Councillor Jacqi Hodgson South Hams District Council Ward Member for Dartington & Staverton Totnes Town Council Member for Bridgetown [email protected] 01803-840526 / 07922 411266

c/o home address; 9, Argyle Terrace, Totnes, Devon. TQ9 5JJ

25th April 2017 Submitted by email to plymouthplan@plymouth.gov.uk

Joint Local Plan Team, Planning Department, Ballard House, West Hoe Road, Plymouth. Devon. PL1 3BJ

Dear Sir / Madam,

Re; Pre-submission Regulation 19 Consultation – Joint Local Plan (JLP) 2014 - 2034

I wish to make the following submission with regard to the above document under the current consultation period. As South Hams District Council (SHDC) Ward Member for Dartington and Staverton, and Town Councillor for Totnes, the foci of my comments are made with particular reference to that area and adjacent parishes, however I also submit comments on the wider spatial strategy and the likely impact on South Hams and the wider jurisdiction of the JLP.

Detailed comments with reference to numbered points as indicated in the JLP:-

1.1: South Hams Our Plan was never completed

2. Vision part 2: Welcome aspirations but these will not be met through this JLP as bullet pt 1: residents have not been empowered to create strong communities as the neighbourhood plan groups have not been asked for input in terms of their plans or proposed housing numbered being integrated into this JLP. Bullet pt 3: local needs are for affordable and social housing. This plan indicates that LPAs will seek 30% affordable housing on major developments. However even affordable housing in Totnes and Dartington is estimated to need at least a £70,000 household income; this is not considered affordable for most people in South Hams where the income to house price to incomes ratio is twelve times earnings1

2.3 Population. According to ONS statistics2 the JLP combined area population growth is projected to rise from 399,914 in 2014 to 434,852.74 (quoted in the JLP as 434,900) by 2034. This gives an average growth rate of 8.7% across the JLP. However the extrapolated breakdown (by myself) of the ONS data is as follows:

1 https://www.ons.gov.uk/peoplepopulationandcommunity/housing/bulletins/housingaffordabilityine nglandandwales/1997to2016 2 http://web.ons.gov.uk/ons/data/dataset- finder?p_auth=tjYR0i9h&p_p_auth=M8IA3qWh&p_p_id=FOFlow1_WAR_FOFlow1portlet&p_p_lifec ycle=1&p_p_state=normal&p_p_mode=view&p_p_col_id=column- 3&p_p_col_count=1&_FOFlow1_WAR_FOFlow1portlet_process=fileDownload&_FOFlow1_WAR_FO Flow1portlet_UUID=0&_FOFlow1_WAR_FOFlow1portlet_geoTypeId=2014WARDH&_FOFlow1_WAR

Area 2014 2034 increase % increase population projected population in population

South Hams 84,108 90,610 6,502.36 7.7% West Devon 54,260 61,558.92 7,298.92 11.34% Plymouth 261,914 282,683.46 21,137.46 8.08%

This clearly indicates that the major growth area is anticipated for West Devon which covers almost 55% of the land area, although the largest increase in actual people numbers is almost three-fold higher in Plymouth which comprises just 4% of the land area. Discussing this population growth data as a single combined figure and focusing that discussion throughout the JLP on Plymouth City for the main growth is misleading as West Devon is subsequently not allocated a share of new housing in accordance with its projected higher population growth. This distortion is further borne out by the distribution of housing allocations as shared between the three LPAs of the JLP. With the JLP divided between Plymouth Policy Area and Thriving Towns and Villages of a ‘combined’ South West Devon; this makes it difficult to marry the allocation of housing numbers in line with the projected population growth.

2.9 Consultation. The claim of “widespread public consultation” for the vision is misleading and inaccurate. During July and August 2016 the document Thriving Towns and Villages was made available for public consultation. When many people objected to the time frame as taking place during the school summer holidays (when it can be difficult for groups to come together to discuss such documents), the response from SHDC to Ward Members was that this was informal consultation “that didn’t have to be done anyway”. The extensive responses sent in by Dartington Neighbourhood Plan and Totnes Neighbourhood Plan groups and indeed my own submission have been largely ignored as overall housing allocations for the Parish and Town, some key sites, namely Broom Park and Sawmills West in Dartington (which local residents have clearly objected to) were left in the JLP going forward. Similar concerns about traffic congestion, air quality and transportation issues were similarly ignored.

The first time that this draft plan was available for viewing by Ward Members was just a week before it went to full Council for approval. SHDC Elected Members (many of whom are involved in Neighbourhood Plan processes in their wards) have not had any opportunity to be involved in shaping or informing the policies that underpin this plan.

