Multi-Towns-Responces-Final-Part-2.Pdf

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

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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

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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.

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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. In addition, the Council is allowing for windfall development of 144 dwellings on sites of less than 10 dwellings between 2021-30. This appears to leave a residual requirement of 234 dwellings. This means that the Neighbourhood Plan is not up to date with, nor in some ways therefore consistent with, the Local Plan requirements. Consequently, there is a role for the Site Allocations Plan to address how the residual requirements in Truro and Threemilestone of the Local Plan should be met.

The land identified on the attached plan is available for development and is suitable for a housing led, mixed use development to meet this residual housing requirement and help address the employment requirements of the Local Plan. It also has the potential to deliver highway infrastructure in the form of a new road between the A390and Chacewater Hill.

I trust the above will be given careful consideration as the Plan progresses.

Yours faithfully

SIMON COLLIER Director

REP 0186

LVA November 2016

Representations to the Cornwall Site Allocations Development Plan Document, Preferred Options Consultation

Land at Saltbox Close, Mylor Bridge

savills.co.uk

November 2016 1

1. Introduction

These representations have been prepared by Savills on behalf of LVA, in response to the Cornwall Site Allocations Preferred Options Consultation Document.

The representations set out our concerns with the Council’s approach to distribution of development across the County and, in particular, the approach taken towards development at Cornwall’s villages.

Given that we are promoting land located at one of Cornwall’s villages, Mylor Bridge, and not land at one of the main towns identified within the Consultation Document, we have not responded to the majority of questions set out in the Site Allocations Consultation Document (Section 15: Consultation Guide). Instead, we have provided comments on the general scope of the Site Allocations DPD, followed by a response to question 6 to promote an alternative site not currently identified within the draft document.

November 2016 2 2. Scope of the Site Allocations DPD

Whilst we acknowledge that this consultation is limited to the scope of the Site Allocations DPD, we continue to have fundamental concerns with the Council’s strategic approach taken in both the emerging Local Plan and Site Allocations DPD to the delivery of development in Cornwall’s villages. In our view, it is concerning that there is no allowance in either Policy 3 of the emerging Local Plan, or the Site Allocations DPD, nor flexibility, for future growth in the county’s most sustainable villages, unless such growth is proposed through a Neighbourhood Plan.

The approach of focussing development away from Cornwall’s villages will not assist in meeting the needs of the most sustainable villages, and will only serve to restrict delivery. Such an approach is contrary to the NPPF, one of the Core Planning Principles is to “take account of the different roles and character of different areas … recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”. This principle is re-emphasised in Paragraph 55 of the NPPF which states “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”.

Whilst it is acknowledged that the Council will prepare the Site Allocations DPD in accordance with the strategic policies of the Local Plan, specifically draft Policy 3, we continue to have fundamental concerns with the approach. We fail to see how the Council will address the housing needs of the rural areas without proactively planning for growth.

For example, the Council's Affordable Housing Team have recently confirmed that the identified housing need for Mylor Bridge Parish, up to August 2016, stood at 91 households registered with a local connection to Mylor on the HomeChoice register. This demonstrates the ever increasing need for housing in the Parish. However, at present there appears to be no policy mechanism for delivery housing within the Parish to meet local needs.

Policy 3 of the emerging Local Plan specifies that, of the 3,400 dwellings to be delivered in the plan period for the Falmouth and Penryn Community Network Area (CNA), 600 are to be delivered within the CNA outside of the two main towns. However, whilst the Council is proposing the delivery of 600 dwellings within the remainder of the CNA, the Council is failing to plan proactively for the delivery of at least this number of dwellings through specific allocations. Without allocating specific sites in the most sustainable villages we fail to see how the Council proposes to address the needs of the whole CNA, including the identified need at Mylor Bridge.

With specific reference to the Falmouth and Penryn CNA, Policy 2a identifies a requirement to deliver 600 housing units over the plan period within the CNA. However, the updated housing trajectory (March 2016) contained within Table 1 of the emerging Local Plan indicates that there is no residual requirement within the CNA, once completions, planning permissions not started or under construction, and small windfalls are taken into account. We have significant concerns over the emphasis placed on windfalls and consider it a much better approach to plan to additional allocations to increase certainty over delivery. In addition, whilst there appear to be 197 units relating to unimplemented planning permissions, it is unlikely that all these unimplemented planning permissions will be delivered. As such, opportunities to maximise the delivery of housing within sustainable locations should be explored.

The Council must make absolutely certain that sufficient land is allocated for development to meet the objectively assessed housing need, including a supply of specific deliverable sites sufficient to provide five years worth of housing against their housing requirements with an additional buffer of 5%. The fact that a number of recent appeal decisions this year confirm that the Council cannot currently demonstrate a five year housing land supply is further compounding this issue.

November 2016 3 Given that it is likely that the Council will need to significantly boost housing delivery to ensure the overall strategic housing requirement set out within the emerging Local Plan is met, the Council must take this opportunity to properly plan for the objectively assessed needs for Cornwall, and more specifically sustainable villages such as Mylor Bridge, and therefore allocate sufficient land through the Allocations DPD to significantly boost the supply of housing and ensure a supply of specific deliverable sites. This should include key settlements, including the most sustainable villages, which are capable of playing a key role in meeting the objectively assessed needs.

We therefore object to the overreliance of the Allocations DPD on delivery of housing at the main towns as the focus for future growth, and the lack of recognition for other key settlements outside of the main towns which are capable of accommodating sustainable future growth.

Furthermore, we are also concerned with the Council’s reliance on the delivery of development in the villages through Neighbourhood Plans, which is, in our view, an entirely unsound approach, and will place significant risk on meeting the objectively assessed needs in the rural areas. The overreliance on the delivery of development through Neighbourhood Plans alone is unlikely to result in an appropriate distribution across the District’s most sustainable settlements. On the contrary, this approach could prevent opportunities to meet a clear need in areas where a Neighbourhood Plan is either slow to prepare; proposes only a limited amount of development in that area; or is never adopted.

It is clear that, currently, no desire to prepare a Neighbourhood Plan has been expressed by Mylor Bridge Parish Council. It is considered that, at this moment in time, there is little prospect of a Neighbourhood Plan being progressed to assist in addressing the immediate housing need for the area. Therefore, at best, it is likely to be some time before a plan is in place to address the growing local need, and, at worst, such a plan may never come forward.

We therefore strongly recommended that the Council considers the allocation of land in the most sustainable villages, including Mylor Bridge.

Whilst Mylor Bridge is not classified as one of the larger settlements within the Site Allocations DPD, it is nonetheless a large village with a range of services and facilities within walking distance for residents, including:

• Primary School; • Pre-School Playgroup; • Pub x2; • Harbour cafe; • Restaurant; • Church; • Parish Hall; • Community Centre; • Post Office; • Village shop; • Butcher; • Dentist; • Doctors surgery; • Fishmonger; • Hair salon; • Recreation Ground; • Mobile Library

The range of services and facilities, along with the public transport links available, create a sustainable platform for future development, and it is considered that Mylor Bridge is a sustainable location for future residential

November 2016 4 development. Indeed, it is considered that Mylor Bridge should be allocated a reasonable level of housing commensurate with its size and scale.

