Union rarely cover this type of project; furthermore in places like Camborne, the reuse of brownfield land has focused on underused / derelict brownfield sites, which if they once had a use, was generally for employment Action: Ensure comments are relayed back to the steering group.

Issue: Other

41. Urban infill Housing: There is an additional key housing opportunity in Helston that does not yet seem to be referenced in the Helston Town Framework document. This is urban infill that follows the character of the old town and conservation area. Much of this historic urban infill gains its character by adapting to not having vehicular access, or standard sized and shaped plots. Much of the special character of Helston comes from these ad-hoc organic infill sites that would probably not satisfy modern housing parameters for example in amenity space and vehicular access - yet still function very well in an urban setting close to facilities such as shops and public parking. Being flexible on proposals for such urban infill housing in non-standard plots perhaps without vehicular access could provide for example smaller dwellings for single occupants as well as families and also if designed sensitively can help to protect and enhance local character. I propose that this be expressed in the Helston Town Framework document as a win win means of both contributing to housing supply and to protecting and enhancing local character. 2) Housing Extension sites: Where these extend out into the adjacent countryside there should be substantial surrounding woodland structure planting largely composed of the main locally characteristic woodland species. (No alien species such as Pine trees etc!) The inclusion of local materials should be encouraged or required in new housing. 3) A) This s the flag ship of the area. Its quality has been significantly eroded by unfavourable public realm works to the detriment of the town centres function as an economic driver for the local economy. Notably the public footways in the heart of the town centre at Coinagehall Street have had their distinctive high quality fan patterned Cornish granite paving replaced with a messy jumble of very poor quality tarmac patching and often cracked or broken concrete paving. Financial or other assistance - eg engineering and/or urban design expertise - to address the above by restoring this key feature of the town centre urban realm can provide the essential framework for it to then be worthwhile for individual shops and office premises to be enhanced. Kick starting regeneration by restoring and enhancing historic town centre public realm is one of the basic principles of economic regeneration in a town such as Helston. Such use of Cornish granite in character led economic regeneration has been well demonstrated in several Cornish town centre regeneration schemes delivered successfully by CORMAC and - St Just - in Penwith is a good comparable example. B) Within a strongly conserved historic character framework a receptive approach varying non standard uses in the town centre should centre should be considered to support it's future vitality. 4) Cycle links: Where eve opportunities arise or can be created cycle links should be established as this is one of the growing areas of economic regeneration. This can include support for emerging cycle links based around the National Trust Penrose estate and should be built into any new housing development. The well researched proposals prepared by Cornwall County Council for the re-use of the old Helston railway line as a cycle route should be reopened for consideration as an economic driver. 5) Train links: Consider the use of new planning powers and government economic regeneration funding for the reopening of the Helston branch railway line to modern standards as a key driver for local economic regeneration. Officer response: Comments noted and aspirations to regenerate the town centre are supported. Furthermore, as part of the Town Framework proposals to improve pedestrian and cycle links, including to the town centre, will be considered Action: Ensure comments are relayed back to steering group.

Issue: Other

58. LE4 is considered for use alternative uses to open up options for the owner. LE4 is a very poor quality commercial area on an aesthetically high impact site beside the and the ancient river crossing at St Johns bridge, visually poor and in terms of use of space it is very inefficiently used, however it does provide valuable low cost commercial premises. The current river boundary here restricts the flow of the river and increases flood risk as it is a pinch point to the immediate south of St Johns bridge. The site also borders a currently derelict brown field site which was previously a gasworks. The whole site combined would be ripe for redevelopment for high quality housing units or work – live industrial units to retain commercial interest. Possibility of a S106 developer agreement/ environment agency funding to construct proper flood defences as a solution to St Johns flooding between the two bridges. Developer could pay compensation to moving business’ cash or rent rebate for new premises? It would be possible to consider new riverside path linking of the footpath route from Lowertown – [ or even Hayle to Porthleven cycle route using railway route and footpaths, Camel trail /mineral tramways type project.] Could LE4 provide space for 50+ flats and houses and kick start development at LE2 Linked ring fenced S106 funding could be used to change priorities at St Johns bridge A394 junction to no left turn coming from Penzance and one way over the bridge with a left turn south only.