Further issues regarding public consultation are sorely lacking in this JLP. For example there are currently 27 individual Neighbourhood Planning groups developing local plans in South Hams for their areas. The work of these groups to date has not been actively solicited by SHDC for inclusion in this plan despite assurances at local workshops hosted by SHDC that Neighbourhood Plans would be an important component of the more strategic JLP.

2.11 The Strategic Objectives of the Plan:- pt 1 Delivering the spatial strategy – this cannot be carried out when the proportion of allocation of new homes does not coincide with the ONS projected population growth by area (as in my table above) pt 6. The proposed settlement pattern of focusing new housing around the main towns and Plymouth fringe is NOT a sustainable settlement pattern. Neither does it “reinforce and protect the settlement pattern of South West Devon as the key driver of prosperity and sustainability of the area, set within the diverse rural economy and an outstanding natural environment”. The tried and tested settlement pattern of the South Hams and West Devon (that dates back to Saxon times – and earlier), has been a more organic growth pattern where smaller numbers of new houses have developed around villages, hamlets and towns in reflection of their natural growth rates. To intentionally surround the main towns, many of which have magnificent historic

_FOFlow1portlet_collectionId=2014SNPP&_FOFlow1_WAR_FOFlow1portlet_context=Social&_FOFlo w1_WAR_FOFlow1portlet_diff=Population centres with swathes of suburbia is to distort and denigrate those town centres and their associated rural hinterland. In particular the proposals that amount to 504 new houses or 63% growth in Dartington does not conform to this objective.

This JLP model supports large scale developments (60+ houses), generally on greenfield sites, rather than smaller developments of 15 -30 (max) houses which could be buildable by smaller local building companies (thereby benefitting the local economy and local jobs and apprenticeships) and would be more likely to fit in with the local vernacular and landscape and provide more balanced progress; i.e. not swamping the adjacent housing and town/village centre. Smaller developments are generally more likely to be built to a higher standard and local builders are generally more accountable to local customers. Local building companies are unlikely to add the additional 25% profit to a new development as found in larger scale viability assessments, and therefore smaller developments would enable more affordable housing to be available, and more likely to meet local needs.

A truly sustainable settlement pattern would be one that was designed from an objective strategic overview. This would take into consideration meeting identified housing needs and accommodating this by building on the historic settlement pattern appropriately within the landscape, infrastructure and heritage constraints both natural and built. The South Hams and West Devon have an outstanding landscape with various designations that include AONB (Areas of Outstanding Natural Beauty), SACs (Special Areas of Conservation) and SSSI (Special Sites of Scientific Interest). Mitigation, while offered is not generally successful for the intrinsic elements and there is likely to be considerable net loss of landscape value in and around the main towns and Plymouth fringe. Similarly mitigation of wildlife corridors and protected species is not generally successful and simply results in net loss of species. Natural habitat cannot be simply moved elsewhere as the network of life is disrupted and there will be loss of integrity of the habitat and its associated species. Devon provides an important area for many wildlife species in particular EU protected bat species.

When the previous Local Plan for South Hams the DpD was developed it was done with a lot of interactive consultation and negotiation with local residents and residents’ organisations. At the same time I understand (from talking to officers from the forward planning team), sites were proactively sought that would meet the identified local need in the areas identified for new planning. In the JLP this has not happened, instead the location of sites has been simply in response to landowners responding to a general call for sites and these were the perused and commented on by a developers’ forum who assessed them (prior to Ward Members) for their views on sustainability etc. I consider that this process did not identify the appropriate locations or sites for development; instead the process has clearly been led by those with vested interests.

Totnes and Dartington are destined in this JLP to receive 960+ new homes between 2014 and 2034, that is 13% of the proposed housing for all the Thriving Towns and Villages area of the JLP. Of this Dartington is allocated 504 new homes, which would create a 63% increase in this rural village. Not only does this overly burden the significant historic town of Totnes and similarly significant parish of Dartington, both of which attract visitors from all over the world, this substantial increase cannot be justified by the local housing needs as identified in their Neighbourhood Plan Housing needs assessments that have been carried out, neither is this justified by the ONS assessed growth and these two adjacent parishes would not be able to carry the increased load of traffic and congestion that would ensue.