November 2016 5 3. Q6. Is there an alternative site that you would like to propose?

For the reasons set out in the section above, it is strongly considered that Mylor Bridge is one of the most sustainable villages in Cornwall which is capable of accommodating future growth. However, as set out in our comments under the sections above, we have significant concerns over the Council’s approach within the Site Allocations DPD which suggests a failure to plan for the sustainable villages.

Land at Saltbox Close, Mylor Bridge

The site comprises greenfield land covering 2.68 hectares immediately south west of existing residential dwellings on Saltbox Close. The land is outside but adjacent to the settlement boundary, and is surrounded by built development on three sides.

An element of vegetation and trees are spread around the perimeter of the site, particularly the north west, south west and south east boundaries which provide an element of screening between the site and the surrounding area. The land slopes gently with a generally flatter area across the central part of the site. The site does not fall within an area at risk of flooding.

Whilst the site is surrounded by built development to the north-west and east, the majority of the site boundaries comprise vegetation and trees. The strong landscape structure on these boundaries ensure that views into the site from the wider area are therefore limited to a small number of properties immediately adjacent to the site along the north-western boundary.

The site is approximately 500m south of Mylor Bridge village centre, with access to a range of services and facilities as set out in the section above. In addition, bus services 66 and 69 provide connections from the village to the surrounding area, including Truro and Falmouth. The nearest bus stop is located opposite Saltbox Close, on Saltbox Road, approximately 80m away from the site entrance. The convenient location of nearby bus stops therefore provide convenient public transport links as an alternative to the private car.

The agricultural land quality of the site is classified as Grade 2, However, it should be noted that all the land around Mylor Bridge, within 1km of the site, falls within the best and most versatile land classification as Grade 2, and therefore any developments within this location would involve the loss of such land.

In addition, whilst the site falls within an Area of Outstanding Natural Beauty (AONB) it is clear that the village is washed over by this designation, and therefore any extension to the village would need to be delivered within this designation in order to address the existing local housing need. Therefore, in order to deliver housing to meet the need, it is important to ensure that development is located in a part of the AONB where the impacts are limited. It is considered that any development on the site itself would be seen in the majority of instances as an extension to the village, with its character viewed in association with the built form of the village. Any future development could also be carefully designed to ensure that the design reflects the character of the area.

The land has, in the past, been assessed as part of the Council’s Strategic Housing Land Availability Assessment (SHLAA). Indeed, the January 2016 SHLAA assessment of the site under reference S148 ‘Land off Saltbox Close’.

November 2016 6 The SHLAA assessment concludes that the site is suitable for development with an estimated capacity for 20 dwellings, and is deliverable within years 6-10 (2020/21 – 2024/25). Indeed, based on the Council’s assessment criteria, the site scored maximum points for deliverability (450 / 450).

Supporting Technical and Environmental Assessments

To date, a significant level of background technical assessment and environmental work has been undertaken to ensure that the site is both suitable and deliverable for residential development. Pre-application discussions have also taken place with officers at Cornwall Council as well as with Mylor Bridge Parish Council and the local community.

A summary of the environmental assessments of the site which have been completed to date are set out below.

Landscape and Visual Impact

A Landscape and Visual Impact Assessment (LVIA) has been prepared for the site to review the baseline conditions for development, identify the landscape setting and wider context of the site, and define this in terms of landscape and visual character and the key elements which contribute to the composition of this character. In addition, the report provides an objective Landscape and Visual Assessment of the site and its context, and identifies potential effects on the landscape character visual amenity of and users of the surrounding area as a result of development.

The report confirms that the site is located within the Cornwall AONB, which was designated in 1959 and covers 1129 square kilometres, approximately 42% of the county. In addition, the Lower Fal & Helford Intertidal Site of Special Scientific Interest (SSSI) is located approximately 1.75km south east of the site and runs along the Carrick Roads coastline between Penarrow Point and Trefusis Point, and the Fal and Helford Special Area of Conservation (SAC) is located 1.5km to the east and 1.3km to the north east at Restronguet Weir, along the Carrick Roads.

The supporting LVIA concludes that the site is not visible from the majority of viewpoints and that the site benefits from a good level of screening provided by mature trees and hedgerow. Overall, the LVIA outlines that the site’s landscape character has the ability in which to absorb development without causing any unacceptable long term landscape and visual harm.

It is therefore considered that development of the site would not present any significant constraints relating to landscape and visual impact of the immediate and wider setting.

Highways and access

A Transport Statement has been prepared to support the potential for future development on the site in order to address the main traffic and transport considerations associated with the potential development of the site, with an assessment of matters including the accessibility of the site by sustainable transport modes, site access arrangements, site parking provision, the number of new trips that will be generated by the site; and, the impact of the development upon the local highway network.

In terms of traffic generation, the Transport Statement confirms that given the anticipated low level of traffic movements associated with such a development, coupled with the expected distribution of traffic movements, it is considered that there would be no significant impact on the operation of the local highway network as a result of the development of the site. Furthermore, it is considered that the development of the site is unlikely to exacerbate the levels of road traffic accidents and that the proposed access is positioned in a location with a low accident record.

November 2016 7 The report confirms that the most safe and suitable access into the site is via Saltbox Close. However, it is recognised that whilst footpath provision around the site is generally reasonable, on some routes there is an absence of footpaths. In particular, the footpath originating from Saltbox Close converges and extends laterally on the southern side Saltbox Road for a total of 20m on each side of the junction before terminating, where pedestrians are required to travel the remaining 60m on Saltbox Road in order to access the footpath on Waterings Road that leads to the centre of the village. There is therefore a need for footpath provision.

In order to ensure that future residents can safely walk to the village centre on continuous dedicated footpath, potential solutions have been discussed with the Council’s highway officer. In summary, potential off-site highway improvements include the delivery of a new section of footpath along the northern edge of Saltbox Road to directly connect with the current pathway on Waterings Road. The new footpath would connect to the existing footpath via a pedestrian crossing with tactile paving. Due to decreased road space available as a result of the construction of the path, a priority system would need to be implemented. Priority will be given to vehicles travelling along Saltbox Road from Waterings Road, in order to prevent queuing vehicles from tailing back and blocking the roadway and junction of Waterings Road.

Such off-site improvements would add to the existing pedestrian links available to future residents of the site and help create a walkable neighbourhood, and would result in a significant improvement to the existing baseline position. Indeed, existing residents on Saltbox Close and Saltbox Road would benefit significantly from the improvements who currently have to negotiate a section of Saltbox Road without a footpath if they wish to walk to the village centre. The introduction of the new footpath, along with the crossing and traffic calming through the priority signage, would result in improved highway conditions which would otherwise not be realised without the delivery of the scheme.

Overall, from a highways perspective, the site is in a sustainable location to make use of the existing walking, cycling and public transport networks, and within close proximity to local shopping, education, and healthcare facilities. The site is considered suitable for development from a highways perspective and there are no transportation reasons why the site could not be developed.

