General comments on the DPD in respect of the Development Plan The approach taken by Cornwall Council to prepare a two tiered Local Plan is supported but only on the basis that when the tiers are combined it provides the necessary minimum strategic guidance across both documents. The Local Plan currently identifies a numerical housing and employment requirement for each CNA but does not go any further. The SADPD must therefore address, as a minimum, the policy gaps left by the higher tier plan. These gaps include necessary detailed guidance on housing and employment provision through the allocation of specific sites. The SADPD seeks to address the minimum requirements for some of the CNAs, but not others. When coupled with the limited scope of the Local Plan, it leaves an incomplete guidance document for Cornwall which is contrary to NPPF. This is explained further below in the section titled Neighbourhood Planning. Paragraph 47 of the NPPF states that LPAs must ensure Local Plans meet the full objectively assessed need (OAN) for market and affordable housing. Coupled with this, the Local Plan Making section of the NPPF (paras 150-182) makes a clear distinction between local plans prepared by the local planning authority and neighbourhood plans prepared by community based neighbourhood forums. When read as a whole, the NPPF makes clear that the Local Plan must demonstrate that the full OAN is capable of being met through the identification of sufficient sites. However, the local plan only identifies the OAN as a numerical requirement and does not address how it will be met through allocated sites and other accepted sources of supply such as planning permissions. Given that the first part of the Local Plan has a limited scope, the SADMP should: - Identify what sites constitute 5 year land supply plus buffer. - Identify specific developable site/ broad locations for years 6-10. - Identify where possible specific developable site/ broad locations for years 11-15. This information should be available for consultation and scrutiny when determining whether sufficient land supply is available. Without this information it is impossible to establish whether sufficient sites are being identified in the DPD to meet the minimum requirements of the NPPF. The SADPD should also make clear that the local plan requirements for each CNA is an absolute minimum requirement. Sustainability Appraisal Page 8 of the Sustainability Appraisal (SA) states that “work has been carried out since 2010 in developing the Allocations DPD” with the early stages focussing on the Draft Town Framework Plans for “the majority of main towns in Cornwall”. This work formed “the foundation from which the Allocations DPD was developed”. From this there is no indication that the outcomes of the Local Plan process and the Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 2 Company Registration No.6370231 Origin 3 Ref 10-019 Inspector’s clear recommendations for a further finer grained employment land review have been taken on board in preparing the SADMP. The SA is therefore inherently flawed in that it can only undertake a comparative assessment of sites from the pre-selected list of main towns. In addition, it is unclear as to whether the brownfield sites submitted to the Strategic Housing Land Availability Assessment & Statutory Register of Brownfield Land Call for Sites exercise (August 2015) have been included within the comparative assessment. Role of Neighbourhood Planning In section 4 of the Sustainability Appraisal, it states that “to ensure a complementary set of documents and to support the principles of Localism, the Allocations DPD has not identified sites for a town where a NDP is actively being taken forward..” However, to be consistent with paragraph 47 of NPPF, the preferred option SADPD must not leave large parts of the housing supply to be identified through neighbourhood plans. The Former Penhale MoD Camp is located within the wider parish of Cubert, which also covers the settlements of Holywell, Treseal and Tresean. It is assumed that the SADPD does not cover this area, as it is expected that the preparation of a Neighbourhood Plan will provide site allocations. However, an application to designate Cubert Parish as a Neighbourhood Plan Area is yet to be submitted, and as such it can be reasonably assumed that a Neighbourhood Plan would not be adopted for an absolute minimum of 2-3 years. Indeed, of the 6 parishes within the St Agnes and Perranporth CNA, only 2 have submitted an application for a Neighbourhood Plan Area designation and both of these are yet to produce a draft NP. The result of this is a significant policy gap for the necessary detailed guidance on housing and employment provision within the Parish and wider CNA. Whilst supporting the role of NP plan preparation, it seems unreasonable to expect small parishes with limited resources to undertake the level of quantitative