SH Regulation 18 Responses

From: Strategic Planning Subject: RE: Our Plan - Consultation

From: Cllr J. Baverstock Sent: 10 May 2014 08:50 To: Strategic Planning Subject: RE: Our Plan - Consultation

Dear Phil,

Thank you for this information, under Health you may feel there should be some thought to Emergency Planning responsibilities and, unless I missed it, Law Enforcement.

Best wishes with the project.

John B

From: Strategic Planning Sent: 09 May 2014 14:40 To: SH-All Members Subject: Our Plan - Consultation

Dear Members,

This email is to let you know that the first formal consultation on “Our Plan” begins today (Friday 9th May) and runs until Friday 20th June. This consultation is about the topics and challenges Our Plan should cover. Please help to spread the word and encourage people to engage in the process and respond to the consultation. All town and parish clerks have been notified of the consultation and provided with information about where they can access the document (see postcard attached).

The consultation document and response form can be found on the Council’s website at www.southhams.gov.uk/ourplan. Hard copies of the document and response forms will also be available at reception in Follaton House.

For further information, please contact me or any other member of the Strategic Planning Team on 01803 861210.

Kind regards

Phil

Phil Baker | Strategic Planning Officer South Hams District Council Follaton House | Plymouth Road | Totnes | TQ9 5NE

@OurPlanSH www.facebook.com/OurPlanSH

1 From: Sent: 13 May 2014 14:37 To: Strategic Planning Subject: South Hams Local Plan: Our Plan Consultation - Highways Agency response

Dear planning team Thank you for advising the Agency of your consultation on the initial evidence gathering phase in the preparation of South Hams’ local plan for the period to 2031. The Agency has no specific comments to make at this stage, but looks forward to further opportunities to comment as development of the plan progresses. Kind regards Gaynor

Gaynor Gallacher, Business Support Highways Agency | Ash House | Falcon Road, Sowton Ind. Estate | Exeter | EX2 7LB

Safe roads, reliable journeys, informed travellers Highways Agency, an executive agency of the Department for Transport.

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1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Sue Green (where relevant) Job Title: Planning Manager (where relevant) Organisation: Home Builders Federation Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

1 Carla Chowings

From: Sarah Winfield Sent: 21 May 2014 13:37 To: Rebecca Black; Phil Baker Cc: Paul Hickson; Janet Powell - SWLEP; Joe Keech Subject: Heart of the South West LEP Response: South Hams and West Devon - Our Plan Consultation

Dear Colleagues

Thank you for consulting the Heart of the South West Local Economic Partnership (LEP) on the scope and options for the Local Plans for West Devon and South Hams District Councils (under Regulation 18 of the Town and Country Planning Regulations 2012). We are responding to this consultation on behalf of the LEP, as Somerset County Council is leading on the place theme work for the LEP.

The consultation documents clearly identify various challenges, under the themes of ‘People’ and ‘Place’, that the Plans intend to address. These priorities are welcomed and align very well with those of the draft Strategic Economic Plan (SEP). In the further development of the Plans, under the Place theme, it might be beneficial to add “digital infrastructure” and “energy infrastructure” to the point about “maintaining and enhancing infrastructure” to further support the priorities for the LEP. These include: improving digital infrastructure (super-fast broadband and mobile phone) allowing businesses to connect and trade world wide; and capitalising on our low carbon economy energy resources, benefiting our low carbon sector, wider business community, households and the environment.

In response to the challenge identified under the ‘People’ theme, regarding “retaining young people and families”, we hope that the Plan will consider the ‘People’ priorities set out in the SEP (page 75): employer engagement and ownership; skills infrastructure and facilities; access to education and employment; moving people into employment; supporting people to progress to better jobs; improving workforce skills; enterprise and business skills; technical and higher level skills; and maximising the skills and employment opportunities aligned to our transformational opportunities. Further information can be found via our website: http://www.heartofswlep.co.uk/strategic-economic-plan

In the further consideration of issues for the Plans, the LEP would also welcome support for the business priorities set out in the SEP (page 74). These include: stimulating enterprise and growth; reaching new markets; and building on capacity for innovation.

We wish you well for the next stages in the development of your Plans, and look forward to further consultation. Please do get in touch if you would like to discuss any of these comments further.

Yours sincerely, Sarah Winfield (on behalf of Paul Hickson, LEP lead on ‘Place’)

Sarah Winfield Planning Policy Officer

a: Planning Policy, B3W Economic and Community Infrastructure Somerset County Council County Hall Taunton TA1 4DY

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2 Subject: Submitted via Web Site

Form namespace is www.southhams.gov.uk/FORM_V2EMAILCONTACT

The following information was received from the form southhams.gov.uk-article-3399 day Wednesday comments Congratulations. This is the first time I have seen any government use the words 'long term and dream'. it is also a great way to move discussion away from short term special interests and go for the strategy. We look forward to following your progress closely. email name Tom Appleton formorigin https://www.southhams.gov.uk/article/3399/community-team submittime 22/05/2014 10:02

1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Carole Partridge (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). i do think that with regards to any new development that good design should be at the forefront. There is large development being carried out in the Teignbridge area. This seems to have been carried out without any Comments: regard to innovative or pleasing design features. The housing could in fact be in any town anywhere in the country. It would be good to think that in the South Hams we could have something different. Keeping in touch Would you like to be kept informed of prgress with Our Plan?

1 Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: simon orr (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). The impact of other organisations (uk government, european state, Comments: business ie sww) on the plans Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

1 From: Strategic Planning Subject: RE: South Hams District Council - Our Plan Consultation Attachments: image001.jpg; image002.jpg; image003.jpg

Dear Phil,

Thank you for the email below regarding "Our Plan", I am presently Secretary of Ivybridge RFC and had some dealings with the present DPD around 2010 re the impact of the plan on the rugby club.

I understand the Local Development Scheme (LDS) in the early stages, but the part of the previous Ivybridge DPD earmarked and area to the south of the rugby club for development post 2016, indeed the developments to the north have yet to be finalised.

Although as a stakeholder group we are pleased to have been informed at this early stage, my immediate concerns are for the present DPDs as the document states this new scheme would supersede these.

What are your comments on this?

With regard to the comments form, the present plans set out overall aims and sub‐headings none of which could be described as wrong, as with all these things the devil is in the detail.

I understand finding the balance to deliver these aims with competing needs is a daunting task. I would like to register my interest in being involved with the consultation and the future stages of this process. regards

John Belcher

From: [email protected] Subject: South Hams District Council ‐ Our Plan Consultation Date: Fri, 9 May 2014 13:15:53 +0000

Dear Consultee,

South Hams District Council is preparing a new plan for its area. “Our Plan” will be a corporate plan which sets out the vision, long term priorities and planning policies for the District to 2031. The planning element of Our Plan will only be relevant to the area of South Hams outside of the Dartmoor National Park.

We have prepared a consultation document setting out the topics and challenges our new plan will cover. Please find attached further information about the consultation and how you can submit your comments. This consultation document is the formal start to preparing a new plan for our area and there are regulations which set out that process. This process is set out in the Town and Country Planning regulations.

1 For further information, please contact me or another member of the Strategic Planning Team on 01803 861234.

Kind regards

Phil

Phil Baker | Strategic Planning Officer South Hams District Council Follaton House | Plymouth Road | Totnes | TQ9 5NE

@OurPlanSH www.facebook.com/OurPlanSH

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2 Carla Chowings

From: Sent: 29 May 2014 09:51 To: Strategic Planning Cc: Strategic Planning; Rebecca Black; Phil Baker Subject: FW: South Hams and West Devon - Our Plan Consultation NOT PROTECTIVELY MARKED Attachments: image001.jpg; image004.jpg; image005.jpg; image006.jpg; Our Plan consultation postcard WD.pdf; Our Plan consultation postcard SH.pdf; The role of the ALO.pdf

Categories: Becca

Good morning,

Thank you for the opportunity to make comment with regard to The Strategic Plans for South Hams and West Devon.

Please find attached a document which explains the role of the Police Architectural Liaison Officer (ALO) in designing out crime, disorder, anti social behaviour and conflict within the built environment and the importance of early consultation with the ALO (i.e. pre app stage).

I am hoping this is a good opportunity and appropriate to enquire if some (or all) aspects of the document could be incorporated into The Plan in order to highlight the role of the ALO and designing out crime. All too often there is never any mention in Design and Access statements or Planning statements of designing out crime or whether any crime prevention measures have been considered.

In addition to reducing crime, preventing crime and the fear of crime, a major part of creating sustainable and cohesive communities for a development is by designing out opportunities for antisocial behaviour and/or community conflict to occur in the built environment through the design process. Conflict will create the erosion of sustainability.

Please advise if you would prefer any aspect of this email to be submitted by other means.

Please do not hesitate to contact me should there be anything further you may wish to discuss.

Thank you

Kind regards

Sarah-Jane Barr

Sarah-Jane BARR Police Architectural Liaison Officer - West Devon, Torbay & South Hams, Totnes Police Station, Ashburton Road Totnes, Devon. TQ95JY

From: Strategic Planning [mailto:[email protected]] Sent: 09 May 2014 14:08 Subject: South Hams and West Devon - Our Plan Consultation

Dear Consultee,

South Hams District and West Devon Borough Councils are preparing new strategic plans for their areas. These plans will set out the vision, long term priorities and planning policies for the areas they cover. The planning element of the Plans will only be relevant to the areas of South Hams and West Devon outside of the Dartmoor National Park.

We have prepared a consultation document setting out the topics and challenges our new plans will cover. The consultation document is the formal start to preparing a new plan for the areas and there are regulations which set out that process. This consultation is in accordance with Regulation 18 of the Town and Country Planning (Local Development) Regulations 2012.

Please find attached two postcards with further details about the consultation and how you can submit your comments.

For further information, please contact either Rebecca or Phil or any other member of the Strategic Planning Team on 01803 861234 (South Hams) or 01822 813556 (West Devon).

Kind regards

@OurPlanWD www.facebook.com/OurPlanWD

@OurPlanSH www.facebook.com/OurPlanSH

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3 From: [email protected] Sent: 29 May 2014 10:55 To: Strategic Planning Cc: Tony Edgcumbe Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Ray Holland (where relevant) Job Title: Independent energy consultant (where relevant) Organisation: n/a

Address: Please enter the post code in the following format PL21 0PP Post code:

Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Infrastructure should include aiming for an integrated transport system. Although much of this may be outside the Council's control there is much that they could do to influence it. e.g. planning for bus and train Comments: services to be coordinated, lobbying for much better links to the rest of the country by road and rail and air, p.s. page 3?? I assume you mean page 13 Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). As above: Infrastructure should include aiming for an integrated transport system. Although much of this may be outside the Council's control there is much Comments: that they could do to influence it. e.g. planning for bus and train services to be coordinated,lobbying for much better links to the rest of the country by road and rail and air, Is there anything else you think Our Plan should contain?

1 Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). As above: Infrastructure should include aiming for an integrated transport system. Although much of this may be outside the Council's control there is much Comments: that they could do to influence it. e.g. planning for bus and train services to be coordinated, lobbying for much better links to the rest of the country by road and rail and air, Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning To: ` Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Mr G Harding (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Although I would like to see affordable housing offering discounted to Comments: buy rather than social housing. Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: David Legg (where relevant) Job Title: Minister (where relevant) Organisation: Lee Mill Church Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Yes, but, the previous strategic plan contained specific environmental improvements for Lee Mill, including building a new A38 road junction to reduce the volume of road traffic through Lee Mill village centre.

Here are my proposals: 1. The A38 south of Lee Mill should be moved slightly further South, onto largely unused land, just enough to allow the building of a new slip road for traffic leaving the A38 heading East.

2. The existing slip road which is only 1-way should then be completely blocked off in order to improve the centre of Lee Mill village, reduce damage to property, pollution, noise etc. I am particularly concerned, as Comments: a minister of a church, that my congregation has to take its lie in its hands to cross the busy A38 slip road to get into church!