Ecology

An Ecological Report has been prepared based upon a number of on-site surveys undertaken over several months in 2016, including an Extended Phase I Habitat Survey and various further species specific surveys.

The Ecological Report confirms that the site is within 1.8km of the Fal and Helford SAC, over 2km from the SSSI Lower Fal and Helford Intertidal, and 1.5km from the South Cornwall Coast Important Bird Area. However, there are no anticipated adverse impacts upon these designated sites.

With regards the site itself, whilst some protected species have been identified through surveys undertaken, the Ecological Report identifies suitable mitigation measures to ensure that there will be no harmful impact. Such mitigation includes the retention of mature trees and hedgerows, and increased planting to increase the biodiversity value of the site.

Overall, subject to the necessary mitigation measures, the development of the site would not have an adverse impact on ecology.

Flood Risk, Drainage and Utilities

A Flood Risk Assessment (FRA) and Foul Sewage and Utilities Assessment have both been prepared to support the promotion of the site. The FRA assesses flood risk, storm drainage and foul drainage capacity on the site. It concludes that there are no prohibitive engineering constraints to developing the site for residential use.

November 2016 8

The site is in Flood Zone 1 and hence the preferable location for residential development in the context of the sequential test in the NPPF. The land also has a low probability of flooding from overland flow, ground water and sewer flooding.

The proposed drainage strategy for the development will be to introduce two detention basins to manage the surface water runoff from the site. Careful integration of these features into the site will create potential habitats for wildlife and promote bio-diversity, providing valuable open space and amenity value.

Furthermore, the Foul Sewage and Utilities Assessment sets out appropriate means to discharge storm and foul water drainage in a manner which complies with the current guidance and requirements of the statutory undertaker – South West Water. Discussions with South West Water have determined that the foul network would need to be modelled to evaluate the possible improvements to the foul sewerage network to accommodate development on the site. It is likely that a detailed solution informed through the completion of foul network modelling would be agreed with South West Water as part of future discussions.

There are therefore no constraints to the development of the site in respect of flood risk or drainage capacity.

Tree Survey

An Arboricultural Assessment has been undertaken to support the promotion of the site, which confirms that the majority of the trees and hedgerows on the site can be retained as part of any future development.

Indeed, there is a significant opportunity, through future development, to provide a net increase in replacement planting to enhance the landscape quality of the site, as well as providing suitable open space and green infrastructure.

Summary

Given the sustainability credentials of Mylor Bridge, as one of the most sustainable villages in Cornwall which is capable of accommodating future growth, and given there is a significant need for housing within the Parish, as demonstrated by the Council’s own Affordable Housing Team, the allocation of land at Mylor Bridge is required. In our view, it is not a robust or sound approach to simply rely on the housing need for Mylor Bridge being addressed through affordable hosuing exception sites or through a future Neighbourhood Plan.

It is strongly considered that the at Saltbox Close, Mylor Bridge, shown on the plan at Appendix 1, is suitable, available and deliverable, and there is no restriction to it contributing towards meeting the strategic housing needs for Mylor Bridge and Cornwall. The site should therefore be considered for allocation within the emerging Site Allocations DPD. Based on the technical assessment work undertaken, some of which has been outlined above, it is considered that the site is capable of accommodating up to 32 residential dwellings, along with associated landscaping and open space.

Not only is the site entirely suitable for development, but it is capable of delivering exactly the type of development required and being sought by the village, commensurate with the size and scale of the existing settlement.

The evidence presented provides good justification for the site to be considered as an allocation for future residential development as part of the emerging Site Allocations DPD. .

November 2016 9 5. Conclusion

In conclusion, we continue to have significant concerns with the Council’s approach to the Site Allocations DPD.

The Council must take this opportunity to properly plan for the objectively assessed needs for Cornwall, and more specifically sustainable villages such as Mylor Bridge, and therefore allocate sufficient land through the Allocations DPD to significantly boost the supply of housing and ensure a supply of specific deliverable sites. This should include key settlements, including the most sustainable villages, which are capable of playing a key role in meeting the objectively assessed needs.

In our view, it is concerning that there is no allowance in either Policy 3 of the emerging Local Plan, or the Site Allocations DPD, nor flexibility, for future growth in the county’s most sustainable villages, unless such growth is proposed through a Neighbourhood Plan.

There is currently an identified need for housing in Mylor Bridge Parish, confirmed by the Council's Affordable Housing Team as 91 households registered with a local connection to Mylor on the HomeChoice register up to August 2016. This demonstrates the ever increasing need for housing in the Parish. However, at present there appears to be no policy mechanism for delivery housing within the Parish to meet local needs.

The range of services and facilities at Mylor Bridge, along with the public transport links available, create a sustainable platform for future development, and it is considered that Mylor Bridge is a sustainable location for future residential development. Indeed, it is considered that Mylor Bridge should be allocated a reasonable level of housing commensurate with its size and scale.

The land at Saltbox Close is entirely suitable for future development. It is available and deliverable, and there is no restriction to it contributing towards meeting the strategic housing needs for Mylor Bridge and Cornwall. The site should therefore be considered for allocation within the emerging Site Allocations DPD for up to 32 residential dwellings, along with associated landscaping and open space.

We request that the Council carefully consider these representations when progressing with amendments to the Villages DPD, with particular attention to the approach to the Built-up Area Boundaries to facilitate suitable and sustainable development.

November 2016 10

Appendix 1 Site Location Plan

November 2016 11

REP 0209

Origin3 Ref. 12-042

Cornwall Allocations DPD Strategic Planning Cornwall Council Dolcoath Avenue Camborne Cornwall TR14 8SX

14th November 2016

Dear Sir/ Madam

Re: Representations to Cornwall Site Allocations Development Plan Document (SADPD) – Preferred Options Consultation (September 2016)

Please accept this letter as formal representations made on behalf of Indian Queens (Cornwall) Ltd, and a consortium of local landowners. These representations follow those submitted to the Local Plan previously by Origin3.

We welcome progress with the SADPD, especially in light of the lack of any real strategic direction provided by the Local Plan for either housing or economic development. It is hoped that in due course the SADPD will provide certainty to the development industry and potential investors and establish a more detailed framework within which development can be delivered. The greater role that Neighbourhood Plans (NPs) are performing as part of Cornwall’s development plan is also noted. Whilst we welcome the intended approach to provide local communities with a greater input into the future growth of areas/ settlements, the plan appears to offer little guidance (or a plan B) in the event that NPs do not provide this information or are not forthcoming in a relevant timescale or indeed unwilling to plan positively for growth. This leads to a somewhat sporadic development plan which unfortunately is likely to be counterproductive for a number of reasons explained below.

Origin3 welcome the opportunity through this preliminary consultation to recommend alternative or more suitable sites for allocation through the SADPD. With regard to our client’s specific land interests these are identified on the attached plan. It is the intention of the consortium to promote a sustainable commercially-led mixed-use development at this location offering employment, retail and leisure opportunities. The site has excellent accessibility to the A30 and significant locational advantages sitting between St Austell and Newquay. It is also located centrally within wider Cornwall. Of equal significance is that the site lies within the China Clay CNA Regeneration Area. These locational advantages would help deliver the aims and aspirations of the St Austell, St Blazey and China Clay Area Regeneration Plan (CCRP, 2012).