Dartington and Totnes straddle the A384 and A385 which comprise an artery from Torbay to the A38. Due to increased traffic this route is frequently jammed with traffic and an Air Quality Management Plan has been in monitored in Totnes for the last few years. Having spoken just last week to the Environmental Health Officer at SHDC, I understand that an Air Quality Action Plan is due to be published this summer, one of the provisions he anticipates is the compulsory purchase of seven houses in Bridgetown due to the poor air quality they are subjected to. It was confirmed by SHDC officers when the JLP was presented to ward Members at SHDC in March ’17 that air quality projections with regard to the increased congestion and pollutants from cars and HGV and PSVs passing along this arterial route has NOT been carried out. This is contradicted later in the JLP in Policy DEV2 Air, water, soil, noise and land pt 2 states that “development proposals which will cause harm to human health or environmental quality by unacceptable levels of soil, air, water or noise pollution will not be permitted. This level of development in Totnes and Dartington will exceed EU standards of nitrous oxides and thereby poses not only a huge health risk to the residents of Totnes and Bridgetown but also makes SHDC liable for health problems due to taking this risk with human health. It is likely to be more costly to purchase unliveable housing than to reconsider the options of where to site new housing in the JLP.

The proposed sites do not lend themselves to community based or more imaginative developments that would enhance the diversity of the community and create more opportunities for more affordable and social housing solutions. While it is appreciated that a number of smaller towns and villages have been ‘loosely’ allocated new housing numbers through the Thriving Towns and Villages assessments and are otherwise unconstrained by the JLP, there are some smaller towns and larger villages that have been allocated substantial sites. Dartington is a rural parish and since 2014 has experienced considerable new housing development that is changing the rural village centre (that was previously a best village winner) into a suburban area domineered by a new development of 65 houses (of which 16% were designated affordable) and where the main general shop is an enlarged post office and a garage that sells take away curry. The next development on the opposite side of the road currently being built will include 30 new houses (19% affordable) and nearby another new development in this parish has 50 new houses (with just 35% affordable housing). All three of these developments are adjacent to the main road and will add to the already toxic levels of congestion and nitrous oxides.

Pt 8 The aspiration to maintain the vitality and viability of the smaller villages in the rural areas for all the good reasons stated will not be met through the imbalance and distortion of the proposed development sites in the JLP. Dartington in particular is a clear example of how this strategic objective will not be delivered as the proposed development sites will increase its housing since 2014 by 63% a gross overdevelopment of a popular rural village. The housing proposals for Dartington will be to the detriment of the village and parish, its vitality and viability will be destroyed by major overdevelopment, it does not have services or school places to serve this major increase in population, the infrastructure from drainage, sewage and transport networks are wholly inadequate for this increase in growth. In 2014, nineteen newly proposed development sites were put forward for public consultation further to the call put out by SHDC. Over two hundred residents sat down at a public meetings and gave informed and detailed responses to each of those sites, commenting on access, infrastructure, landscape, biodiversity and overall sustainability etc. Of those sites twelve were later withdrawn and a further two not considered sustainable by SHDC. Of the remaining five sites, the landowner, Dartington Hall Trust identified three sites which were it’s a preference A and two were preference B if any A sites were considered unsuitable. Dartington Neighbourhood Plan understood that this could work with those A sites having sustainable design guidelines and being away from the main roads and good links to footpaths and Totnes station etc. However SHDC has submitted all five sites in the JLP. The community at every stage of public consultation has objected to the two B sites. These are Broom Park (80 houses) and Sawmills Field West (40 houses).

The new sites in Dartington from 2014 are as follows: Site use employment area housing comment Beacon Park Employment 11,300sq.m 0 Dartington Hall (H.Barton) Mixed use 0 20 homes Foxhole Mixed use 0 130 homes Brimhay Bungalows Housing 0 12 homes (planning in progress) Broom Park Housing 0 80 homes Higher Tweed Mill Mixed use 500 sq.m 30 homes (currently being built) Sawmills Field Housing 0 40 homes Woodlands Yard Employment 5,500 sq.m 0 Sawmills Field East (Origins) Housing 65 homes -completed, not in JLP Webbers Yard Mixed use 1 ha 30 homes -part completed, not in JLP Land at Ashburton Rd (Meadowside) Housing 1,200sq.m 50 homes completed,listed as Totnes Transition Homes Housing 27 homes listed as Totnes Dartington Lane Housing 40 homes (45 listed in Totnes) ______1 ha, 18,500 sq.m 504 new homes