3. In the meantime, some noise reducing fence on the A38 or earth banks would improve the acoustic environment in Lee Mill.

4. A temporary speed limit of 50mph on the A38 near Lee Mill would benefit residents.

5. Speed reduction measures on the A38 slip road that goes through Lee Mill, such as a 30mph speed limit would also benefit residents and improve safety by reducing this hazardous road crossing for pedestrians. Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters).

1 Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: See above. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: See above. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Stuart Watts (where relevant) Job Title: Chairman (where relevant) Organisation: Aune Conservation Association Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

1 Date: 03 June 2014 Our ref: 120593 Your ref:

Phil Baker Strategic Planning Officer Customer Services South Hams District Council Hornbeam House Crewe Business Park Electra Way BY EMAIL ONLY Crewe Cheshire CW1 6GJ

Dear Sir

Planning consultation: South Hams Local Plan Regulation 18 Consultation

Thank you for your consultation on the above dated 09 May 2014.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Whilst we understand that the document we have been consulted upon is the legal statement informing us that the Plan making process is about to commence. The timetable for the preparation of the Plan is particularly challenging, especially given the environmental considerations of the Plan Area. We are surprised that this initial consultation does not include any estimate of housing need. We note the housing position statement dated March 2014. We note that this document considers three economic models although the Regulation 18 document does not steer the Plan in a particular direction. We note the preparation of both the Strategic Housing Market Needs Assessment (SHMNA) and the Strategic Housing Land Availability Assessment (SHLAA) is on-going. We look forward to engaging with the authority on the environmental implications of future Plan objectives.

There are a number of environmental assets in or liable to be affected by the plan, and these need to be considered in the plan making process. These include:  The South Hams Special Area of Conservation, particularly the flyways and sustenance zone.  The Dartmoor Special Area of Conservation including its salmon which use the rivers which flow from Dartmoor.  The new marine Special Area of Conservation- Start point to Plymouth Sound  Marine Conservation Zones  The South Hams AONB and its setting  The setting of the Dartmoor National Park  Sites of Special Scientific Interest,  and more local features of wildlife value.

We would expect that any allocations are demonstrated to be deliverable in the context of the NPPF and local policies to protect the natural environment. In particular we advise that the plan should address the following:  The Plan should take account of an up to date evidence base and coherent ecological networks mapped  The plan contain a clear strategy for protecting and enhancing the natural environment Page 1 of 3

 The plan should set out clear criteria for appropriate development within or impacting on National Parks and AONBs, including complying with the major developments test. Any allocations or apportionments should be able to be shown to comply with the major developments test and be supported by appropriate evidence.  The development management policies set out criteria to firstly avoid, then mitigate and, as a last resort compensate for adverse impacts on biodiversity. The plan should set criteria based policies for protected biodiversity, geodiversity or landscape sites, distinguishing between international, national and local sites. This should include proposed and candidate European sites.  The development strategy should propose sites for development with the least environmental or amenity value.  Policies for good design in order to avoid light spill generally preserving dark skies are encouraged and will be essential for protecting the South Hams SAC bat flyways.  Any strategy on renewable/low carbon energy should take full account of the capacity of the natural environment to accommodate energy infrastructure based on criteria that ensure designated landscapes and sites are fully protected.  The plan should promote the use of public transport, walking and cycling to improve access to nature  The plan should make provision for an appropriate quality and quantity of green space to meet identified local needs as part of wider open space provision. We recommend use of ANGSt as a useful tool that can help ensure adequate provision of accessible natural greenspace.  Green space policies should be linked to Green Infrastructure policies.  The plan should protect and enhance public rights of way and access, including National Trails and improve public access to and enjoyment of the coast  The plan should refer to and / or reflect National Park and AONB Management Plan objectives.  The plan should have policies for conserving and enhancing the landscape which identifies, protects and enhances locally valued landscapes. The plan should take account of the character of different areas and recognise the intrinsic character and beauty of the countryside  The Plan should consider as appropriate, that relevant areas of tranquillity are identified and protected.  The plan should set out a strategic approach-, planning positively for the creation, protection, enhancement and management of networks of biodiversity and consider biodiversity at a landscape-scale across the local authority boundaries through the duty to cooperate. This particularly applies to the South Hams SAC and the AONB.  Ancient woodland and aged or veteran trees should be protected by policy.  Planning policies should promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identifies suitable indicators for monitoring biodiversity in the plan.  The Plan protects habitats (internationally, nationally and locally designated sites) from water related impacts and seek enhancement to them. This should include run off from development and effects from combined sewage outfalls on designated marine features.  The plan should set out a strategic approach, planning positively for the creation, protection, enhancement and management of networks of green infrastructure. It should also recognise the role of green infrastructure in aiding climate change adaptation  Soil is a finite resource, and fulfils many roles that are beneficial to society. As a component of the natural environment, it is important soils are protected and used sustainably. The plan should recognise that development has a major and usually irreversible adverse impact on soils. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during the construction process. Soils of high environmental value should also be considered as part of ecological connectivity.

Page 2 of 3

 The plan should safeguard the long term capability of best and most versatile agricultural land and make clear that areas of lower quality agricultural land should be used for development in preference to best and most versatile land.  The Plan should take account of the marine environment ensuring integration of the terrestrial and marine planning regimes. This is particularly important regarding the recently designated Marine Conservation Zone and the Marine SAC.  The plan should maintain the character of the undeveloped coast and protect and enhance its distinctive landscape and seascape; the plan should identify and include policies for the Heritage Coast.

Despite the challenging timetable the authority should ensure the Plan meets its legal requirements:

Sustainability Appraisal (SA)

We note that no SA scoping has been consulted upon with this consultation. This is a missed opportunity as such a document can analyse problems issues and opportunities as well as setting out the SA objectives and the evidence base. Moreover, the audit trail of assessing and consulting on alternative strategies will be challenging under the planned timetable, particularly in the absence of a consultation stage that assesses options. However, we look forward to being actively engaged with the authority to find the most sustainable outcome.

Habitat Regulation Assessment (HRA) Several European sites could potentially be significantly affected by development unless mitigation measures are put in place to avoid such effects. Such mitigation may require evidence to be updated.

It is not clear if the new plan may include allocations. You should be aware that deferring allocations to neighbourhood plans may prove difficult if such allocations give rise to Likely Significant Effects (LSE). The Neighbourhood Plan Regulations 2012 prevent neighbourhood Plans from generating LSE. Mitigation strategies backed by sufficient evidence must be included in the higher tier Local Plan.

We look forward to being consulted informally on an early draft of the HRA once the Plan objectives and how needs will be met are agreed.

Finally we note that we are presently excluded from the current Engagement Plan. Given the progress the Authority wish to make this year, this is disappointing. As a statutory consultee we would very much wish to engage in the South Hams Plan. Failure to engage in an environmentally sensitive area such as this District, could unnecessarily delay the Plan timetable.

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries relating to the specific advice in this letter only please contact Laura Horner on For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected].

Yours faithfully

Laura Horner Lead Advisor Development Plan Network Page 3 of 3

From: Turner, Steve Sent: 04 June 2014 17:53 To: Strategic Planning; James Doxford Cc: Steward, Pat; Pickhaver, David Subject: RE: South Hams and West Devon - Our Plan Consultation

Please read the Council's email disclaimer notification which is located at the end of the email message.

Dear Strategic Planning Colleague,

Thank you for giving Torbay Council the opportunity to comment on ‘Our Plan’, the emerging Strategic Plan for the South Hams District.

As a general point, we found your document to be attractively and well presented, concise and easy to understand. Given the high level and outline nature of the document, we have limited our comments at the present stage to the following observations:

About the Plan – Page 7 It is suggested that you consider the following: 1. adding a bullet point to ‘Our Economy’, namely Training and education; 2. adding a bullet point to ‘Our Nature’, namely Designated and protected sites of wildlife and biodiversity importance; and 3. amending the Designated and protected landscapes bullet point in ‘Our Nature’ by adding and coastline at the end.

Big challenges – Page 11 It is suggested that you consider the following: Add a new orange signpost as follows: We have a legal duty to co‐operate with neighbouring authorities to address important cross‐boundary issues (such as housing and funding of infrastructure)

Challenges: Place – Page 13 It is suggested that you consider the following: Amend Protecting and enhancing our natural landscapes by adding and coastline at the end Add a new ‘white box’ containing the following: Reducing the impact of development on wildlife, flora and fauna

I appreciate that you are aiming for brevity but I believe that these suggestions do address genuine omissions, and we hope you will find them helpful.

It is noted that you are proposing to adhere to fairly ambitious timescales in your work programme. As you appear not to be consulting on a full draft Plan (as part of the Regulation 18 stage) prior to publication of the Proposed Submission Plan in November / December 2014, Torbay would welcome the opportunity to have at least some form of informal opportunity to comment on relevant policies, particularly those with strategic cross boundary implications, prior to final drafting.

In the meantime, Torbay wishes to continue to share ideas, monitor key cross‐boundary issues and to explore solutions as part of our commitment to fulfilling our duty to co‐operate, both through regular discussion and through meetings of the South Devon Strategic Planning Liaison Group.

Kind regards,

Steve.

Steve Turner

1 Team Leader - Strategic Planning

Strategic Planning Team Spatial Planning Place and Resources Torbay Council Electric House (2nd Floor) Castle Circus Torquay TQ1 3DR

This email and any attachments are intended solely for the use of the intended recipient(s) and may contain confidential information and/or may be legally privileged. If you have received this email in error, please notify the sender immediately and delete this email.

From: Strategic Planning [mailto:[email protected]] Sent: 09 May 2014 14:08 Subject: South Hams and West Devon - Our Plan Consultation

Dear Consultee,

Please find attached two postcards with further details about the consultation and how you can submit your comments.

For further information, please contact either Rebecca or Phil or any other member of the Strategic Planning Team on 01803 861234 (South Hams) or 01822 813556 (West Devon).

Kind regards

@OurPlanWD www.facebook.com/OurPlanWD

2 @OurPlanSH www.facebook.com/OurPlanSH

______

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3 From: [email protected] Sent: 09 June 2014 15:43 To: Strategic Planning Cc: Tony Edgcumbe Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Daniel Parry-Jones (where relevant) Job Title: Associate Director (where relevant) Organisation: BNP Paribas Real Estate, as agent for Centrica plc Portwall Place Address: Portwall Lane Bristol Please enter the post code in the following format PL21 0PP Post code: BS1 6NA Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 3) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 12) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 13) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). The emerging plan should be worked up having full regard to the need to protect existing businesses and employment providers rather as well as Comments: focussing on provision of new development. New development should be planned so as not to prejudice existing businesses and employment

1 providers such as Centrica's Langage Power Station, the efficient operation of which is of strategic importance regionally and nationally. Please see BNP Paribas's covering letter dated 9 June 2014 on behalf of Centrica plc for more detail. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

From: Sent: 11 June 2014 10:01 To: Strategic Planning Subject: South Hams Our Plan

Dear Sir/Madam

Network Rail has been consulted by South Hams District Council on the Our Plan document. Thank you for providing us with this opportunity to comment on this Planning Policy document. This email forms the basis of our response to this consultation request.

Network Rail is a statutory undertaker responsible for maintaining and operating the country’s railway infrastructure and associated estate. Network Rail owns, operates, maintains and develops the main rail network. This includes the railway tracks, stations, signalling systems, bridges, tunnels, level crossings and viaducts. The preparation of development plan policy is important in relation to the protection and enhancement of Network Rail’s infrastructure.

Developer Contributions

The Our Plan document should set a strategic context requiring developer contributions towards rail infrastructure where growth areas or significant housing allocations are identified close to existing rail infrastructure.

Many stations and routes are already operating close to capacity and a significant increase in patronage may create the need for upgrades to the existing infrastructure including improved signalling, passing loops, car parking, improved access arrangements or platform extensions.

As Network Rail is a publicly funded organisation with a regulated remit it would not be reasonable to require Network Rail to fund rail improvements necessitated by commercial development. It is therefore appropriate to require developer contributions to fund such improvements.