Given that the SADPD currently only focusses on a limited number of main towns, other sites and opportunities with better communication links to the A30 have therefore already been excluded by the Plan without proper and due process or detailed qualitative consideration. Given the importance of this area and the need for continuing regeneration the SADPD must emphasise the

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 1 Company Registration No.6370231 Origin 3 Ref 12-042

CCRP more clearly. The introduction to the 2012 CCRP states that “Cornwall Council has identified the St Austell, St Blazey and China Clay Area as one of its two priority areas for strategic regeneration and investment” (paragraph 1). In our opinion therefore there is discord between the aims of the adopted CCRP as the latter allocates nothing in those areas most in need.

Our key areas of feedback are summarised in turn below.

 Incomplete Development Plan

The approach taken by Cornwall Council in preparing a two tier Local Plan is supported but only on the basis that when the tiers are combined it provides both the necessary strategic and more detailed guidance. The Local Plan currently identifies a numerical housing and employment requirement for each CNA but does not go any further. We have raised previous concerns on the calculations and the strategy which seeks to concentrate solely on B1, B2 and B8 uses at key towns as previous Local Plans have also done. Local, regional and global economies, growth sectors and operators requirements have moved on from this type of 1980s approach to employment but the plan misses these opportunities. The SADPD must therefore address, as a minimum, the policy gaps left by the higher tier plan in our view. These gaps include necessary detailed guidance on housing and employment provision through the allocation of specific sites as recommended by the Inspector in his September 2016 final report. 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 NPPF. The implications of this are discussed further below in relation to the China Clay CNA.

 Inconsistency with NPPF requirements to address housing need

Paragraph 47 of the NPPF explains that LPAs must ensure that 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, the 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 for obvious reasons.

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 sites/ broad locations for years 6-10. - Identify where possible specific developable site/ broad locations for years 11-15.

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 Inconsistency with NPPF requirements to address economic need

As noted above the SADPD only identifies employment sites and requirements in some CNAs and not others. The SADPD appears to limit itself to the identification of B1a (office) and industrial land only rather than looking to encourage other economic sectors. 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.

The uplifted OAN in the final iteration of the Local Plan took account of the peer review work undertaken by Ash Futures (August 2015) in forecasting jobs and economic growth. However as set out in our representations to the Local Plan this work did not clearly explain the interrelationship between jobs forecasts and employment land requirements (for all types of economic development, not only B class uses). Paragraph 161 of the NPPF states that local planning authorities should use SHMA and SHLAA processes to assess:

“The need for land or floorspace for economic development, including both the quantitative and qualitative needs for all foreseeable types of economic activity over the plan period, including retail and leisure development;

The existing and future supply of land available for economic development and its sufficiency and suitability to meet the identified needs. Reviews of land available for economic development should be undertaken at the same time, or as combined with, Strategic Housing Land Availability Assessments and should include a reappraisal of the suitability of previously allocated land.” (O3 emphasis):

Despite national guidance, the Council’s updated SHLAA (January 2016) only covers housing. There appears to us to have been no similar exercise (Call for sites) undertaken for Economic land opportunities or any assessment of land available for economic development. In his September 2016 report the Inspector acknowledges this gap in the assessment stating that:

“This strategic plan leaves considerable further work to the SAP and to NPs to determine the type and scale of new employment allocations which should be made in each CNA. For effectiveness, it is essential that the policy sets out a checklist of what needs to be done as part of this work, taking in to account not just the quantitative scale of sites available to meet the floorspace targets, but also the viability /attractiveness of sites for investment consistent with the sectors that the Plan and wider Council/ LEP strategy is targeting. Because of the need for this further qualitative assessment, it is not appropriate for the employment floorspace distribution table to identify a specific figure as the residual to be provided. “ (paragraph 82). (O3 emphasis)

Despite this clear recommendation the SADPD does not as yet appear to have been underpinned by such an assessment.

 Role of the SADPD

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Policy 5 (Business and Tourism) of the Local Plan states the following:

“4. Site Allocations Development Plan Documents and Neighbourhood Plans should identify new land, and safeguard appropriate existing land, necessary for the delivery of the economic strategies for Cornwall. These allocations should be based on an assessment that considers the ability of the quantity, nature and quality of existing space and any commitments to meet the space requirements set out in Policy 2a and the needs of particular sectors.”

It then goes on to detail what such an assessment should include. However it is not clear in the SADPD whether such an assessment has taken place to underpin the selection of the allocations.

The China Clay CNA Employment Summary table (February 2016) for the Local Plan lists both the completed and extant employment site permissions that have contributed towards the setting of the Local Plan’s targets. This quantitative exercise concluded that there is an oversupply of both office and industrial space in the CNA. However without a finer grain assessment of the quality of this supply it is not possible to conclude that all of this land will be delivered and whether it is fit for purpose to meet the objectives of either the current Local Plan’s economic strategy, other growth sectors in the Cornwall SEP or indeed the Regeneration Plan for the China Clay area. The role of the SADPD was meant to further test both the appropriateness of the targets in the Local Plan and whether the traditional locations for employment in Cornwall were still fit for purpose.

The SADPD (paragraph 2.11) states that assessments have been undertaken of employment site opportunities within “each of the towns” and that these have been assessed against their “deliverability and commercial attractiveness”. However it is not clear what the scope and currency of this assessment was. The evidence behind this needs to be published so that it can be properly scrutinised. It refers to a document called “Cornwall Employment Sites Assessment 2015” that can be found on the website however this document does not appear to be readily available or listed as part of either the SADPD or the Local Plan evidence base. This document needs to be published for transparency. Even if this work has been undertaken it is still open to criticism in that it is limited solely to a list of main towns only whilst ignoring more needy areas or areas better located to access local and regional markets. It does not constitute a Cornwall-wide assessment. Unless this work is now undertaken through the SADPD process the result will be that economic growth will continue to be focussed at the main settlements only as opposed to using the plan-led system to pro-actively identify sites in other locations better suited to the new growth sectors.

 Sustainability Appraisal

The SA (page 8) states that “work has been carried out since 2010 in developing the Allocations DPD” with the early stages focussing on Draft Town Framework Plans for “the majority of main towns in Cornwall”. This work formed “the foundation from which the Allocations DPD was developed”. There is no indication that the recent outcomes of the Local Plan process and the Inspector’s recommendations for a finer grained employment review have been taken on board in preparing the SADMP. The SA is therefore inherently limited in that it can only undertake a comparative assessment of sites from an already pre-selected list of main towns. It is assumed that as new sites are put forward through this consultation stage that the SA will be updated for the next iteration.