Officer response: Suggestion noted; LE4 is identified as an existing employment site which is to be retained. However, the suggestion will be considered for assessment. Action: Ensure suggestion is heard by the steering group.

Issue: Urban area sites

64. 1. Section 4 Future Economic Growth The Helston Business Park (LE2) was first granted outline planning permission in March 1991 and has been held by SWERDA since 2001. The Agency has invested in roads and sewers on the site but has not achieved one job creating opportunity on the Park in 12 years. However over that period my Clients have been approached on many occasions by local businesses and professional firms who wanted to relocate/expand in new premises in Helston. These requests have not been able to be accommodated on the Tresprison Industrial Park. My Clients have considered developing the remainder of OS 0335 in which The May Tree Restaurant and Premier Inn have been developed with a view also of providing a more direct and convenient access into the Tresprison Business Park but have discounted these proposals as the land was not shown for development in previous draft Local Plans for the area. It is requested that the Town Framework should identify the undeveloped remainder of OS0335 for office, light industrial and storage space (Classes B1 and B8) with the provision for an alternative access into the existing Tresprison Industrial Park. 2. Section 5 Future Housing Growth Site U1 is a commenced development permitted as Phase II of the outline planning permission PA88/01512/OE02 and the reserved matters approval PA88/01512/S02 and is not as extensive as shown on the map at Pages 8-9 of the Consultation Document because, by reference to the Kerrier District Local Plan Revised Deposit Draft, it does not include: - OS776 to the east; - OS777 to the south west; and - R672 to the west. In addition, the Tesco replacement store not only expanded into approximately two thirds of R672 but also a part of the Phase II commenced development (see attached 2010 Tesco Site Plan) with a loss of approximately 15 dwellings. It is requested that Site U1 is shown correctly and referred to as a site with 134 dwellings. Site U5 should be shown as a ‘site with planning permission’ for 32 dwellings not 22 dwellings (LPA ref. PA11/11018 granted 14 November 2012). Site HX2 my Clients are the owners of the majority of this site and support the proposed residential development of the land. Officer response: Comments noted; section 1 will be assessed in further detail, section 2 regarding the extant permission has been reviewed and accordingly the map will be amended in future versions of the Town Framework. In terms of the last comment relating to U5, this has been noted and the document will be amended to 32 dwellings. Action: Ensure comments are relayed back to steering group and the identified actions are undertaken.