Specifically, we request that a Policy is included within the document which requires developers to fund any qualitative improvements required in relation to existing facilities and infrastructure as a direct result of increased patronage resulting from new development.

The likely impact and level of improvements required will be specific to each station and each development meaning standard charges and formulae may not be appropriate. Therefore in order to fully assess the potential impacts, and the level of developer contribution required, it is essential that where a Transport Assessment is submitted in support of a planning application that this quantifies in detail the likely impact on the rail network.

To ensure that developer contributions can deliver appropriate improvements to the rail network we would recommend that Developer Contributions should include provisions for rail and should include the following:

. A requirement for development contributions to deliver improvements to the rail network where appropriate. . A requirement for Transport Assessments to take cognisance of impacts to existing rail infrastructure to allow any necessary developer contributions towards rail to be calculated. . A commitment to consult Network Rail where development may impact on the rail network and may require rail infrastructure improvements. In order to be reasonable these improvements would be restricted to a local level and would be necessary to make the development acceptable. We would not seek contributions towards major enhancement projects which are already programmed as part of Network Rail’s remit.

Railway Safety – Level Crossings

Development proposals’ affecting the safety of level crossings is an extremely important consideration for emerging planning policy to address. The impact from development can result in a significant increase in the vehicular and/or pedestrian traffic utilising a crossing which in turn impacts upon safety and service provision.

As a result of increased patronage, Network Rail could be forced to reduce train line speed in direct correlation to the increase in vehicular and pedestrian traffic using a crossing. This would have severe consequences for the timetabling of trains and would also effectively frustrate any future train service improvements. This would be in direct conflict with strategic and government aims of improving rail services.

1 In this regard, we would request that the potential impacts from development affecting Network Rail’s level crossings, is specifically addressed through planning policy as there have been instances whereby Network Rail has not been consulted as statutory undertaker where a proposal has impacted on a level crossing. We request that a policy is provided confirming that:

 The Council have a statutory responsibility under planning legislation to consult the statutory rail undertaker where a proposal for development is likely to result in a material increase in the volume or a material change in the character of traffic using a level crossing over a railway: o Schedule 5 (f)(ii) of the Town & Country Planning (Development Management Procedure) order, 2010 requires that… “Where any proposed development is likely to result in a material increase in volume or a material change in the character of traffic using a level crossing over a railway (public footpath, public or private road) the Planning Authority’s Highway Engineer must submit details to both Her Majesty’s Railway Inspectorate and Network Rail for separate approval”.

. Any planning application which may increase the level of pedestrian and/or vehicular usage at a level crossing should be supported by a full Transport Assessment assessing such impact: and . The developer is required to fund any required qualitative improvements to the level crossing as a direct result of the development proposed.

Traveller Sites

Any traveller site is deemed the same as any residential development next to the operational railway with potentially increased numbers of young people and minors using the site, there is an increased risk of trespass with residents using the railway as a short cut and failing to recognise the risks involved by crossing the railway at unauthorised points.

Any existing Network Rail fencing at any potential site which is next to the operational railway has been erected to take account of the risk posed at the time the fencing was constructed and not to take into account any presumed future use of the site.

Therefore, any proposed residential traveller development site may import additional trespass onto the railway, therefore, should the Council chose to develop a site next to the operational railway they must provide a suitable trespass proof steel palisade fence of a minimum 1.8m in height to mitigate any risks that the development might import.

Any fencing installed must not prevent Network Rail from maintaining its own fencing/boundary treatment. As Network Rail is a publicly funded organisation with a regulated remit it would not be reasonable to require Network Rail to fund boundary works and enhancements necessitated by commercial or third party developments that import risks onto the operational railway and Network Rail land.

There must be a minimum of a 2 metres gap between any buildings or structures and the Network Rail boundary.

Wind Turbines & Solar Farms

Developers of turbines must consider shadow flicker and its effect upon railway infrastructure. Network Rail would request that developers must consider when constructing wind turbines or wind farms the likely effect upon the railway, particularly where safety is critical. There may be a minimal risk to driver’s vision (how they perceive signalling, the route ahead, stopping in the case of emergency etc) which may be impacted by a wind turbine(s).

Network Rail utilises radio/signalling equipment and we would not want to see this interfered with by wind farms/wind turbines, particularly as it is safety critical and absolutely integral to the operation of the railway.

There is some concern that vibration from turbines can affect ground conditions; with the possible issue here being embankments and potential instability, in which case Network Rail would raise an objection to any applications for turbines close enough to the railway to create these issues and would wish consultation on a possible repositioning. The construction of the towers, heavy blades, gearbox and generator as well as guy lines to hold the tower in place put strain on the ground at the base of the structure.

Many wind turbines are now a minimum of a 45 metre long tall tower with concomitant long blades, as such it may be necessary for the developer of any proposal for a wind turbine or turbines to gain consent from Network Rail’s Structures Engineers and Level Crossing Managers to cross Network Rail infrastructure in particular over a Network Rail bridge prior to construction on site. Consent may be needed as bridges have a maximum load and a wind turbine(s) plus blades and vehicle transporting said equipment may be over the limit for that bridge.

2 Network Rail should be consulted on applications for wind turbine(s) as standard, and this should be added to the council’s policy. We would also request the policy to require applicants to engage in pre-application consultation with the Network Rail Asset Protection Team to determine if a proposed wind turbine(s) / wind farm(s) impacts upon Network Rail land and the safety, integrity and operation of the railway and its infrastructure for the reasons as stated above.

At this stage the construction and usage of wind turbine(s) is relatively rare, but Network Rail Town Planning has seen an increase in applications and it is highly probable that the numbers of developments with wind turbine(s) will increase as the drive toward sustainable, renewable, carbon neutral energy production increases.

Any proposed installation of Solar Panels adjacent to the railway should consider the following point at design stage to eliminate any risk to railway operations: the provision of any reflective material used in the solar collecting equipment should not interfere with the line of sight of train drivers and the potential for glare or reflection of light from the panels that may impact upon signalling must be eliminated.

South Hams District Council should be made aware that any proposed Wind Turbine scheme or Solar Farm that includes as part of the remit the installation of cables under the railway to facilitate any works on site or any method of electricity transmission would invariably be objected to as this would necessitate works that could damage or undermine the safety, operation and integrity of the railway. Any proposal for a wind turbine or solar farm that necessitated any cabling/high tension lines over the railway would also be objected too pending negotiation/consents/agreements with our National Business Team.

We would have serious reservations if during the construction or operation of the site, abnormal loads will use routes that include Network Rail assets (e.g. Level Crossings, Bridges etc). Network Rail would request that contact is made with our Asset Protection Engineers to confirm if any proposed route is viable and to agree a strategy to protect our asset(s) from any potential damage caused by abnormal loads. I would also advise that where any damage, injury or delay to the rail network is caused by abnormal load (related to the application site), the applicant or developer will incur full liability.

We would appreciate the Council providing Network Rail with an opportunity to comment on any future planning applications or proposed site allocations should they be submitted for sites adjoining the railway, or within close proximity to the railway as we may have more specific comments to make (further to those above).

We trust these comments will be considered in your preparation of the forthcoming Our Plan document.

Regards,

Barbara Morgan Town Planning Technician (Western and Wales) 3rd Floor, Temple Point Redcliffe Way, Bristol BS1 6NL

www.networkrail.co.uk/property

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4 Gregory Gray Associates CHARTERED TOWN PLANNING CONSULTANTS Victoria House, 18-22, Albert Street, Fleet, Hampshire, GU51 3RJ.

The Strategic Planning Team, South Hams District Council, Follaton House, Totnes, Devon TQ9 5NE

11th June 2014

Dear Sir/Madam,

OUR PLAN CONSULTATION.

Gregory Gray Associates is instructed by The Garden Centre Group to submit representations in relation to the above document which seeks views on the scope of the ‘Our Plan’ Document which is a strategic level plan intended to provide planning policies for the area of South Hams District outside of the Dartmoor National Park.

The Garden Centre Group own Endsleigh Garden Centre, a large retail garden centre located to the south of the A38 at Ivybridge. This site is highly developed and makes a significant contribution to the local economy through the employment it offers and the support afforded to local suppliers.

Our client is keen to ensure that future planning policies that apply to the site are consistent with the national ‘pro-growth’ agenda set out in the NPPF and accordingly the following comments are offered.

Para. 28 of the NPPF indicates that ‘planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development’. It indicates that in order to promote a strong rural economy, local plans should support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through the conversion of existing buildings and through well designed new buildings.

The support for local businesses identified in the ‘People’ Section of the Council’s Consultation Document is welcomed and the emerging Plan should contain policies which would support the growth and expansion of all types of rural business.

Whilst, it is noted that the ‘Places’ section refers to ‘enhancing the role of town centres’, the Council is reminded that this is not mutually exclusive to the expansion of certain, specialist types of out of centre retail enterprise such as our clients. Para. 23 of the NPPF requires local

Director: G.W.R. Gray MSc. Dip.TP MRTPI ACI.Arb Secretary: C.J. Gray Associate Director: M.G. Cole BA(Hons.) Dip.TP MRTPI Associate: A.J. Ayles BA(Hons.) BTP MRTPI Gregory Gray Associates is the trading name of Gregory Gray Associates Limited. Reg. No. 4633530 Registered Office: Victoria House, 18-22, Albert Street, Fleet, Hampshire, GU51 3RJ planning authorities to ‘set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres’.

Garden centres comprise one such use. Due to the high bulk to low value ratio of the goods sold, together with the requirement for large external areas for the display of plants, a town centre site is rendered unviable and inappropriate. Thus it is requested that the emerging policies of the development plan provide appropriate support for the continuing development of all types of existing rural business, including such specialist retail operators as our client.

The foreword to the consultation document identifies as the biggest challenge, the balance between enabling growth to provide much needed homes and jobs whilst protecting the existing attractive landscape environment. One of the fundamental tenets of the NPPF seeks to facilitate this balance by ‘encouraging the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value’ (para. 17). However no mention is made in the consultation document of the need to prioritise the use of brownfield sites.

It is requested therefore that the emerging Plan take full account of the opportunity offered by brownfield sites to achieve new development without detriment to existing undeveloped areas. The re-use of previously developed land also often offers opportunities to positively enhance the visual amenities of the area or secure landscape remediation.

Finally, our client considers that Endsleigh Garden Centre has the potential to contribute towards meeting future development needs within the District through its allocation for residential, retail, business, tourism or leisure purposes. Representations will be made at the appropriate time when the Council are considering their specific site allocations.

I trust you will find these comments useful, if you have any queries please do not hesitate to contact me.

Yours faithfully

Joanna Male cc. Client

From: [email protected] Sent: 11 June 2014 10:56 To: Strategic Planning Cc: Tony Edgcumbe Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Gary Parsons (where relevant) Job Title: Planning Manager (where relevant) Organisation: Sport England 21 Bloomsbury Street Address: LONDON Please enter the post code in the following format PL21 0PP Post code: WC1B 3HF Contact number:

Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Ensuring adequate access to recreations and open spaces should include Comments: built sports facilities, playing pitches, courts etc and natural resources. Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). We support Enabling healthy and active lifestyles and improving overall Comments: health and well being. Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Ensuring adequate access to recreations and open spaces should include Comments: built sports facilities, playing pitches, courts etc and natural resources. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Sport England advocates that a planned approach to the provision of Comments: facilities and opportunities for sport is necessary, new sports facilities should be fit for purpose, and they should be available for community sport. To achieve this, our objectives are to: PROTECT sports facilities from loss as a result of redevelopment ENHANCE existing facilities through improving their quality, accessibility and management PROVIDE new facilities that are fit for purpose to meet demands for participation now and in the future. 1. Local Plan & Evidence Base In reference to paragraph 73 of the NPPF, we raise concern that there does not appear to be a robust and up to date evidence base for sport and recreation in South Hams and West Devon but we are currently working with your local authority on a playing pitch strategy. Sport England’s view is that, in order to meet the requirements of the National Planning Policy Framework (NPPF) (formerly PPS12 and PPG17), this should include a strategy (supply and demand analysis with qualitative issues included) covering the need for indoor and outdoor sports facilities, including playing pitches.