The new sites in Totnes (excluding those in Dartington as listed above) are as follows: Site: use: employment area: housing: comment: KEVICCs housing 130 homes Land at Baltic Wharf (ph1) housing 93 homes – part completed 90 in JLP Land at Baltic Wharf mixed 3,300sq.m 100 homes –under construction Atmos mixed 99 – 62 in JLP Riverside (Camomile Lawn) mixed 3,200sq.m 106 homes – part completed 0 in JLP Dartington Lane Housing 5 in Totnes (see ref. 40 in Dartington) Follaton Oak Housing 60 – completed – not in JLP Great Court Farm (in Berry Pomeroy) Housing 75 (P. permission granted) ______6,500 sq.m 668 new homes

pt 9 Maintaining the vitality and viability of the many sustainable villages in the rural area. The proposed settlement plan starves many of these rural villages and hamlets across South Hams and West Devon. A more sustainable development pattern across the JLP area would spread the housing allocations far more equitably, this would enable smaller villages and parishes to meet their housing needs which are generally for affordable housing for young people and low income families. Such development brings vitality to rural parishes and enables their village centres, community facilities and public transport services to be viable and sustainable. Despite the endeavours of the Neighbourhood Plan groups across the South Hams (and west Devon) who are progressing plans that are essentially working from the ‘bottom up’ to meet local needs and support their local facilities by keeping them viable, their work to date has not informed the JLP; to the detriment of the JLP.

Pt 10. Dartington is a beautiful parish principally comprised of a series of small hamlets and a more recent village centre. Dartington Hall is world famous for the 20th century innovative arts and crafts movement with rural regeneration that resulted in a series of pioneering architectural developments as well as the international Schumacher school. It is a parish full of architectural gems and beautiful rolling landscape with some ancient forest. Of late the Dartington Hall Trust has revitalized its vision to reinstate many of the principles and take forward new projects based on the vision of the Elmhirsts who established this work. To reduce this parish to fields full of suburban housing would be to kill off this possibility of regeneration and diminish its attraction to visitors who contribute to a very active tourist industry.

Pt 11. Delivering high quality development would be more possible with smaller developments built by local builders who are more accountable to local people. Some of the new developments listed above that are completed or nearing completion have many problems already, e.g. are causing drainage and flooding problems in adjacent areas. In this time of climate change, it is a sad reflection that most new homes are not fitted with solar panels or have solar orientation to benefit the environment and the householder with use of passive solar energy.

Pt.12 Infrastructure that encourages people to use the car less and walk or cycle more should underpin this plan. For this more investment in footpaths and cycle paths should be encouraged.

General points: At least 50% of new housing in any larger development should be affordable. 30% is not high enough in an area which is popular and is pushing out younger people and their families.

There is little promotion in the plan for truly innovative design or development that could reduce the carbon footprint of new buildings. Indeed a strategic objective that is clearly absent is one to mitigate climate change.

Natural habitats including the South Hams SAC for protected bat species are not adequately protected in this JLP. Development Policy is weak and should state that these important habitats should be fully protected, not available for development. Developers frequently put the case for economic benefit over environmental quality. Once an ancient woodland or hedgebank has been destroyed and built over it is gone forever. These are dynamic parts of our shared heritage and need to be maintained for generations to come.

This plan calls into question the NPPF and how it prepares and guides for planning decisions that can meet local needs without condemning more green fields to low quality developments at the expense of meeting food and farming needs or at the detriment to environmental quality including air quality and visual amenity whilst adding to an increase in second and holiday homes in areas of high landscape value. The loss of the previous very detailed planning framework that enabled a sound understanding and process for planners, decision makers and applicants to work with carefully crafted national and local policies and detailed guidance has left a void that has only served large scale developers who can challenge planning authorities, and landbank available sites. Many Planning authorities, including SHDC have been left vulnerable to unsustainable planning applications, only indefensible at appeal due to the requirement of a five year land supply. This has led to a number of inappropriate and low quality housing developments in South Hams that would otherwise have merited refusal.

These are not NIMBY concerns as often cited, but instead sound reasons to challenge these planning proposals that could change the face of South Hams forever and risk public health. Dartington and Totnes have often stated they are not against development, just bad development in the wrong place; the local community here are SWIMBY’s, in other words they welcome ‘Something Wonderful In My Back Yard’. This plan needs a complete rethink if it is to deliver a truly sustainable future for the South Hams. It is possible to accommodate local housing needs and take a share of the national needs, we just need to apply a bit of creative thinking and demand high quality design and buildings in appropriate places supporting local builders and skilled workers, not succumb to allocating large green field sites so that major developers can make their money and run”.

I would like to speak at the oral hearing for this Joint Local Plan.

Yours faithfully,

Jacqi Hodgson

Cllr. Jacqi Hodgson c.c. Strategic Planning Dept. South Hams District Council, Follaton House, Plymouth Road, Totnes, Devon. TQ9 5NE