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 China Clay CNA Regeneration and Indian Queens

In relation to the China Clay CNA, the SADPD currently only includes allocations for the eco- communities. In Section 10 the plan does make reference to the wider regeneration context of the China Clay area however it fails to specifically mention the adopted St Austell, St Blazey and China Clay Regeneration Plan (CCRP, 2012) as noted above. On the Council’s web page for the CCRP it states the following (O3 emphasis):

“The Regeneration Plan does not allocate sites, but provides criteria that large-scale and strategic developments should achieve in order to bring about sustainable and high-quality development within the plan area..” Detailed site specific information will be found in the Local Plan through limited strategic site allocations..” The expectation appears to be that the Local Plan and assumedly the SADPD will make site specific allocations (some of a strategic nature) that will take forward the essential aims of this Plan. However only the eco-communities and a small number of existing sites have as yet been allocated.

The Local Plan states under Objective CC1 – Regeneration that a specific objective for the China Clay CNA area is to “support the regeneration of villages and the local economy” (paragraph 12.16). Furthermore the 2012 Regeneration Plan states that:

“To help achieve economic growth the Council will plan proactively to meet the development needs of existing and emerging businesses…” (paragraph 31, O3 emphasis)

Despite these stated objectives of both the Local Plan and the Regeneration Plan, it is not clear how the SADPD is currently proactively planning for the regeneration of either locations like Indian Queens or the wider area. It does not reflect the geographic extent of the regeneration area nor does it reflect its key objectives. Particularly given the current economic uncertainties in a post- Brexit environment, Cornwall’s regeneration areas should be a key focus for pro-active plan- making. As such it is recommended that either Section 10 is broadened to cover the whole of the Regeneration Area or that a new section is included in the next iteration of the SADPD.

 Neighbourhood Planning

In Section 4 of the SA 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..”

In the case of Indian Queens, the wider parish of St Enoder was designated in 2013 for the purposes of preparing a NP. It is assumed therefore that this is the reason why the SADPD does not cover this area? Notwithstanding the important role of NPs; it seems unreasonable to expect parishes with limited resources to undertake the level of quantitative and qualitative employment land analysis that is required to underpin robust allocations. Given that in this location the SADPD appears to be running ahead or in parallel with the NP preparation; it would be far more proactive for the SADPD to extend to the whole of the CNA and then for the NP to reflect any identified allocations, rather than the other way around. Leaving allocations to NPs that have not yet commenced could result in delays to the delivery of much needed economic development.

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 Alternative Site Proposal – Land at Indian Queens

Our client has land interests at Indian Queens that they are keen to promote through the SADPD process by working collaboratively. The site of circa 26ha (see site location plan attached) would be capable of delivering a mix of uses, including economic, some retail and leisure development that would contribute towards the Local Plan targets, the LEP’s Economic Strategy and the CCRP’s regeneration objectives. As well as being readily accessible to the whole of Cornwall via the A30 junction, the site is also well connected to Newquay Airport and local rail services, as well as the recently completed incinerator to the south. It is therefore a sustainable location which would prove attractive to inward investors and existing businesses in creating a modern well planned, mixed use development that also serves the adjoining community.

The village of Indian Queens is centrally and strategically located along the A30 corridor and has the potential to provide a hub for a new employment/commercial destination. The SADPD already acknowledges the current contribution of employment land at Indian Queens through Policy C-E4: Indian Queens / Moorland Industrial Estate which protects these existing employment sites as ‘strategically important employment sites safeguarded outside of the larger towns’. The Council and SADPD whilst already acknowledging the role of Indian Queens as a sustainable location for economic growth do little to plan proactively for further growth beyond safeguarding a small extension to the existing industrial estate.

 Conclusion

In summary we welcome the publication of the SADPD and support its role in promoting growth in Cornwall. As set out above we are concerned that thus far the SADPD has not been sufficiently informed and shaped by the recent outcomes of the Local Plan process and the Inspector’s recommendations. In particular the Plan does not appear to have been informed by an up to date quantitative and qualitative employment assessment as required by the NPPF and the Inspector. In continuing to focus on a list of main towns only the SADP is missing the opportunity to promote growth along key nodal points of the A30 and other locations better suited. The A30 is the catalyst for encouraging new growth and new sectors into Cornwall. It is arguably the best opportunity for linking Cornwall to the wider markets outside of Cornwall but the SADPD currently misses the opportunity to emphasis this. Locations that could also contribute towards sustainable economic growth and foster regeneration of the wider area, such as at Indian Queens, are so far excluded.

As Indicated it is now the intention of the Consortium to promote land at Indian Queens for inclusion with the SADPD whilst working with the emerging NP.

Yours sincerely

Jane Fuller Associate Planning

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REP 0233

Strategic Planning Cornwall Council County Hall Treyew Road Truro TR1 3AY Email: [email protected]

14 November 2016

Dear Sir/Madam,

RE: Cornwall Allocation document– preferred options RSPB RESPONSE

The RSPBs main interest in this document is to ensure that there are no potential impacts of site allocations on Cornwall’s wildlife assets, especially Natura 2000 and Ramsar sites, nationally designated Sites of Special Scientific Interest (SSSIs), County Wildlife Sites (CWS) and non-designated coastal and maritime BAP habitats which are important for priority bird species, a plays a role in maintaining and enhancing the wildlife interest of the county of Cornwall.

In our view the current sites allocation document is not consistent with the National Planning Policy Framework (NPPF) 11 or the nature conservation polices (23 and 23A) in the Cornwall Plan or the associated habitat regulations assessments (and resulting studies) and therefore have the following objections:

 The site allocations (Penzance-Newlyn [all], Falmouth – Penryn [FP-St, FP-St2, FP-St3, FP-St4], St Austell [All], Eco-communities [ECO-M2], Saltash [SLT –UE2]) have not been adequately informed by the Cornwall Council Recreational Strategy (policy 23A of the local plan) and needs to be amended (objection).

- Does not adequately set out and explain the key environmental features in growth areas (Penzance-Newlyn, Falmouth – Penryn, St Austell, Eco-communities) and the implications of their levels of protection and the priorities for protection and enhancements (policy 23) and therefore requires changes (objection).

- Allocations (PZ – H1/ PZ- E4, H-E2, H-E4), potentially damage sites of national or international importance (and or their features) for wildlife and therefore should be removed while others require changes (FP-St, FP-St2, FP-St3, FP-St4, ECO-M2, SLT –UE2) to comply with policy 23 and 23A (objection).

Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe PENZANCE Cornwall TR18 3LP rspb.org.uk

Patron: Her Majesty the Queen Chairman of Council: Professor Steve Ormerod, FIEEM Chief Executive: Dr M ke Clarke Regional Director: Nick Bruce-White The Royal Society for the Protection of Birds (RSPB) is a registered charity: England and Wales no. 207076, Scotland no. SC037654

- Allocation (BD-UE2) Potentially destroys an area of important ecological resource and associated ecological corridor and needs to be amended to comply with policy 23 and 23A (objection).

We therefore object to the document in its current form and have made recommended changes as set out in Annex 1.

We would also like to comment of the ability to read and interpret some of the information provided. Maps when printed out or enlarged were unreadable and therefore we are concerned that this may have disadvantaged consul tees.

If you have any queries regarding this response please do not hesitate to contact me.