2. Planning Obligations/Community Infrastructure Levy (CIL) to Sport Sport England supports use of planning obligations/community infrastructure levy (CIL) as a way of securing the provision of new or enhanced places for sport and a contribution towards their future maintenance, to meet the needs arising from new development. This does need to be based on a robust NPPF evidence base. This includes indoor sports facilities (swimming pools, sports halls, etc) as well as playing fields and multi use games courts.

All new dwellings in South Hams and West Devon in the plan period should provide for new or enhance existing sport and recreation facilities to help create opportunities for physical activity whilst having a major positive impact on health and mental wellbeing.

3. Protection of Sport & Recreation including playing fields Sport England acknowledges that the NPPF is promoting “sustainable development” to avoid delays in the planning process (linked to economic growth). Thatsaid, the NPPF also says that for open space, sport & recreation land & buildings (including playing fields) paragraph 74.

Sport England would be very concerned if any existing playing pitches would be affected by these proposals without adequate replacement in terms of quality, quantity, accessibility, management & maintenance and prior to the loss of the existing facility.

4. Active Design Sport England believes that being active should be an intrinsic part of everyone’s life pattern. The master planning of new housing proposal has a vital role in providing easy access to a choice of opportunities for sport and physical activity to suit all age groups for making new communities more active and healthy.

Sport England commissioned David Lock & Associates to investigate the contribution that masterplanning can make to create new environments that maximise opportunities for participation in sport and physical activity. This work including a developer’s checklist has been completed and can be accessed via http://www.sportengland.org/facilities-planning/planning-for- sport/planning-tools-and-guidance/active-design/

Through an analysis of the current health agenda and urban design principles and good practice, the term ACTIVE DESIGN has been adopted to describe ways in which master planning can promote healthy environments through creating healthy environments through creating conditions for participation in sport and physical activity and the use of active travel modes (walking and cycling). Three overlapping Active Design objectives have been identified that should be promoted by master plans: improving accessibility; enhancing amenity and increasing awareness.

Sport England would encourage the major urban extensions and significant

2 housing development be designed in line with the Active Design principles. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

3 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Mrs Laurence, Nicola Mary (where relevant) Job Title: Retired (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). I am writing as joint owner of land adjacent to the settlement boundary in Kingston. The site consists of two fields abutting the northern boundary of the village. It is adjacent to the existing housing exception site at Westentown and has access through the Westentown cul de sac. Comments: We would be interested in making this land available for development of any affordable/market housing or other sustainable needs arising in Kingston as considered appropriate either in this plan or through the Neighbourhood Planning process.

Please will you add this site to the SHLAA database and take it into consideration in preparing your new Local Plan. Further details including plans can be provided Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

South Hams ‘Our Plan’ – Shaping our communities to 2031

We are pleased to see Designated & Protected Landscapes, Green Infrastructure and Trees & hedges listed for the ‘our Nature’ topic.

1. Ancient Woodland and Ancient Trees As a core policy, the new Plan should have a clear commitment to absolute protection of ancient woodland and ancient trees. Government policy is increasingly supportive of this. It is now required under the National Policy Planning Framework, w hich clearly states: “ …planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland…" (DCLG, March 2012, para 118). In addition, the Government Forestry Policy Statement (Defra Jan 2013) reinforces this requirement: ‘We recognise the value of our native and ancient woodland and the importance of restoring open habitats as well as the need to restore plantations on ancient woodland sites. We, therefore, confirm our commitment to the policies set out in both the Open Habitats Policy and Keepers of Time, our statement of policy for England’s ancient and native woodland’. Finally, the Forestry Commission has published its Standing Advice with Natural England on Ancient Woodlands and Veteran Trees (Forestry Commission, April 2014) and its associated Assessment Guide (http://www.forestry.gov.uk/pdf/FCNEAWSAAssessmentGuideFinalJune2014.pd f/$FILE/FCNEAWSAAssessmentGuideFinalJune2014.pdf), specifically designed to help Local Planning Authorities process the required protection for ancient woodland and ancient trees.

2. New Woodland creation The new Plan should also support new woodland creation for all the benefits that it can deliver, particularly for green infrast ructure. Tree planting can deliver a wide range of benefits for local communities, in both a rural and urban setting, and this is strongly supported by current national planning policy. The Woodland Trust believes that woodland creation is especially important because of the unique ability of woodland to deliver across a wide range of benefits – see our publication Woodland Creation – why it matters http://centrallobby.politicshome.com/fileadmin/epolitix/stakeholders/4117Woodan dCreationbro.pdf.These include for both landscape and biodiversity (helping habitats become more robust to adapt to climate change, buffering and extending fragmented ancient woodland), for quality of life and climate change (amenity & recreation, public health, flood amelioration, urban cooling) and for the local economy (timber and woodfuel markets).

We also consider that the Council has a statutory duty to protect trees and promote tree planting. Section 197 of the Planning Act (1990) states:

197. Planning permission to include appropriate provision for preservation and planting of trees.

‘It shall be the duty of the local planning authority – to ensure, whenever it is appropriate, that in granting planning permission for any development adequate provision is made, by the imposition of conditions, for the preservation or planting of trees’.

The National Planning Policy Framework (NPPF) also supports the need for more habitat creation by stating that: ` Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure', (DCLG, March 2012, para 114). Also para 117 states that: ` To minimise impacts on biodiversity and geodiversity, planning policies should:....promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan' .

The new England Biodiversity Strategy which makes it clear that expansion of priority habitats like native woodland remains a key aim - ` Priority action: Bring a greater proportion of our existing woodlands into sustainable management and expand the area of woodland in England', (Biodiversity 2020: A strategy for England's wildlife and ecosystems services, DEFRA 2011, p.26).

A reading of these two policies in the National Planning Policy Framework together with the England Biodiversity Strategy indicates that habitat expansion, like native woodland creation, should form a high priority for this new Plan.

Woodland creation also forms a significant element of the Government Forestry Policy Statement (Defra Jan 2013): ` We believe that there is scope for increasing England's woodland cover significantly to deliver economic, social and environmental benefits. We want to see significantly more woodland in England. We believe that in many, although not all, landscapes more trees will deliver increased environmental, social and economic benefits. We particularly want to see more trees and woodlands in and around our towns and cities and where they can safeguard clean water, help manage flood risk or improve biodiversity'.

3. Exemplar Local Plan policy A good example of a Local Authority incorporating these w oodland elements into its Local Plan is the Solihull Local Plan (adopted Dec 2013) – see Policy P10 Natural Environment – ‘The Council will seek to conserve, enhance and restore biodiversity and geodiversity, to create new native woodlands and other habitats and to protect, restore and enhance ancient w oodland and green infrastructure assets across the Borough. Protection of ancient woodland, designated sites and priority habitats shall include the establishment of buffers to any new development. Development should be informed by the latest information on habitats and species, and take full account of national and local guidance on conserving biodiversity, opportunities for biodiversity enhancement and for improving and restoring the Borough’s green infrastructure’.

We also note the references to improving health and wellbeing, and also adapting to changing weather patterns.

1. Woods for health & wellbeing In an era of ever increasing concern about the nation’s physical and mental health, the Woodland Trust strongly believes that trees and woodland can play a key role in delivering improved health & wellbeing at a local level. At the same time, the Health & Social Care Act 2012 has passed much of the responsibility for health & wellbeing to upper-tier and unitary local authorities.

Although the relationship betw een the natural environment and health is a complex one, it is now widely accepted that green infrastructure – such as trees, woods and forests – can contribute to both preventative and restorative wellbeing solutionsi.

Increasing evidence has demonstrated the critical impact that trees can make in encouraging more active lifestyles and alleviating the symptoms of some of our most debilitating conditions such as dementia, obesity, heart disease and mental health problemsii.

This linkage between woodland and health is now firmly embedded in national Government policy for health, planning and forestry –

Health: “Access to green spaces is associated with better mental and physical health across socioeconomic groups…..Defra will lead a national campaign to increase tree planting throughout England, particularly in areas where tree cover would help to improve residents' quality of life and reduce the negative effects of deprivation, including health inequalities." Healthy Lives, Healthy People (Government White Paper, November 2010, paras 3.36-37).

Planning: “ Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and well-being of communities. Planning policies should be based on robust and up‑to‑date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision.” National Planning Policy Framework (DCLG, March 2012, para 73).

Forestry: “Our trees, hedgerows, woods and forests contribute signif icantly to the quality of life in both rural and urban areas. Amongst other things, they enhance the local environment and biodiversity, support economic growth through regeneration, help mitigate the impact of climate change, assist in reducing air pollution and provide important health and educational benefits….The Natural Environment White Paper recognised the value and potential for green spaces to support and contribute to everyone’s health and w ell-being. This is being reflected in the Public Health Outcomes Framework, which underpins the new public health duty of local authorities’. Government Forestry Policy Statement (Defra, January 2013, p.16).

But when it comes to turning this national policy into local policy and also local delivery, the perspective is currently less clear, with local authority Public Health teams and Health & Wellbeing Boards jostling with Clinical Commissioning Groups, Public Health England, NHS England and the National Institute for Health & Care Excellence (NICE) to find new ways of working.

There are excellent individual case study examples of woods and trees delivering local health benefits, such as Forestry Commission Scotland’s Branching Out mental health project iii, but there is a need to mainstream this relationship across the board in local policy and delivery.

At a time of ongoing budgetary constraint, such mainstreaming will clearly be a challenge. However evidence suggests that, as well as providing environmental and biodiversity benefits, woods and trees can be a cost effective solutioniv for reducing negative climate change impacts like poor air quality and for supporting local economic growth, as well as promoting healthy lifestyles. There are also great opportunities for positive local community empowerment and neighbourhood planning initiatives in woodland creation and management.

The King’s Fund, an independent healthcare charity, has produced Improving the public’s health - A resource for local authoritiesv, a report that sets out what Local Authorities can do for health together with the business case for doing so. The report says that: “ Increasing access to parks and open spaces could reduce NHS costs of treating obesity by more than £2 billion. Access to green space can reduce mental health admissions too, resulting in additional savings for the NHS…Analysis of Birmingham’s city-wide Be Active programme suggests that up to £23 is recouped for every £1 spent, in terms of better quality of life, reduced NHS use, productivity gains, and other gains to local authorities” .

Research by the Woodland Trust shows that only 17% of the population of England has access to local woodland within 500m of their homevi. In South Hams this figure is even lower at 12%. Providing more accessible trees, woods and green space can therefore provide a critical link to healthier lives in South Hams DC and, consequently, to saving money. In addition, the Government’s £3.8bn Better Care Fundvii (previously the Integration Transformation Fund) could support Local Authorities to better integrate green infrastructure like woods and trees into the health sector. iHartig, T., Evans G.W., Jamner L.D., Davis D.S., and Gärling T. (2003). Tracking restoration in natural and urban field settings. Journal of Environmental Psychology 23, 109-123. Ulrich, R.S. (1984). View through a window may influence recovery from surgery. Science 224, 420-421. Van den Berg, A.E., Koole S.L., and van der Wulp N.Y. (2003). Environmental preferences and restoration: (how) are they related? Journal of Environmental Psychology 23, 135-146. iihttp://www.scribd.com/doc/190436945/Healthy-Woods-Healthy-Living iiihttp://www.forestry.gov.uk/pdf/Greenspace.pdf/$file/Greenspace.pdf ivhttp://www.woodlandtrust.org.uk/mediafile/100083921/trees-or-turf-report.pdf vhttp://www.kingsfund.org.uk/sites/files/kf/field/field_publication_file/improving-the- publics-health-kingsfund-dec13.pdf vi https://www.woodlandtrust.org.uk/mediafile/100083906/space-for-people.pdf viihttps://www.gov.uk/government/publications/better-care- fund?utm_source= rss&utm_medium= rss&utm_campaign= correspondence-better-care- fund

2. Woods for water flow and quality The Woodland Trust believes that trees and woodlands can deliver a major contribution to resolving a range of water management issues. They offer opportunities to make positive water use change whilst also contributing to other objectives, such as biodiversity, timber & green infrastructure - see the Woodland Trust publication Woodland actions for biodiversity and their role in water management (pdf) - https://www.woodlandtrust.org.uk/mediafile/100083927/Woodland-actions-for- biodiversity-and-their-role-in-w ater-management.pdf . The intensity of weather events, like flooding, appears to be an increasing characteristic of climate change.