and qualitative analysis that is required to underpin robust allocations. Given that the SADPD is running ahead of the NP preparation in the whole of the St Agnes and Perranporth CNA, it would be far more proactive for the SADPD to include sites within the CNA to guide future NP preparation. The NPs, once prepared, can then reflect the allocations identified within the SADPD, rather than leaving the identification of development sites open to uncertainty for several years resulting in delays to the delivery of much needed economic development and housing. Alternative Site Proposal- Former Penhale Ministry of Defence Camp The opportunity to promote the Former Penhale MoD Camp through the SADPD process is welcomed. The Camp is a large brownfield site, with a site area of approximately 16 hectares. The site was formerly used Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 3 k Company Registration No.6370231 Origin 3 Ref 10-019 The SADPD seeks to address the necessary minimum requirements for some of the CNAs, but not others. When coupled with the limited scope of the Local Plan, it leaves an incomplete guidance document for Cornwall which is contrary to the National Planning Policy Framework (NPPF). Paragraph 47 of the NPPF explains Local Planning Authorities (LPA) must ensure Local Plans meet the full objectively assessed need (OAN) for market and affordable housing. Coupled with this, the Local Plan Making section of the NPPF (paras 150-182) make a clear distinction between local plans prepared by the local planning authority and neighbourhood plans prepared by community based neighbourhood forums. When read as a whole, NPPF is clear that it is for the Local Plan to demonstrate that the full OAN is capable of being met through the identification of sufficient sites. Cornwall Council’s local plan only identifies the OAN as a numerical requirement it does not address how it will be met through allocated land and other accepted sources of supply such as planning permissions. To be consistent with paragraph 47 of NPPF, the emerging draft SADPD must not leave large parts of the housing supply to be identified through neighbourhood plans. Whilst neighbourhood plans are being progressed in some communities such as Roche in the China Clay CNA (a process which is supported), the three tiered approach to the plans lacks a transparent integration to demonstrate that the OAN requirements are being comprehensively planned for. The SADPD should also demonstrate the following as set out in the NPPF given that the first part of the Local Plan does not: - Identify what sites constitute 5 year land supply plus buffer. - Identify specific developable site/ broad locations for years 6-10. - Identify where possible specific developable site/ broad locations for years 11-15. This information should be available for consultation and scrutiny when determining if sufficient land supply is likely to be made available. Without this information it is impossible to establish whether sufficient sites are being identified in the SADPD to meet the minimum requirements of the NPPF. In a near identical manner to housing sites, the SADPD only identifies employment sites in some CNAs and it is therefore impossible to establish whether sufficient employment provision is going to be capable of delivery. Furthermore, the SADPD appears to limit itself to the identification of B1a (office) and industrial land. This seems to be wholly at odds with the Government’s approach to a much broader assessment of economic need in order to build a strong and competitive economy. Origin3, Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 2 REP 0185 Cornwall Allocations DPD, Strategic Planning, Cornwall Council, Dolcoath Avenue, Camborne, Cornwall TR14 8SX Date: 14/11/2016 Letter ref: CP/00072 Dear Sir/Madam Cornwall Allocations DPD – Regulation 18 consultation I write on behalf of my client Strongvox Homes to make representations in respect of the current consultation on the Cornwall Allocations DPD. Strongvox Homes has an interest in land at Ivydene Farm, Threemilestone, which is identified on the attached plan. We are surprised that the draft Allocations DPD makes no proposals for Truro and Threemilestone. The document states that it will be for the Neighbourhood Plan to perform this function. However, the Truro and Threemilestone Neighbourhood Plan was prepared and examined prior to the uplift in the Local Plan apportionment of housing to be provided in Truro and so is drafted on the basis of there being no residual requirement to be met. The proposed modifications to the Local Plan include an uplift in the apportionment of housing to be provided in Truro (with Threemilestone) between 2010 and 2030 from 2900 to 3,900. The Council’s June 2016 schedule of proposed changes advises that completions between 2010 – 2030 amounted to 758 dwellings but a further 2737 had planning permission or were under construction.