Yours sincerely

Paul St Pierre Conservation Officer

Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

Annex I

RSPB’s area of interest

In particular we are concerned about the potential impacts of site allocations on Cornwall’s wildlife assets, especially Natura 2000, Ramsar sites, and Important Bird Areas (IBAs), nationally designated Sites of Special Scientific Interest (SSSIs), County Wildlife Sites (CWS) and non-designated coastal and maritime BAP habitats which are important for priority bird species.

This includes the Natura 2000 network of sites consisting of the Tamar Estuaries Complex Special Protection Area (SPA); The Fal Bay to St Austell Bay (pSPA), Marazion Marsh (SPA); The Lizard Special Area of Conservation (SAC); Breney Common & Goss & Tregoss Moors SAC; Fal & Helford SAC; and the Isles of Scilly (SPA/Ramsar site).

It also includes the network of non-designated Important Bird Areas (IBAs) consisting of Bodmin Moor IBA; the South Cornwall Coast IBA; the West Penwith Coast & Moors IBA; and the Isles of Scilly IBA.

It also includes the Hayle Estuary & Carrick Gladden SSSI, part of which is owned and managed by the RSPB as a nature reserve, other SSSI’s that are designated for birds, sites that support nationally important populations of birds and the county’s extensive areas of coastal grasslands and heathlands which are important for nationally rare bird species such as chough.

Growth Areas

3. Penzance & Newlyn

The RSPB are concerned about the potential impact of growth in this area on the Marazion Marsh SPA/SSSI and RSPB Nature Reserve, especially allocations adjacent to this protected site or ones that are connected to its watercourse or floodplain, or result in increases in recreational activity.

Page 28 Biodiversity

3.66

The priority area for biodiversity enhancement is around the Marazion Marsh SPA/SSSI, the most important wildlife site in the growth area. Objection.

The text should be amended to include:

The most important sites for wildlife in this growth area is the Marazion Marsh Special Protection Area and Site of Special scientific Interest. The presumption in favour of

Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

development does not apply to developments that affect this site. Adjacent or connected land should be safeguarded to secure opportunities to buffer it from disturbance and pollution, provide resilience and allow it to adapt to climate change and continue the eco-system function through habitat creation opportunities and enhance it through habitat enhancements and creation, especially on low lying land or where it is connected through existing watercourses. Housing or tourism developments within 10km of the site will need to contribute to a series of onsite and offsite measures to protect the site.

Site Allocations

The RSPB are concerned about the potential impact of growth in this area on the Marazion Marsh SPA/SSSI and RSPB Nature Reserve. Especially allocations connected, adjacent or within areas which would be suitable for connecting or recreating habitat to support the protected sites resilience to climate change and the ecosystem functions it provides. In addition we are concerned about the potential increase in recreational impacts that can arise from off-site developments which will need to be addressed.

Housing or tourism developments within 10km of the site will need to contribute to a series of onsite and offsite measures to protect the site from recreational disturbance.

Allocations: PZ – H1/ PZ- E4

These allocations lie adjacent to the Marsh SPA and therefore have the potential to have direct and indirect effects and overlap with existing green infrastructure. To be in line with the NPPF these allocations should be removed and safeguarded for their potential eco-system services they provide through flood defence, water quality, habitat recreation and strategic areas of green infra-structure. Objection.

The text and maps should be amended to remove: PZ – H1/ PZ- E4

Additional Requirements & Considerations

Only some of the site allocations are identified as contributing (within about 3km of the site). All sites within 10km should be included (policy 23 A). Objection.

Hayle Town

The RSPB are concerned about the potential impact of growth in this area on the Hayle Estuary and Carrack Gladden SSSI and RSPB Nature Reserve.

Allocations: H-E2, H-E4

These two proposed allocations will remove and isolate the Hayle Estuary from surrounding farmland on which a number the SSSI features (notably curlew, golden plover and lapwing) depend. This is at the southern end of the estuary where site Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

allocations would link Lelant on the west side with Hayle on the east side potentially damaging the existing green corridors and habitats that the features use. Objection.

The RSPB recommend that the council undertake a wider assessment of the impact on the ecological function of the farmland for the SSSI features so they are maintained or enhanced.

The text and maps should be amended to remove: H-E2, H-E4

7. Falmouth & Penryn

The RSPB are concerned about the potential impact of growth in this area on the Fal to St Austell pSPA, Fal and Helford SAC and associated SSSI’s.

Page 136 Biodiversity

7.71

The biodiversity description fails to mention the Fal Bay to St Austell Bay pSPA. Objection.

The text and maps should be amended to include:

Fal Bay to St Austell Bay pSPA.

Allocations: FP-St, FP-St2, FP-St3, FP-St4

Additional Requirements & Considerations

These sites will also be expected to provide an appropriate contribution to mitigate against water based recreational impacts at the SAC. Objection.

The text should be amended to include the following point:

These sites will also be expected to provide an appropriate contribution to mitigate against water based recreational impacts at the SAC.

9. St Austell

Page 193 Biodiversity

9.69

The RSPB are concerned about the potential impact of growth in this area on the Fal Bay to St Austell pSPA, which is not mentioned in this section. Objection

The text should be amended to include the following point:

Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

The Fal Bay to St Austell Bay pSPA follows the coastline and extends seaward from this growth area. All development should consider any potential recreational impacts resulting from increased housing and tourism developments on this site.

Allocations: All

Additional Requirements & Considerations

Housing or tourism developments within 10km of the site will need to contribute to a series of onsite and offsite measures to protect the site from any recreational disturbance that is highlighted in the Cornwall recreationally study.

The text should be amended to include the following point:

These sites will also be expected to provide an appropriate contribution to mitigate against water based recreational impacts at the SPA.

10. Eco-communities

The RSPB are concerned about the potential impact of growth in this area on The Fal Bay to St Austell Bay pSPA, breeding nightjar, breeding lesser black backed and herring gull

Biodiversity

There is no section of biodiversity; therefore there is no clear mapped or written information on how policy 23 and 23A have been used to determine the location, scale and mass of housing for this growth area or where the main opportunities are for protecting, connecting, creating or restoring habitats are located. The section will also need to refer to the Fal Bay to St Austell Bay pSPA and any potential impacts arising from recreational studies. Objection.

The text should be amended to include the following:

Biodiversity

The ecotowns growth area at Bal and Carcleaze is located in an area with significant heathland and wet woodland resource (list SSSIs and County wildlife sites in the Clay Country Area) and supports a large area of mining land which could provide the largest recreation opportunities for these habitats in the county. It is important that this development does not destroy, fragment or sterilise significant areas of biodiversity enhancement or gain. It should also take into account the needs of significant populations of protected species (e.g. nightjar and willow tit) to ensure the greenspace supports their presence. Housing or tourism developments close to the Fal Bay to St Austell Bay pSPA will need to contribute to a series of onsite and offsite measures to protect the site from any recreational disturbance that is highlighted in the Cornwall Council Recreationally study. Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

The following map should be inserted:

Green infrastructure strategy Map

Allocations: ECO-M2 Par Docks

Additional Requirements & Considerations

Housing or tourism developments within 10km of the Fal Bay to St Austell Bay pSPA will need to contribute to a series of onsite and offsite measures to protect the site from any recreational disturbance that is highlighted in the Cornwall recreationally study. Objection.