In addition, a joint Environment Agency/Forestry Commission publication Woodland for Water: Woodland measures for meeting Water Framework objectives states clearly that: ‘There is strong evidence to support woodland creation in appropriate locations to achieve water management and water quality objectives’ (Environment Agency, July 2011- http://www.forestry.gov.uk/fr/woodlandforwater).

The Government’s Independent Panel on Forestry (Defra, Final Report, July 2012) has emphasised these benefits by stating that: ‘One of the many benefits of woods and trees is their ability to help us respond to a changing climate, better enabling us to adapt to future temperature increases. We know that trees, in the right places, help us to adapt to climate change by reducing surface water flooding; reducing ambient temperature through direct shade and evapo-transpiration; and by reducing building heating and air-conditioning demands. A landscape with more trees will also help increase the resilience of our rural areas, by reducing soil erosion and soil moisture loss. Improving the condition of existing woodlands, and the creation of a more resilient ecological network of associated habitats, will help wildlife adapt to climate change and other pressures’. This has been endorsed by the response in the Government Forestry Policy Statement (Defra Jan 2013) with the key objective (p.23) ‘Work with other organisations and initiatives to support the further development of markets in forest carbon and other ecosystem services such as water and biodiversity’ , together with a Cumbria case study (p.22 - SCaMP) on water benefits from woodland creation.

Woodland can help adaptation strategies cope with the high profile threats to water quality and volume resulting from climate change. The Forestry Commission’s publication, The Case for Trees in development and the urban environment (Forestry Commission, July 2010), explains how: ‘the capacity of trees to attenuate water flow reduces the impact of heavy rain and floods and can improve the effectiveness of Sustainable Urban Drainage Systems’.

Trees can reduce the likelihood of surface water flooding, when rain water overwhelms the local drainage system, by regulating the rate at which rainfall reaches the ground and contributes to run off. Slowing the flow increases the possibility of infiltration and the ability of engineered drains to take away any excess water. This is particularly the case with large crowned trees. Research by the University of Manchester has shown that increasing tree cover in urban areas by 10 % reduces surface water run-off by almost 6%. (Using green infrastructure to alleviate flood risk, Sustainable Cities www.sustainablecities.org.uk/water/surface-water/using-gi/).

We would therefore like to see the concerns listed above included in the next iteration of the South Hams Plan.

For further information please contact:

Justin Milward Regional & Local Government Officer (South West) Woodland Trust Jayrise Butcombe Bristol BS40 7UT

Planning, Transportation and Environment Devon County Council County Hall Topsham Road Exeter EX2 4QD

13th June 2014

Dear Sir/Madam,

RE: West Devon and South Hams – ‘Our Plan’ Regulation 18 Consultation

Thank you for consulting us on the scope and options for the Local Plans for West Devon Borough Council and South Hams District Council (under Regulation 18 of the Town and Country Planning Regulations 2012).

The consultation documents clearly identify various challenges, under the themes of ‘People’ and ‘Place’, that the Plans intend to address. These priorities are welcomed, particularly around matters for which Devon County Council is lead local authority e.g. education and transport. We look forward to working with both West Devon and South Hams as Plans develop, ensuring necessary infrastructure is identified and planned for to support sustainable development.

We wish you well for the next stages in the production of your Plans, and look forward to working closely with South Hams and West Devon as the Plans progress over the coming months.

Yours faithfully,

Joe Keech Chief Planner

Textphone: 0345 155 1020 www.devon.gov.uk

Strategic Director Place Heather Barnes

From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Revd Rodney Bomford (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). It is not just beautiful natural surroundings that need to be preserved, but also the nature of some communities. In particular Modbury has a strong sense of community which would not be enhanced by 'bolting on' Comments: housing estates beyond the town's natural shape. We do not want to be the next Ivybridge! Some people like city life and some, such as most in Modbury, like the place to be about the size it is. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Under 'Our Wellbeing' you mention social inclusion and community assets. This does not necessarily include looking after the kind of community a Comments: place already is, and the network of relationships already present. Modbury has grown significantly in the last few years and further substantial growth will be destructive of its sense of community. Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Places are not just important because of historic buildings, but also Comments: because of their design and how they hold people together. This aspect is not apparent to me in your list. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000

1 characters). A realistic view of what the future of the South Hams should be. You show awareness of a conflict between development (houses and work-places) and natural beauty. This will intensify until gradually development wins, except in a few pockets, unless there is a real vision of an alternative. This alternative should recognise the importance of tourism and farming and also accept that an area like this is bound to house a growing retired population. These three factors all create employment. It is also inevitable that younger working people will to a considerable extent move away because of housing prices and job opportunities. Housing prices can only ultimately be lowered by making the area no more desirable than Comments: elsewhere - they are high, because people want to live in a beautiful place. Because there is restricted space, it will also not be possible to provide for every sort of employment that people want. Attempting to provide everything that everyone wants at a price they can afford is clearly impossible, but that seems to be implied in your document. New housing should be virtually limited to Civic Trust schemes providing local people with rented accommodation until they can afford to buy where they want. Most other house building simply draws in more people, probably mainly retired people, and exacerbates the problem it is intended to solve. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Christopher Balch (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). While the content of the new Local Plan is influenced by both the requirements set out in the NPPF and associated Guidance and key local issues I believe that there should be more explicit consideration given to the infrastructural and environmental capacity of the settlements in the South Hams. While acknowledging that responsibilty for the provision for both public and private transport lies with other bodies there is a clear need to ensure that the future development patterns are based on a full and objective assessment of transport, water supply, waste water, energy services. The lack of adequate infrastructure is frequently cited as a Comments: major reason for local resistence to new development. this issue needs to be explicitly examined in devising the new Local Plan.

It is noted that there is no mention of quality as an issue with respect to new development in the District. Again resistence to development frequently arises as a result of landowners and developers seeking to extract too much by way of land value and profit from the development process. The search for innovative apporaches to the delivery of new housing which meets the needs of local people is therefore welcomed. Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Broadly the issues facing the population of the District are well understood. Particularly in terms of ageing. However it is vital that the Local Plan gives equal consideration to the needs of the young and Comments: working population who generally have less time to contribute to the shaping of development plans. This is particularly the case in respect of provision of new affordable homes alongside a range of job opportunties. A vision of South Hams dominated by the views of its older residents is 1 unlikely to be the same as a vision generated by people with a long term stake in the area. Intergenerational equity is arguably one of the greatest challenges in areas like the South Hams. Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Broadly the issuesfacing the District are well understood. However it will be important that the plan takes into account strategic (greater than local) factors which could impact significantly on the future of the District and its communities. This includes the substantial levels of housing growth being planned for Plymouth and Torbay. South Hams lies between these major settlements and is liekly to be significantly impacted by the growth of these settlements. Comments: Similarly the vulnerabilty of the main rail line passing through the District has been highlighted by the recent events at Dawlish. The possible realignment of the line to protect strategic infrastructure from the impactof climate change could have a major impact on accessiblity to the district and consequent localtional preferences. A Local Plan which is looking forward to 2031 needs to consider theresiliance of the local economy to possible long term changes forward to 2031 needs to consider theresiliance of the local economy to possible long term changes Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Consideration of alternative development strategies for the District. The current Core strategy took the bold step to promote a new community at Sherford. Notwithstanding the delays which have been experienced in Comments: getting the development underway it is considered that this bold approach needs to be continued rather than planning on the basis of incremental growth of exisiting towns where infrastructure and environmental constraints (and public opinion) makes this difficult to achieve. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 Subject: Neighbourhood Plan information... Attachments: One plan conversation.doc; One plan conversation.pdf

Dear Phil,

Since the helpful meeting you arranged in Totnes i have been taking further interest in the South Hams One Plan.

I have been encouraging my colleague parish councillors in West Alvington to engage in the consultation process and also to consider developing a Neighbourhood Plan.

Unfortunately our meeting last meeting was non-quorate so we are unable to send you any decisions to include in the consultation process which ends, as I understand it, on 20th June. Just in case it is of interest, however, I attach the discussion paper I prepared for the meeting which was found to be of interest. In particular we discussed the degree to which the District may be subject to a gradual decline in terms of productive population and potentially productive prime agricultural land along with a failure to appreciate the extraordinary natural resources we have, for instance, for renewable energy. It is difficult to make sense of all the data you have gathered in terms of the long term dynamic changes and the level of dependency we have, for instance, on incoming tourist spend.

You will see that I would encourage your team to engage in consultation through combinations of town and parish councils, as well as the work you are doing with District Councillors. I continue to be struck by how little of the fine data you have assembled reaches a wider audience of the local community, clearly crucial to the success of any strategic outcome you determine.

There seems to be some possibility of a number of rural parishes combining to consider a neighbourhood Plan, mainly centred on Simon Wright's ward over which he has some influence. I would really like to find ways of pursuing the idea of town plus neighbouring parishes and will try to engage the newly elected Mayor of Kingsbridge with this idea.

In the meantime I wish you and your team well in this complex process. I have been broadcasting my appreciation for the intelligence and effort you all seem to be bringing to the task - I would just like more local citizenship involvement if possible. with best wishes,

1 West Alvington Parish Council

Meeting Thursday 5th June 2014

Some Thoughts about the South Hams District One Plan Consultation.

Introduction:

At the last meeting held on 8th May I reported on a meeting held by South Hams District Council for town and parish councillors to introduce the consultation process on South Hams “Our Plan”.

I suggested that we might reserve some time for a fuller discussion to decide on whether we want to make any observations or representations as part of the consultation process. This initially runs, as I understand it, to 20th june.

I also raised the question as to whether we might consider engaging in developing a Neighbourhood Plan, perhaps based on Kingsbridge and its neighbouring parishes.

The mail from Joan includes the basis of the One Plan in a large series of documents placed on the web-site through which I have scanned - but it is hard work!

I have chosen, therefore, in this little brieﬁng document, to offer a few, obviously personal, thoughts at a rather conceptual level along with more speciﬁc requests we might make as a next stage of consultation.

Why bother?

This seems to me a really good question. Indeed, we began to debate it last time we met. There is a feeling amongst parish councillors that we are pretty powerless to intervene on matters, such as planning, and that much voluntary time can be squandered in the process. This feeling was expressed at the parish council meeting and amongst a broader segment of councillors at the District meeting. Many councils are doubting their willingness to undertake the considerable work involved in developing a Neighbourhood Plan on the basis that decisions will inevitably be taken elsewhere.

Indeed, there are similar reservations at the District level which is subject to strong policy guidelines and targets from central government.

Along with these speciﬁc reservations about the value of planning at a local level, there is also a more general view that “strategic planning” is pretty useless in the face of overwhelming political and market forces.

A District under Siege:

I have been struck, in the meetings I have now attended at District level, by a mood amongst fellow councillors at town and parish level that we are under siege, with little power to halt the gradual erosion of our precious natural heritage. A combination of national guidelines ( an unconsidered response to decades of neglect to national house building) and market forces has created what some describe as a ‘feeding frenzy’ amongst developers, who are seen as pretty rapacious and purely proﬁt motivated.