Issue: Other

69. We act for the Rowe Family and associated companies (the promoters) who own land to the north and north east of Helston. We have also submitted representations in respect of the Cornwall Local Plan Strategic Policies 2010-2030. These representations should be read in conjunction with those representations. Our client wishes to play an ongoing role in the preparation of Helston Framework and consider that their land is ideally suitable to assist in meeting some of the future housing and employment needs of the town in the period up to 2030. We believe that the level of employment development should be in excess of 20,000 sqm rather than 10,000 sqm as presently identified. Question 2: We consider that land identified to the north of Water-Ma-Trout employment area is ideally located for future employment development (see attached plan). The land represents a logical extension to the existing employment area which is at capacity. In addition it is well located next to the B3303 making it attractive for new employers or for inward investment to take place. There are no technical or environmental constraints to the site coming forward. We note that the existing proposed employment area (LE2) has been available for development for approx 10 years without development taking place. The promoter's site adjacent to LE5 would be brought forward immediately (there are businesses looking for space now). It is therefore recommended that this land be identified for future employment provision. As part of that allocation improvements would be made to Lowertown Road. Question 3: The only comment to make is that within the land known as HX1 which is controlled by the promoters, local retail provision could be provided at an appropriate scale as part of their proposals. Question 4: We fully support the proposed housing site options for Helston. Our client controls the option identified as HX1 and considers that it is eminently suitable to accommodate some of Helston's future housing needs in association with some of the other identified options. We have submitted representations to the Local Plan which indicates that: i) The level of existing commitments of 450 dwellings (as identified on the Framework map as sites U1-5) have been overestimated. We understand that sites U3, U4 and possily U2 are extremely unlikely to be delivered and that U1 planning permission is for less than the 149 units stated. Even if you add the stated existing commitments of sites U1, U2 and U5 together this totals 217 dwellings. The total is therefore more likely to be in the region of 250 dwellings. ii) The level of housing required for Helston should be increased to between 1,500-2,000 dwellings. iii) That at least two strategic sites should be identified to not only provide a choice of location but also to ensure that sites are actually delivered. By adopting such an approach it is more likely that the existing and future housing needs of the town would be met. Whereas at present this is not the case. However turning to site HX3 it has many technical issues which include: i) Access is extremely problematic in that there are a large number of mature trees protected by a TPO along the north eastern boundary of the site. Many of these would need to be removed to provide access. ii) The site is not located close to any existing employment or schools unlike site HX1. iii) The sites proximity next to the Helston Conservation Area placing a further constraint on development which is not applicable to any of the other identified sites i.e. HX1 and HX2. iv) The proximity of RNAS Culdrose presents significant aviation and noise issues which do not affect any of the other identified sites. This is a major constraint which effectively prohibits development on this site. v) The landscape impact of development on this site is more severe than any of the other identified sites. Question H5: There are no other suitable locations for housing in Helston other than those identified. Question H6: A by-pass for Trewennack (which has been campaigned for and recognised as necessary for 20 years) should be provided within any plans. Site HX1 has the potential to provide a large part of the bypass. QH7: As stated earlier we have made representations in respect of the Cornwall Local Plan which requests: i) That the housing provision for Helston be increased to 1,500-2,000 dwellings. ii) That additional employment land for Helston be identified. iii) That a range of housing sites be identified for Helston which includes site HX1. This will ensure that the housing needs both open market and affordable for the town are not only met but also it will provide a choice for sites for potential residents. Comment: We trust that these comments will be taken into consideration in the preparation of the Helston Town Framework. Our client wants to play a full and active part in the ongoing work for the Framework and would welcome the opportunity to meet to discuss these representations together with the suitability and availability of their land for development. Officer response: Comments noted; in terms of the concern over the projected levels of employment, the surveys undertaken were commissioned by independent qualified assessors and we believe that those figures are sound. Additionally, the suggestion made to the proposed employment to the North of Mater-Ma-Trout is not appropriate due to the local resistance, the definitive road barrier, the sites isolation to Helston and essentially, there is an appropriate employment site identified within Helston. In terms of the issues raised regarding the housing numbers for existing commitments, we will review the urban capacity accordingly. We note that you have made comments regarding housing provision and those comments will be dealt with by the Local Plan. In respect of comments raised concerning HX3; specifically relating to the access, we recognise that there are constraints and it would be for one to justify how access could be made appropriately. In terms of school provision, it is evident that Nansloe School is within close proximity to the site and Helston secondary school is also within walking distance. The proximity to the conservation area is also not a seen problem and it would be for one to respect and respond to the sites proximity to the designated conservation area. The concerns relating to the proximity of Culdrose, have been noted, Environmental Health was previously consulted on the potential development site; however, they raised no objections. Furthermore, RNAS Culdrose have been on the Steering Group progressing the project and whilst they have indicated that they do receive complaints from a few residents within this vicinity, they have not indicated an objection to the proposed site. The final comment relating to Trewennack is a known aspiration for Helston and Wendron; work is currently underway on the transport modelling and highway improvements may be identified as part of that process. Action: Relay comments back to steering group and undertake relevant actions.