The text should be amended to include the following point:

These sites will also be expected to provide an appropriate contribution to mitigate against water based recreational impacts at the SPA.

Bodmin

The RSPB are concerned that current allocations will destroy or damage areas identified as having existing ecological resource or green corridors.

Allocations: Bd-UE2

This allocation destroys an area of important ecological resource and corridor. Objection.

Additional Requirements & Considerations

The following should be inserted:

This development should be shaped to ensure that open space provision includes areas of important ecological resource and their corridors or those areas are removed from the allocation footprint.

Saltash

The RSPB are concerned about the potential impact of growth in this area on the Tamar Estuaries Special Protection Area (SPA), Plymouth Sound & Estuaries Special Area of Conservation (SAC) and associated SSSI’s.

Allocations: SLT-UE1

Additional Requirements & Considerations

This site will also be expected to provide an appropriate contribution to mitigate against any identified recreational impacts on the SPA as well. Objection.

Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

The text should be amended to include:

This allocation will provide mitigation towards recreational impact from the development relating to the Plymouth Sound & Estuaries SAC and Tamar Estuaries SPA.

Cornwall Office Tel No 2 The Old Smelting House Chyandour Coombe rspb.org.uk PENZANCE Cornwall

REP 0235(2)

WRITTEN SUBMISSION

DRAFT SITE ALLOCATIONS DPD

for

PROPOSED RESIDENTIAL DEVELOPMENT

TREVISPEN VEOR

TRISPEN, ST. ERME

TRURO TR4 9BH

for

PROGRESSLAND LTD

1 FAIRMANTLE STREET

TRURO TR1 2EG

Contents:

Introduction

1.0 Site & Location

2.0 Planning Policies

3.0 Evaluation

4.0 Assessment

5.0 Other Matters

6.0 Conclusion

7.0 Appendices

Martin S Lee, MA MRTPI AMInstLM MTCPA Chartered Town & Country Planning Consultant Martin S. Lee Associates Ltd. Wyndham, Station Road, Hemyock EX15 3SE

INTRODUCTION

This appraisal has been prepared in representation on the draft Site Allocations DPD for Cornwall in anticipation of any formal application for planning permission for residential development on land at Trevispen Veor, Trispen, St. Erme, Truro, TR4 9BH.

1.0 SITE & LOCATION

1.1 Context

1.1.1 Trevispen Veor comprises open meadow abutting the eastern flank of the village of Trispen at the northern end of St. Erme near Truro and defined by well- established field boundary hedges and banks. The land varies in level, generally falling towards the east and open countryside beyond. The full extent of the land in the same ownership is shown outlined in red on the attached plan. The individual field parcels which this enquiry relates are outlined in green on the same plan.

1.1.2 In accordance with the Government website “Magic” the following designations have been considered:

Designations Relevant - Yes/No Settlement Development Boundary (SDB) Yes, abutting, but outside High Amenity Area (HAA) No Article 4 Direction No Coastal Zone (CZ) No Area of Outstanding Natural Beauty (AONB) No National Park (NP) No Statutory Listed Building (LB) No Site of Scientific Special Interest (SSSI) No Scheduled Ancient Monument (SAM) No Tree Preservation Order (TPO) No Flood Risk Zone - Sea or River (FRZ) No Nitrate Vulnerable Zone (NVZ) Yes, groundwater & eutrophic Public Right of Way (PROW) No

1.1.3 The village of Trispen lies within St. Erme Parish and the administrative area of Cornwall Council as Local Planning Authority.

1.2 Planning History

1.2.1 Pre-application Enquiry: PA14-02480-PREAPP - Land at Trevispen Farm Trispen – LPA letter of response from Mark Ball dated 4th September 2014 (copy attached).

2.0 PLANNING POLICIES

2.1 National Planning Policy Framework confirms the following key priorities:

• Achieving Sustainable Development • Supporting a prosperous rural economy • Requiring Good Design • Delivering a wide choice of quality homes

2.2 Cornwall Local Plan is the emerging development plan for the area. Its advanced progress towards formal adoption (currently anticipated by the end of November 2016) means that the draft policies it contains are attributed more weight by the Local Planning Authority in the consideration and determination of formal applications for planning permission policies ‘Saved’ from Carrick District Plan.

The 2014 & 2016 pre-application enquiry responses advised that emerging Cornwall Local Plan policies 1, 2, 3, 6, 8, 9, 11, 13, 14, 17, 22, 23, 24, 26, 27, 28 and PP6 have relevance.

2.3 St. Erme Parish Plan 2005: Highlighting local support for small-scale, sustainable residential development respecting local character and meeting local housing need, the Plan was prepared when Carrick Council was the Local Planning Authority responsible for the area. No move has been made to update the Parish Plan. A start has been made on moving to prepare a Neighbourhood Development Plan but no concrete progress is evident other than a housing survey for which the report and conclusions have yet to be publicly released.

2.4 Involvement - Professional Consultations: No direct approach to any statutory consultee, including the Parish Council, has been made. Neither have nearest neighbouring property owners been contacted. Future pre-application consultation/engagement with these parties is intended to provide the opportunity to identify and resolve important site specific or local issues before any formal application for planning permission is submitted for formal consideration and determination by the Local Planning Authority.

3.1 EVALUATION

i. Policy:

a. Principle: If an application for full planning permission were to be made, the acceptability in principle (under emerging and adopted planning policy) of new residential development has to a certain degree already been established by the most recent attitude of Cornwall Council to new development outside of settlement development boundaries defined by the previous District Council, where such development can be shown to be in a sustainable location and without substantial adverse impacts on such issues as landscape, highway safety or residential amenity.

b. Exception: In the absence of formal allocation as a housing site or inclusion within the settlement development limit the Council currently consider the site would fall for consideration and determination under Policy 9 of the Cornwall Local Plan which relates to exception sites where affordable housing provision forms fifty percent or more of the total development proposed.

c. Housing Land Supply: The Council’s view is reinforced by their current assertion that they do have a five-year land supply available for new housing to meet the target of housing numbers accepted by the Local Plan Inspector. However, there are already questions over whether this assertion can be demonstrated within the draft Site Allocations DPD allowing that this document identifies certain areas of the County will have sites allocated not in the DPD but in Neighbourhood Plans. Accordingly, it would be appropriate to consider increasing the numbers provided for by allocating this site to ensure adequate levels of provision, particularly when there is current evidence of likely under provision for Truro from examination of the newly published draft Truro & Kenwyn Neighbourhood Plan which fails to allocate any housing sites at all within that Plan area. Trispen/St. Erme lies very close to the boundary of that Plan area, within the Truro & Roseland CNA and forms an immediate part of the residual housing area serving and surrounding Truro. St. Erme’s own proposed Neighbourhood Plan is only at the inception stage with no documentation or draft policies produced or consulted upon. A housing survey is understood to have been undertaken very recently but its report and conclusions have not yet been made publicly available. It is intended that direct engagement with the Neighbourhood Plan process in St. Erme will be made in an endeavour to have the site allocated within the Plan. However, due to the very slow progress in that Plan’s development it is essential that this site is recognised and allocated in the Site Allocations DPD to ensure its development may be secured in the required five-year period.