A more considered reﬂection over the longer term, based on some of the background data in the planning documents, suggests that we live in a District which is subject to a gradual process of transformation now accelerating, in the view of many. There continues to be a major demographic shift. Census information for the past decade shows, if I have read the ﬁgures correctly, that while overall population has increased by 1.6%, ‘old people’ in the District have increased by 16% with a corresponding net loss of young and working age people. The number of dwellings has increased by 6.4% but all the anecdotal information suggests that a very large proportion of this increase has been taken up by retirees and second home owners, with continuing pressure on affordable housing for local people who service this growing population of visitors and retirees.

The set of challenges identiﬁed by the District strategic planners recognises this particular shift along with more general issues:

!> Population Change !> Market and affordable housing !> Out migration of young and working age population !> Energy security including energy generation and fuel poverty !> Climate change !> Health and well being !> Neighbourhood plans.

On the basis of these challenges Our Plan is intended to include:

!> Vision !> Homes !> Economy !> Heritage !> Communities !> Nature !> Resources !> Well being.

While I was struck by the thought which has gone into identifying the challenges along with much background data, and the accompanying sets of topics under general headings of People and Place, there is clearly a complex set of interactions at work here with which the District and local councils have only some very limited ways of intervening strategically.

However, I take the view that it is deﬁnitely worth our while (citizens of the South Hams) to try to understand these complex interactions and the various sources of power at play, and to develop clear sighted intentions to inﬂuence pro-actively.

A possible cohering Vision:

As I wade through the data I search for some kind of guiding principle or cohering vision to help me make sense, in the ﬁrst instance, of our situation and to consider possible combinations of choices. Interestingly the National framework for planning (NPFF) is headlined under the term sustainability and offers a set of three interlocking aspects, Social, Environmental and Economic.

It seems to me that this framing could help given substantial clariﬁcation of each aspect and the way they might inter-act including prioritisation between the three.

I suggest that the District declare, as their “Vision” an intention that the community of the South Hams, human and other than human, forms a self-sustaining or resilient community for the generations to come.

This leads me to offer a few suggestions for the immediate future of the planning process.

Assembling the data for ease and depth of understanding:

A vision for local resilience suggests assembling data in the form of ﬂows , in- and out-, across District boundaries. As noted earlier these ﬂows include, crucially, population along with, for instance, energy, food, water, money, waste and so on.

I doubt that all this data is easy to establish, certainly with any precision, but there is much located in different sources that might begin to form the basis of a coherent understanding out of which competent strategies can be considered by a wider section of the population.

There are obvious choices facing us, for instance, with land use. Should we be valuing land highly as a natural resource for the production of food for local sustainability, as a vital ingredient of our attraction to visitors with their incoming £s, for development as places for employment, innovation and entrepreneurship or housing for local or open market needs. Unfortunately these different valuations have widely varying levels of precision and understanding, refer to ownership versus stewardship and differing timescales.

Similarly, the well established battleground of renewable energy could do with a wider level of understanding and agreement amongst the District community to establish a mix of wind, solar and wave based solutions, for example, to energy generation. Similarly we could do with some much clearer and tougher measures on energy conservation in the new building sector, both commercial and domestic, as well as a targeted programme for insulating existing buildings and installing energy sources. A District based Vision for local resilience cannot rely on national measures.

I could certainly do with a much better understanding of our economic status as a District. Clearly we rely to a considerable extent on money ﬂowing across our boundary in the form of tourist spend and newcomers capital injections. These support a very substantial infrastructure of services offering employment and livelihoods to local people. Clearly the strains of this pattern show up in market pricing of housing, for instance, along with many other social considerations for absence of community in many of our villages.

We live in a highly productive farming and fishing area and there must be significant flows in both directions across our district boundaries of food. It would be really helpful to understand the net flows and constituents to help guide local policies in these areas.

Just a few areas for consideration as we try to make sense of the District from the potential vision of sustainability or resilience. Communication and Consultation through Neighbourhoods.

There is much stress in the planning process on the development of Neighbourhood Plans. As noted above, there is also a good deal of scepticism about the value of such plans compared to the effort required to develop them.

My suggestion is that we ask the District ofﬁcers, through our representatives, to engage in a communication and consultation effort through neighbourhoods of towns and their local parishes.

If this is combined with the assembly of data on the basis suggested above, combinations of councillors could begin to envisage similar ﬂows across and within their neighbouring communities. More local suggestions could emerge including the siting of enterprise based land usage - logistics and light industry clearly more suited to the A38 corridor while smaller, craft and artisan based enterprises in the southern parts of the District.

Research and data based strategies.

We are supposed to be working to a national policy framework of sustainable development based, as noted earlier, on the interactions of Social, Environmental and Economic factors.

I certainly have no idea how well we are doing on that score but I suspect very badly indeed.

As it happens we have the multi-functional Institute for Sustainability on our District doorstep at the University of Plymouth.

I suggest that the District commission an in-depth if small scale study of the impact of recent planning decisions around the District. It would be fascinating to know what impact commercial and domestic sites have had, once developed, on population demographics, social diversity and cohesion, health and well being, economic activity and value, environmental degradation and so on. Such a study could begin to furnish us with the basis for much more data based decisions and guidelines.

Summary:

Of course we may decide to take no further part in the One Plan process on the basis that any effort is unlikely to be productive. I certainly have sympathy with this view.

Or we may dip our toes in the water a bit, to make a few practical suggestions for the way in which the consultation moves forward, in the hope that we become better informed at a coherent level of understanding and might join with neighbouring communities in trying to fashion a future which is realistic to the national and market forces we face but also offers local contention and determination.

On this basis I offer a few suggestions we might forward, presumably through Simon, to engage with the consultation process in the present timescale.

I look forward to our conversation on Thursday.

Robin 3/6/14

From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Jessica Crellen (where relevant) Job Title: Junior Strategic Planner (where relevant) Organisation: Persimmon Homes Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). In regard of housing, we believe that the Plan should robustly consider the distribution and quantum of housing growth, growth areas or areas of search,spatial distribution of sites, specific site allocations and a settlement hierarchy that identities the key Comments: settlements and villages, strongly linked to the distribution of housing growth. The Company also feels it is important for the Council to have a permissive approach when it comes to policy, to not have any housing design requirements that would restrict growth. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). We believe the categories identified are broad and non-descriptive. It would be useful to understand how this information will be fed into the preparation of the new Local Plan and what use this feedback form has. The plan makes no reference to addressing housing need or providing Comments: affordable housing to allow local people to stay within the local area that they originate from. Far greater importance should be put on housing delivery, need and accessibility of all types of housing (both affordable and private). Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). As stated above, this section is very broad and is not relevant to the Comments: context of South Hams. The plan makes reference to enabling the right amount of development in the right places, however makes no mention to the 1 creation of new communities and neighborhoods within sustainable places. It is unclear how the categories are going to be robustly assessed, reviewed and implemented as policy within any emerging plan. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). The Company acknowledges the plan is within the early stages of preparation and is at an extremely broad stage. Within the plan, the Council makes reference of the population increase by 1.57% since 2001 (83,140) and the number of dwellings up by 6.64%. It is clear that the council acknowledges the growth pattern which strongly demonstrates the continued housing need for the district. We want to stress the importance of the Council fully responding to the historic trends in housing need and supply and robustly cater for the continued growth of South Ham's housing market. There has been lack of delivery of housing over the previous plan period and there is a significant under-supply. The NPPF states that all Local Planning Authorities must have at least a 5 year land supply. When establishing housing targets there is a need to address this, within the first five years of the plan period in accordance with the Sedgefield approach. The Company supports the bulk of the growth to be directed at the main towns, specifically Comments: Ivybridge, Totnes and the Plymouth urban fringe; and promotes the Company's land holdings at Woodland Road, Ivybridge, Barracks Hill, Totnes and Old Newnham Farm, Plymton for suitable residential sites and encourage the Council to consider these sites for specific allocations.The plan will need to comply to the National Planning Policy Framework and have a presumption in favour of sustainable development. With regard to viability, the Company would like to see sufficient flexibility where viability would require a reduction to affordable housing and/ or other contributions. Lastly, we would like to draw attention to the Duty to Cooperate and the importance of working with other Local Authorities throughout the whole process of the new Local Plan. This includes the quantum, delivery and spatial location of housing. It is important to make reference to Plymouth City Council who will shortly be preparing their new local plan. We encourage South Hams to work with such authorities to fully address the combined housing needs. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: FW: Our Plan Response SH

Our Plan Response SH

Your details Name: JILL DAVIES (where relevant) Job Title: CHIEF OFFICER (where relevant) Organisation: SOUTH HAMS COMMUNITY & VOLUNTARY SERVICES Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Response from a small VCS subgroup: Our wellbeing - include Volunteering; include fuel poverty; Our Vision - add Our partners - or preferably it should be a seperate box (as below) Our Partners - bullet points below Strategic Planning together; Statutory Health; Comments: Local Government; Emergency services; Voluntary & Community Sector Others Our Communities - add rural isolation Our Homes - add Homelessness; Affordable should say 'Low cost';add Sheltered/Supported Accomodation Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Response from a small VCS subgroup: Add: Encouraging citizens to be involved in community activities Partnership working Poverty & Welfare reform impact Comments: Encouraging continuous learning vulnerable groups Encourage Equality & Diversity Take out and put in Place: Building a mix of housing changed to enabling a mix of housing Housing solutions bit 1 Waste reduction Change Retaining to attracting & involving young people and familites Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Response from a small VCS subgroup: Change improving transport links to support sustainable public & community transport Change making the most of new technologies to improving access & use of Comments: new technologies while ensuring inclusivity Add: Commissioning locally & for added social value Supporting new social enterprise and community groups

Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Response from a small VCS subgroup: More about Equality & Diversity, including with regard to access to services

Comments: Something about Sherford new town and how this is going to impact on and add to services etc

More about partnership working and involving all sectors, particularly voluntary & community sector in initial project planning Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

From: Strategic Planning Subject: FW: South Hams - Our Plan E-newsletter - Issue 1

Importance: High

For the attention of Phil Baker, Strategic Planning Officer

Dear Mr Baker

I write on behalf of Cornwood Parish Council, for which I am the Parish Clerk, and I was an attendee at your meeting at the beginning of May when you launched the plan.

The Parish Council is thoroughly dismayed that you are allowing so little time for the dissemination of the details to Councillors and thus the local communities – that you expect anyone interested to have the time to trawl your website and make a response to you by the 20th June, and that within a very limited time frame you hope for a considered response on the essential elements of local knowledge. Whilst you are offering a number of local events all of these will be shortly after the closing date of the consultation on the scope of the plan, and will presumable be focussed on the next stage of your Plan.

We are also very concerned that you have such a focus on consulting with developers and land agents – these people do not represent the communities yet you are offering ‘specific events’ to talk through your plan with them. This will create a developer‐led plan because developers will have the greatest vested interests in having the plan in place – working only subjectively. The work of Parishes, Councillors and members of the public will be largely objective and it is essential that the balance is right.

May I point out that most Clerks of smaller Parishes only work a few hours per week (and Parishes usually only meet once a month) and your expectations that we can all consult extensively in such a short time is totally unrealistic. There are other competing factors locally especially now that both SHDC and DCC expect Parishes to take more responsibility for providing local services , and for most Councillors (who are all voluntary) and Clerks who work only a few hours ‐ actually earning a living is priority. Offering only a very short time scale for consultation is usually a sign that the decisions are already made.

We would be very pleased to have your views on these matters of concern to us

Sincerely Sally Fairman, Clerk to Cornwood Parish Council.

Your Ref: Our Ref: MC/

17 June 2014

Strategic Planning Team South Hams District Council Follaton House Plymouth Road Totnes, Devon TQ9 5NE

Dear Sir/Madam

South Hams Our Plan Consultation May/June 2014

The Trust is grateful for being consulted on the scope of the new South Hams local plan. At this stage the Trust would like to make the following comments in relation to identified challenges for ‘Places’:

Conserving and enhancing the historic environment

The National Planning Policy Framework (NPPF; 2012) establishes a core planning principle to conserve heritage assets in a manner appropriate to their significance (NPPF; para 17). It requires local planning authorities to set out in their local plan a “positive strategy” for the conservation of the historic environment, including heritage assets most at risk from threats (NPPF, para 126).

