101 ST DENNIS PARISH COUNCIL. Set out below are the comments of St Dennis Parish Council on the Draft Cornwall Local Plan,the proposed Community Infrastructure Levy and the Gypsy and Travelling Communities Plan. 1). Draft Local Plan 2010-2030. i. The Parish Council are concerned that the amount of housing development proposed for the ‘St Austell,St Blazey,Fowey and Lostwithiel and China Clay Area’ is excessive when compared to the other 16 areas of Cornwall identified in the Plan. ii. The number of dwellings both existing and proposed is 15.4% of the total for Cornwall (42,250) and the largest by far in the 17 areas identified. Similarly the number of future dwellings proposed (3,508) excluding existing commitments represents 15.4% of the total suggested for Cornwall (22,716). iii. Within these figures the total proposed for the China Clay Network Area (1,400) is 21.5% of the total for all of the Restormel Area (6,500). iv. The Parish Council concluded that this amount of housing development for the China Clay CNA was too much particularly in the light of the amount of development that had taken place already in the area,a point which is acknowledged in the proposed Plan. v. The Parish Council also notes that the proposed Eco Community (2,300 dwellings) impinges on the China Clay CNA and felt that this development together with the amount proposed for the China Clay CNA was too much and could compromise the individuality and separation of the villages in the area.It was important that the amount of development allowed did not lead to the creation of an urban sprawl. vi. Any development permitted in the China Clay villages should be of a small scale to protect their sustainability and character and contain a significant amount of affordable housing.Any data contained in parish plans regarding housing demand should be considered. vii. One Councillor felt that any development in St Dennis should contain an amount of 1 and 2 bedroom bungalows suitable for the elderly which could release larger properties for families. viii. Affordable housing should only be available to local people in the first instance. 2). Community Infrastructure Levy (CIL) – Proposed Charging Schedule. The Parish Council considered the CIL proposals and agreed that the following comments should be made:- i. It would support the introduction of a Community Infrastructure Levy. ii. It did not agree with the proposal that there should be no CIL for developments in the ‘Housing Zone H3 area’ except for affordable housing.There was a danger that if no CIL was imposed developments could be denser and may not contain sufficient amenity and recreational ‘green’ space.A lack of space within developments did not encourage people to have pride in their environment and could lead to conflict. 3). Gypsy and Travelling Communities - Strategy and Delivery Plan. i. The Parish Council is concerned to note that for all the 6 areas of Cornwall a total of 237 residential pitches are proposed for the period 2006-2020 of which only 91 had planning permission.A further 146 pitches were apparently required to the year 2020. ii. Within the total proposed residential pitches (237) the Council noted that 103 already existed (47) or were proposed (56),for the Central 2 area (formerly Restormel) which equated to 43% of the total for the whole of Cornwall.The Council were opposed to this level of saturation in one area and felt that this should be challenged. The Parish Council is also concerned at the short space of time allowed for a response to the documents which considering the limited resources of Parish Councils was not sufficient to make a thoroughly considered response. Similarly the Parish Council would have preferred that the response deadline was later than the 22nd April so that Parish Councils in place after the local elections could have responded. 103 COMMENTS REGARDING THE CORNWALL LOCAL PLAN 2010 – 2030 VISION AND OBJECTIVES. Policy 1. The Presumption in favour of sustainable development will be heavily biased in favour of development. The three criteria used to define sustainability are quoted as improving social, economic and environmental conditions. Inevitably the environmental criteria will be side tracked as the vast majority of new development will be on green field sites leading to an inexorable loss of countryside. Sustainability is subject to a wide range of interpretations and will be used by developers to suit their purposes and any doubts raised in interpretation are stated to favour development. Policy 2. The need for adequate new infrastructure to accommodate new development has been ignored. A glaring omission is the inadequacy of Treliske Hospital to accommodate an increase in admissions. 1 The requirement for new employment opportunities is supported, but to be located on sites classed as brownfield. 2 The provision of this amount of employment floor space should be located on brownfield sites and not be located in out of town locations. 3 Why have offshore renewables not been mentioned. Restrictions are required to ensure that on shore renewable projects do not impact adversely on the countryside. 4 The provision of 42, 250 homes is excessive and far exceeds the requirements of the local population. The provision of 40,000 homes in the previous Structure Plan has failed dismally to provide for local needs, but catered for an influx of in migrants. The criteria for affordable housing in terms of pricing needs to be rigorously re-assessed and needs to be largely social rented housing. 5. The enforcement of good design is universally poor and has led to a polyglot collection of housing estates with pocket handkerchief gardens, inadequate parking provision and poorly located open space with no maintenance provision. 6 AONB’s are not receiving the protection that they require and the designation of AGLV’s has been quietly dropped allowing next to no protection over these areas. 7 The present strategy of dispersed development has provided housing in local dormitory settlements, but not associated jobs, so commuting is ever more widespread. 8 Supporting economic regeneration is all very well, but it will not prosper without adequate infrastructure and why has Falmouth been ignored, a town which should be taking advantage of its deep water location for a wealth of maritime industries and cruise liner facilities let alone a facelift. Policy 3. In general this policy is supported. It is noted that large scale development will be located “in”, but only too much is located on the edge or well outside in the countryside and large scale needs to be defined. We note that housing growth outside the main towns nearly always does extend settlements, so this part of the policy should be reworded so that any growth outside boundaries should be strictly limited and confined to that required for local needs. Policy 4. It is noted that retail and commercial development outside existing centres must show a need, etc. Whether they do significant harm to the countryside or are located in areas designated for their environmental qualities is ignored. The development proposed for the Eastern Development at Truro breaches this Policy and the proposed development at COYTE FARM St Austell if approved would flout this policy. We query whether the Council has the will to enforce this Policy. In terms of the target provisions it is asked why Falmouth and Penryn have a housing target far exceeding that of the last Structure Plan. As we mentioned in Policy 2, we regard the whole housing provision as excessive. Policy 5. No comment. In general support. Policy 6. Every effort needs to be made to deter the building of houses, which in their location could become desirable second homes. Although it is recognised that the country is suffering from a prolonged economic downturn, the plan is increase the rate of house building over and above the previous 10 years of relative prosperity. This will not help local need as this market housing is well beyond the means of local people and is geared to satisfy incomers. Major developments should incorporate the needs of those aspiring to climb the housing ladder and the ageing population. Just to consider the problem is not enough, concrete proposals are a pre-requisite for the granting of a planning application. The Cornwall Housing Register urgently needs to be updated as it includes an unknown number of applicants housed elsewhere some overseas. Policy 7. The use of recently built agricultural buildings for dwellings should be prohibited. Policy 8. Attempts to supply more affordable housing in the County have been a feature from the very first Structure Plan and we support every effort to achieve this, but not on the back of more market housing Policy 9. Housing developments outside settlement boundaries should not be permitted within designated areas such as AONB’s and AGLV’s except for a small number with a dozen maximum for proven local need. Cross subsidies from market housing should not be permitted. New housing should not be permitted outside the boundaries of hamlets without any facilities and services. Only infill housing should be permitted. A relaxation of this rule will lead to ribbon development and the intrusion of housing in to the countryside and can not be credited as sustainable. Policy 10. No comment. Policy 11. Object as could be a loophole for developers to avoid or circumnavigate their obligations. Policy 12. No comment. Policy 13. Prominent and skyline development should not be permitted. Concrete block is the most common building material in the County. Unfortunately minerals within the blocks or the aggregates used leach out after a number of years and render buildings drab and unattractive.