d. Sustainable Location: Trispen/St. Erme lies within a short distance of the City on a major arterial route leading into it with substantially improved direct access to the A road. Accordingly, it forms a natural and sustainable location for new development serving the housing needs of Truro, which would also greatly benefit the settlement of Trispen/St. Erme itself.

ii. Transport and Highways Impacts: There is likely to be genuine concern where visibility is poor or impaired and where additional dwellings may increase vehicular movements to an unacceptable level. The categorisation of the road, together with road speeds would be taken into consideration. Where concerns are expected, they should be addressed by providing an appendix to the Planning Statement. This would take the form of a Transport Assessment to confirm comparative traffic levels between the existing and proposed use and would include details on the lack of potential adverse impacts on the local road network. This Assessment would also determine the specification for altered/new site access arrangements.

iii. Landscape Impacts: The sensitive nature of the landscape within Cornwall means that the LPA will be likely to insist on a landscape impact assessment. Such an assessment would need to be accompanied by an arboricultural assessment of likely impact and practical mitigation in relation to any existing, mature trees and hedgerows. These assessments would form appendices to the Planning Statement.

iv. Contamination Risks: Concerns in relation to potential historic industrial activity would need to be addressed through an appraisal of the potential risks of contaminants being present on site. In the absence of any historical evidence of potential contamination such an appraisal may comprise an integral element of the Planning Statement.

v. Flood Risk: In areas not identified as subject to flood risk, the Planning Statement will need to include an assessment which addresses surface water drainage issues within the site.

vi. Ecology: An ecological appraisal may be required to assess the potential presence of protected species of fauna and flora, as part of the Planning Statement.

vii. Sustainability: Justification that the proposed development is both desirable and practical will need to be included in the Planning Statement. When taken in the literal sense, “desirable” relates to a good design, something that people would like and “practical” relates to whether the site is capable of accommodating the development proposed without unacceptable harm to interests of acknowledged importance (such as landscape character). The character of new residential development on site combined with the scale of the plot and the presence of substantial hedgerows and the degree of separation/privacy from neighbouring properties appears to provide realistic opportunity to provide new residential development within the site as an extension to the existing settlement.

3.1.1 Options & Process - To secure formal approval for new development one of the following two options could be pursued (the LPA pre-application responses of 2014 & 2016 provide additional detail in supplement to the following on the submission requirements for any formal application presented to the Council):

i. Outline Consent

a. Any formal application to the LPA, would need to include:

• Planning fee (payable to Cornwall Council and dependent on total application site area) • Planning Application Form • Planning Statement (with Appendices) • Site survey (topographical) and indicative proposal drawings (site layout, sections and external elevations) • Planning statement – To include any additional supplementary statements or documents that may be required, as appendices.

b. Once submitted, Cornwall Council will aim to validate within five working days.

c. The LPA should then aim to issue a formal decision within a determination target period dependent on the scale of development proposed. The LPA could issue an approval or refusal. Any approval would be subject to conditions requiring further information on detailed design to be formally submitted to and subsequently approved by the LPA, prior to any work commencing on site. This subsequent application would attract a separate fee payable to the Local Planning Authority. Refusal of consent or failure to issue approval within a reasonable timeframe at either stage would be open to appeal.

3.1.2 Full Planning Application

In addition to the information required for an outline application, full architectural drawings would need to be submitted showing internal floor layouts, site drainage, access, parking, landscaping and external materials.

4.0 ASSESSMENT

4.1 Siting, Form & Landscape Impact – In considering the potential for additional dwellings on site over and above the twenty or so units which pre-application responses from the Council have pointed to, it will be essential to determine the contribution such development could make to housing land supply within the Parish, Truro area and County. It is accepted that the area currently falls outside any defined settlement development limit and is not allocated for development within the previous or emerging Local Plan, but at the same time it is also recognised that it would form a logical extension to an existing settlement with a range of services which in its turn has easy access to nearby larger settlements which provide a broader range of services. The site is substantial enough to enable any new development within it to present a very open, traditional, rural character to the public view/streetscene. Any proposal on this site would need to resolve precise form, layout and scale through direct pre-application discussion with the Local Planning Authority.

4.2 Transport and Highways Impacts – The existing points of road entrance have shortcomings which would benefit from alterations to provide improved advance visibility at the existing entrance point or even select a wholly new entrance point. Whilst is possible that the existing entrance would require modification in some form it is likely that an additional access might reasonably be required to serve the scale of development proposed.

5.0 OTHER PLANNING RELATED MATTERS

5.1 Community Infrastructure Levy (CIL) – Any submission to the LPA would be subject to a requirement to pay the relevant level of CIL contribution to the Council. At present Cornwall Council do not have an approved CIL Charging Schedule in place and will not do so until the emerging Local Plan has been adopted which is not now anticipated until sometime late in 2016 or early 2017 (the draft charging schedule may be viewed on the Council website). Any proposed development’s liability for such contributions under this Schedule will thus be dependent on the timeframe for consent in relation to the formal adoption of that Schedule.

5.2 S.106 Contributions – These would relate to payments towards assisting affordable housing provision in the area and could require the services of a solicitor to complete any formal agreement required with the Council.

5.3 Viability: Whilst it is unlikely that the cost of any such contributions will individually be likely to jeopardise the viability of this type of project, it is always advisable to be aware of same in advance of starting any scheme. Any formal pre-application approach to the LPA would resolve the precise figures applicable in each case and a viability assessment would need to be prepared on that basis.

6.0 CONCLUSION

6.1 The site appears to have genuine and realistic potential to secure approval for new residential development, but neither scale, form, nor timing in relation to a successful outcome can be guaranteed. A formal pre-application enquiry submission to the Local Planning Authority was made in 2016 as a follow-up to that submitted in 2014 to secure the most up to date assessment from officers of the current and anticipated planning policy framework and housing need within which any formal application for planning permission is likely to be considered and determined.

6.2 The conclusion of the 2016 pre-application responses received is that the principle of housing development on the site would be acceptable, but that under the emerging Plan it would be treated as an exceptions site in the absence of its formal allocation as a new general housing site and/or inclusion within the defined settlement development limit.

6.3 The St. Erme Neighbourhood Plan is unlikely to progress swiftly enough to address the allocation of this site within the five-year period. The Draft Truro & Kenwyn Neighbourhood Plan has failed to allocate any sites, contrary to anticipation expressed within the Draft Site Allocations DPD. If allocated for general housing development the site would address this shortfall and provide substantial opportunity for a large, sensitively designed development in a highly sustainable location, capable of making a major contribution to help meet Cornwall’s five-year housing land supply requirements.

Statement prepared 14/11/16 by:

Martin S. Lee, MA MRTPI AMInstLM MTCPA Chartered Town & Country Planning Consultant

7.0 APPENDICES

i. Site Location & Aerial View ii. Site Extent (Outlined in Green) iii. Magic Map (Listed Building locations) iv. Flood Risk Map v. LPA Pre-application Enquiry Responses - PA14-02480-PREAPP - PA16-01285-PREAPP