In the recent report on the Examination into Mid Devon Local Plan Part 3 - Development Management Policies (July 2013), the Inspector found the Mid Devon District Council (MDDC) policy on Development affecting Heritage Assets, which largely reflected “the thrust of the approach advocated in paragraphs 126 to 141 of the NPPF”, to be unsound:

“…to be sound …I consider that, in line with the guidance in paragraph 126 of the NPPF, it should be more positively worded, emphasising the desirability of new development making a positive contribution to local character and encouraging enhancement of local distinctiveness. The Policy and supporting text could also be

National Trust President: HRH The Prince of Wales South West Region Regional Chair: Clare Broom Killerton House, Broadclyst Regional Director: Mark Harold Exeter, Devon EX5 3LE Registered office: Heelis, Kemble Drive, Swindon, Wiltshire SN2 2NA Registered charity number 205846

clearer by referring to the systematic approach to the assessment of proposals affecting setting as set down in guidance from English Heritage: ‘The Setting of Heritage Assets’.” (Report to MDDC, by Douglas Machin; 17 July 2013; para 29)

The Trust would like to see a positive strategy for the conservation of the historic environment in the South Hams local plan, which provides clarity on the need for a systematic assessment of development affecting the setting of heritage assets.

Conserving and enhancing the natural environment

The new local plan should reinforce the National Planning Policy Framework requirement for conserving the landscape and scenic beauty of AONB (NPPF; para 115) by being clearer that this should be given ‘great weight’ in development management. The recent High Court case on the School Hill site at Mevagissey (Megavissey Parish Council v Cornwall Council and Megavissey Bay View LLP) highlighted the need in decision making to demonstrate giving the conservancy of the AONB great weight.

In relation to major development in the AONB the NPPF requires exceptional circumstances and public interest tests (NPPF; para 116). However, the NPPF fails to provide a definition of ‘major development’ in its glossary. It has been clear from appeal decisions, subsequent to the NPPF coming into force, that there is a lack of clarity over the definition of ‘major development’ in the context of paragraph 116 of the NPPF. For example, in the case of an appeal, in Chipping Camden, Gloucestershire (APP/ /2173963), in relation to 18 dwellinghouses in the Cotswolds Area of Outstanding Natural Beauty the Inspector deemed the proposals not major in the context of paragraph 116 of the Framework. But, in a recent appeal case in relation to Old Kiln Quarry in Berkshire (Appeal Ref APP/ /2173977), with regard to paragraph 116 of the Framework, the Inspector cited extant planning legislation for a definition of ‘major development’, and the definition provided by Statutory Instrument 2010 No.2184 – The Town and Country Planning (Development Management Procedure) (England) Order 2010, where ‘major development’ includes the provision of 10, or more, dwellinghouses.

The new local plan for South Hams should include a policy, or supporting text, on major development in AONB that would clarify the interpretation of national policy at the local level, including a clear definition of ‘major development’. The Trust supports the definition of major development provided by Statutory Instrument 2010 No.2184 – The Town and Country Planning (Development Management Procedure) (England) Order 2010.

Finally, the Trust would like to see a clear policy on the undeveloped coast, taking forward the NPPF national conservation objective that local planning authorities should “maintain the character of the undeveloped coast, protecting and enhancing its distinctive landscapes” (NPPF, para 114). The Inspector who recently reported on the Teignbridge local Plan in April 2014, commented that:

Cont/d

“The plan follows guidance in paragraph 114 of the NPPF in setting a restrictive policy context for substantial areas of coastland, through the ‘Undeveloped Coast’ notation.” (Teignbridge DC Local Plan; Inspector’s Report April 2014).

The new South Hams local plan should establish clear criteria or spatial definition as to what constitutes ‘undeveloped coast’, and clarity as to how it will be treated.

Enabling Renewable Energy

The National Planning Policy Framework, which aims to increase the supply of renewable energy, requires that local planning authorities should ‘have a positive strategy to promote energy from renewable and low carbon sources’, and ‘consider identifying suitable areas for renewable and low carbon energy sources’ (NPPF; paragraph 97).

The National Trust is a member of the Planning and Climate Change Coalition (led by the Town and Country Planning Association, and also supported by the Renewable Energy Association), which has developed Planning for climate change – guidance for local authorities (April 2012), the first sector-led environmental planning guidance of its kind following the introduction of the NPPF in March 2012: [http://www.tcpa.org.uk/pages/planning-for-climate-change-guidance-for-local-authorities- 2012.html]. As part of good practice this guidance recommends that local authorities identify the most and least environmentally sensitive areas for deployment of different renewable energy technologies (part 3.4).

Assessment[s] of Landscape Sensitivity to onshore wind and large-scale PV by Land Use Consultants have been completed for both Cornwall Council and Torridge District Council, and are currently being finalised for North Devon District Council. The completed assessments fulfil the recommendation in the best practice guidance by assessing the sensitivity of each landscape character area (LCA) or landscape character type (LCT) to wind and solar technologies, and by developing a ‘landscape strategy’ and siting guidance as a guide to deployment. The Trust would like to see such an assessment for South Hams as part of the positive strategy required by national policy.

The Trust also supports the principle of consistent guidance on renewable energy development across Devon, as now developed by Land Use Consultants on behalf of the Devon Landscape Policy Group, through the Advice Note [‘Accommodating Wind and Solar PV Developments in Devon’s Landscape’, LUC; June 2013]. The Trust encourages each local authority in Devon to adopt this guidance.

National planning policy in the NPPF whilst being supportive of renewable energy states that local planning authorities should “design their policies” … “ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts” (NPPF; paragraph 97). Paragraph 98 requires local planning authorities to consider whether the impacts of a renewable energy proposal are (or can be made) acceptable. The NPPF makes clear that in determining planning applications for such development; planning Cont/d

authorities should follow the approach set out in the National Policy Statement for Renewable Energy Infrastructure and the Overarching National Policy Statement for Energy Infrastructure (NPPF; paragraph 97; footnote 17). The Overarching National Policy Statement for Energy Infrastructure (EN-1) states that the aim for projects should be to “minimise harm” to the landscape (EN-1; 5.9.8).

In order to “ensure” adverse impacts (including “cumulative landscape and visual impacts”) are satisfactorily addressed in line with national policy the Trust believes reference should be made in the new local plan to the best practice guidance on the; “Siting, Design and Assessment of Wind and Solar PV Developments in Devon”.

The Trust hopes these comments will be taken into account and would like to be consulted once a draft local plan is prepared

Yours sincerely

Michael Calder Planning Adviser

Cont/d

South Hams Society’s comments on the April 2014 Consultation Document for the South !Hams Local Plan! The consultation document presents the plan in 7 pages; a map of the South Hams District, a foreword by Mr Tucker, the leader of the Council, a diagram outlining the plan’s major contents, a timetable, two pages containing simple statistics and objectives and an !invitation for readers to comment.! Such a simple minded consultation document could have been produced with a few days work at any time in the last two years since the National Planning Policy Frame (NPPF), !required it. ! The child-like graphics and statements of the plan’s contents are pitched at such an outline level that it provides no guidance to make meaningful comments. A reader can only agree !that the plan should indeed cover the areas suggested. ! No doubt the document will generate some response but as most of the context and references required for the local plan are missing much of the response will be wide of the !mark, lacking in relevance or practical use.! Mr Tucker in the foreword complains that ‘Unfortunately most people only get involved at a much later stage’. This was certainly the case with the previous District plan, the LDF, and many complaints about lack of consultation were received at the public hearings. The !process currently proposed will only perpetuate this problem. ! The timetable shows that this is the single consultation document to be provided before the final draft is produced for examination by the planning inspectors. As the current document is ineffective and as there will be little opportunity for any significant change to !the final draft there will be no effective consultation.! This problem is exacerbated by the fact that ‘work with local communities, stakeholders !and partners takes place in July and August, i.e. when many are away on holiday.! What is needed is a more detailed consultation document midway between this outline stage and the final consultation. The aim must be to present a draft of proposals which can provide ‘material issues’ when neighbourhood plans and planning applications are !considered for approval. ! This is the only way for Mr Tucker to achieve his objective of ‘trying to engage more people earlier in the process’. Enable people to comment by providing concrete proposals to support or oppose at a point when there is time for their responses to be considered for !the plan. ! The newsletter proposed are a useful way of updating people but will stimulate responses only if they contain concrete and specific proposals. And in addition stakeholders will need !to see the complete detailed consultation document to enable them to comment usefully.! In inviting the public to contribute, the council should include in this new consultation document the main points of all evidence it already has. For instance, an SHMNA has been carried out. There is little point in soliciting opinions on housing provision which are made in ignorance of the SHMNA.! It happens that the SHMNA gives wildly variable evidence. The ONS demographic forecast an ageing population with slow growth. The South Hams becomes a major retirement and tourist centre for the UK and there is little other industry. But the economic forecasts were !for fast growth of employment with increases in the working population and the young. ! Depending upon which is adopted, the two scenarios have profound implications for the plan - vastly different numbers and types of new dwellings, schools, employment sites, !health care provision and infrastructure. ! The consultation for the local plan should not conceal this dilemma. It should present the pressures the Council is under from central government but also ask How many new houses do parishes and towns want? How much appetite is there for market, as opposed !to affordable, houses? What would help to keep housing within reach of young families?’! Another important topic is the protection to be afforded to the natural environment. The existing document contains simple references to ‘Designated and protected landscapes’ !and ‘protecting and enhancing our natural landscapes’ but no further detail at all. ! On the South Devon AONB which covers about a third of the District, for instance, Nick Boles, the Planning Minister, has made it clear that the local plan should say what is meant by 'great weight', 'major development' and 'public interest' in paragraphs 115 and 115 of the NPPF.* Other examples where the content of the local plan must supplement the NPPF could be cited. ! ! One benefit of SHDC being so late in its preparation of a local plan is that we can look at the content of neighbouring LPAs' plans, for example, Teignbridge, and try them for size !here. It would be very helpful if references were given to these.! The NPPF requires effective consultation with the public. Without a consultation document containing the level of detail described above effective consultation will not be obtained. The Council will have backed off taking the public into it’s trust and Mr. Tucker’s objectives !will not be realised.! ! * The Society has determined from Nick Bowles, via Sarah Wollaston MP, that the terms used in these paragraphs must be interpreted by the local planning authority. From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Paul Bennett (where relevant) Job Title: Secretary (where relevant) Organisation: Totnes and District Society (Totsoc) Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters).

Comments: But many of the hopes/aspirations are not within SHDC control Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters).

Comments: As before Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters).

Comments: as before Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters).

Comments: Please see separate email which will follow this. Keeping in touch Would you like to be kept informed of prgress with Our Plan? 1 Updates Yes Data Protection

SHDC Our Plan response form 06.14

Additional items which Totsoc wish to discuss with SHDC Strategic Planning

1. The economic impact on Totnes of the closure of Dartington Arts College. 2. Would further outward expansion of Totnes destroy its integrity as an historic small market town? 3. The total population of the District since 2001 is largely unchanged but age group 30 – 44 is down 22% with age group over 65 up 16%. Average weekly wage up 25% house prices up 91% (2001 – 2009). It is self–evident that affordable housing is needed and that more open market housing will continue to increase the imbalance of the population. With central government planning/housing policies as they are do we simply have to accept the inevitability that Totnes will lose its present vibrancy and regress into a somnolent retirement town? 4. Brownfield sites within the town for further consideration: Dairy Crest. Car Parks – consider apartment/flat development above them Follaton House car park. Survey small sites currently under-used/derelict. KEVICC impact of possible re-location to Dartington. 5. Employment land. The allocation of land for this purpose should be re-assessed. Speculative development for B1 B2 uses has not been viable for many years and this is likely to continue. Creation of jobs should be the criterion not site allocation. Consider intensifying employment on the Babbage Road industrial estate. Release land at Ashburton Road for further housing and give further consideration to the employment land at the impending Riverside development. 6. DCC must be urged to come up with realistic A385 management plan proposals with the developments taking place not only within South Hams but within Torbay the congestion problem cannot be ignored. 7. Impact on services and infrastructure generally needs to assessed and discussed.

2 Devon Senior Voice Senior Council for Devon In partnership with

PO Box 210, Harberton, Totnes, Devon TQ9 9DA

SOUTH HAMS DISTRICT COUNCIL.

17th June 2014

Strategic Planning Team, Follaton House, Plymouth Road, Totnes, TQ9 5NE

Dear Sir, SOUTH HAMS – OUR PLAN – SHAPING OUR COMMUNITIES.

Devon Senior Voice(DSV), wishes to acknowledge receipt of the above consultation document which provides information about an overarching strategic plan for the District of South Hams up to 2031.

We welcome the opportunity for consultation and would like to make representations on a number of important issues which are of interest to the “Over 50”, with particular regard to the provision of “houses fit for purpose” and social well-being policies. It is of critical importance that these issues are addressed in detailed policies which are included in the emerging plan, in order to avoid any ambiguity and frustration at later stages in the plan preparation stages. All too often the planning authorities are criticized by the general public for allegedly failing to understand the needs of an ageing population. Perhaps one of the main reasons is that the public fail to grasp the opportunity to work with the planning authorities at the early stages of the consultation process when the plan is evolving. Therefore, Devon Senior Voice would like to offer its support at any stage of the plan preparation as thought to be appropriate by the Planning Authority.

It is difficult to comment on the contents of “Shaping the future to 2031 Response Form” because of its generality. However, we have endeavoured to identify some of the issues facing an ageing population in South Hams which we believe should be included in the New Local Plan.

Devon Senior Voice is a voluntary forum working with Devon County Council and the NHS Devon to improve the lives of people aged 50+. Devon has an ageing population, and older people are a creative resource for the community. The Devon Senior Voice was started in 2008 to provide an effective independent and non-party political forum that is listened to by the policy makers at Devon County Council and NHS Devon. Since then, nearly 2000 individual and associate members in 19 groups across the county have been working together with the authorities to improve the lives of people aged 50+, monitoring and reporting on services. Since April 2013 the organisation has joined a partnership with Healthwatch Devon to monitor services and feedback to identify trends and bring individual cases to Strategic Groups in the County.

Devon Senior Voice is a company limited by guarantee. Registered in England with number 06538562 Reg. Office c/o Foot Anstey Solicitors, Senate Court, Southernhay Gardens, Exeter, EX1 1NT

REPRESENTATIONS.

AIMS AND KEY ISSUES. Housing Develop homes in locations which reflect local needs with particular reference to an ageing population.

Balanced Communities. Provide schools, medical and social care and ensure that the infrastructure is adequate for the population in each locality. Transport Public transport in rural areas is critical for an ageing population in order to sustain villages. DSV is seriously concerned that there appears to be no mention on Page 6, “ About the Plan” in regard to Transportation Older Age The need for recognition in the plan that the provision of “housing fit for purpose” particularly for the retired, is a major issue in South Hams.

OUR HOMES. Future Housing Numbers. Devon Senior Voice consider that the allocation of local housing need to be considered for inclusion in the plan for the period up to 2031 is likely to be perhaps the most contentious issue that will require consideration. Consultation will be of critical importance because it is this factor of the planning process that will enable the plan to proceed smoothly through its various stages. The justification for the scale of Residential Development in the plan must be spelt out and be written in a simple manner in order for the public to understand the importance for the need for more housing. The creation of a more balanced community in the rural villages in order to achieve sustainability must be one of most important spatial strategies of the plan. DSV is pleased to note that in the Housing Position Statement March 2014, the Plan will be able to demonstrate a 5 Year deliverable supply of housing sites. The fact that this allocation is outside the Plymouth Urban Fridge is an important distinction to make. If a five year supply of deliverable housing sites is not being achieved, then the Planning Authority must work progressively to bring forward additional allocations or outstanding planning consents. Affordable Housing. Devon Senior Voice strongly supports the provision of affordable housing on open market sites. We are aware that there is a high demand across the whole age spectrum and not just in the younger generation age group. Many of the rural planning authority housing surveys highlight the need for affordable housing but the actual number planned for 2010/2011 shows inadequate provision. South Hams shortfall in affordable housing provision indicated as 19% of need, (Countryside Alliance findings in Aug 2011)… This survey rightly points out that “homes and jobs need to go together. Without homes and jobs there is no community to support local shops, schools and services. We believe that there is an essential need for reliable up to date information from Parish and adjacent parish housing need surveys. DSV is of the opinion that there is a serious lack of awareness by many parish councils and communities of what effect the lack of affordable housing will have on rural quality of life. Many seem to be oblivious to the fact that unless we can provide homes for a balanced age population capable to support services, then the villages will be unsustainable. We would highlight the work being carried out by the Community Council of Devon, through the work of the Rural Housing Enabler, and the support they give to parishes in the preparation and implementation of local housing need surveys. The Local Plan must therefore present a positive approach and DSV suggest the inclusion of a Policy to allow for “Mixed Market and Affordable Housing Outside Built-up Area Boundaries”. This policy to allow for up to 15 dwellings to be allowed in rural settlements where there is a proven local need. Affordable housing must account for at least 66% of the houses built. Obviously to be permitted, evidence would need to show affordable housing need, development within or well related to the existing village built form, and control over the occupancy of the affordable dwellings. However, “Fundamentally, any resolution of the housing crisis will require the many strands of Government to work together, and for planning in particular to be linked to other disciplines. Infrastructure funding policies must be linked to planning policies”(RTPI, chief executive, Trudi Elliot). SELF BUILD. DSV supports those who wish to self-build and is specifically recognised in National Planning Policy Framework and the Government is actively promoting as part of the solution to the shortage of financially accessible new housing. Housing mix and type. The study of the “Housing Aspirations of Older People Living in Rural Devon, produced by the Community Council of Devon on behalf of Devon Rural Housing Partnership in 2011 examined the issue of “Type of accommodation need”. In this study the residents were asked to give their preference between house, bungalow and apartment. Respondents replied with strong support for a bungalow if the home was specifically designed for older people but with no support services. However, support for a bungalow or apartment was even, when in a situation where older people required a more extensive support service. The study avoided the phrase “sheltered housing” as it can cover a wide range of accommodation. The study stated that it was not unexpected that older households prefer either accommodation better meeting their needs or accommodation without any support. Over 53% of residents wanting to move house said they simply wanted a home which better met their needs. Clearly this would include people looking to downsize or move to easier maintained property. The study clearly indicates need for the new Local Plan to provide for a mixed housing type suitable for an ageing population. Life time Homes and Care/Extra Care Homes. Since 2001, South Hams has had an increase of 16% of the population aged 65 and above and this number will grow. As we grow older and mobility decreases then homes may no longer be suited for needs and might require adaption. Disabilities in the younger and older can also affect mobility or require adaptions to assist living. DSV strongly believe therefore that a far greater range of housing types need to be provided as part of all major applications, including single storey dwellings and sheltered accommodation. The plan will therefore be required to state that all significant developments make provision for a changing population. This will need to be implemented through a specific policy requirement to build homes to Life time homes standards. The plan must also allocate land for Care and Extra Care Homes in all Towns and Villages in line with identified need. Design Standards. Space standards, ie, Parker Morris were abolished in 1980 and since then new homes have become smaller. The average home used to be 85sqm and is now 76sqm. The main reason why younger people with growing families want to move home is the lack of enough space for their possessions. However, paradoxically, the main reason for not buying newly constructed homes is the inadequate room sizes. Many show houses on new construction sites are pleasantly furnished but indicate little or no storage facilities. Secondary bedrooms for children in a growing family, lack space for study purposes. In recent years, house plans have shown little imagination and almost complete lack of flexibility for change. Options to extend recently constructed houses being extremely limited by width of plot size or internal configuration of halls and landings. The provision of car parking spaces in lieu off a garage exacerbates the problem further with no space for cycles or leisure apparatus. It is interesting to note that even when garages are provided, they are commonly used as additional storage space, with the car left on the drive. DSV strongly believe that the provision of higher standards of house design would undoubtedly provide for a better quality of life for our ever evolving family life. DSV is also seriously concerned with the existing minimum car parking standards for residential development. Although we are not in possession of information available in recently published supplementary planning documents, observation of medium to high density housing developments across rural Devon indicates a lack of off road parking. The landscape of rural villages is being destroyed by the excessive amount of on street parking of cars. A high quality of life will not be obtained unless it is recognised that in rural areas the motor car is an essential and not just a desirable commodity. DSV considers that the Planning Authority and the Devon Highway Authority should reconsider the existing standards with the view to increasing off street provision. Additionally, excessive on street parking creates a very dangerous environment for the older pedestrians living on the development.

OUR COMMUNITIES. The development strategy. The plan must vigorously address the need to achieve a more age-balanced structure in our communities. This needs to be emphasized in the emerging Local Plan and Neighbourhood Plans. The lack of awareness in some of the rural parishes and the consequences of an overtly aged profile to community wellbeing is frightening. The actual task of providing residential properties for younger people takes time to achieve and is fraught with difficulties. Role for Neighbourhood planning. DSV consider that Neighbourhood Plans can play a positive and critical role in the future of community planning in the South Hams. The Local Plan should encourage the communities of South Hams or cluster of communities to prepare Neighbourhood Plans. It is accepted that the Planning Authority will provide support to communities wishing to pursue the preparation of a Neighbourhood Plan even if their aspirations can be met though the preparation of the New Local Plan, and that considerable time and expense could be saved by this process. The proposed time table for the Local Plan may allow this to happen. However, it should be spelt out the considerable advantages that the local community can achieve and benefit from in the detail that can be included in a Neighbourhood Plan. They can through a local housing needs survey decide what type of residential development is fit for purpose for an ageing population and make positive steps towards its implementation. They can promote more development than is set out in the local plan and include design standards to accord with the local vernacular architecture. Also the promotion of social wellbeing policies which are specific to their local needs. If as pointed out, the aspirations of the community can be met through the New Local Plan, all well and good, but if more detail at a local level is required, then alternatives are available. These include updating or preparing a Parish Plan, Village Design Statement or Community Action Plan although they all suffer from the disadvantage of being non-statutory. DSV therefore recommends that information as to the options that are available to local communities are set out in the plan and also that a Neighbourhood Plan can come forward before an up to date Local Plan is in place. The plan can be developed before or at the same time as the local planning authority is producing its Local Plan. The neighbourhood plan must be in general conformity with the strategic core policies of the adopted development plan in force and is not tested against the policies in the emerging new Local Plan (NPPG). Defining “sustainable development.” DSV strongly support the provision and retention of services and facilities where feasible. The availability of local shops and post offices, are important ingredients of a sustainable community. This is of particular importance in an ageing population. Their closure can mean increased inconvenience for local people and create hardship. DSV has strongly lobbied government and local authorities to retain post offices, village shops and halls, libraries and where feasible, local schools. Many of these capital assets of local and parish authorities provide existing and future opportunities for social and health facilities such as dementia cafes etc. The inclusion in the plan of a “Policy for the Provision and Retention of Local Services, is strongly recommended. DSV are advising all Planning Authorities and Parish Councils of the need for this policy in all emerging planning documents in order to increase “awareness” of the necessity to “resist the loss of a facility that represents the only one of its kind in the settlement it serves”

OUR WELLBEING. Transport. The plan must recognise that people in rural communities must have access to essential services in order to retain quality of life and sustainable living. DSV would draw your attention to the County Council report which states that “Securing appropriate modes of transport is decisive when accessing health services in rural areas (Devon CC Rural Access to Health Task Group, March 2010) Community Hospitals. DSV concur with the recent comment of the newly appointed CEO of NHS that the retention and additional provision of community hospitals in that “research on Community hospitals suggests that better value for money can be achieved rather than the main regional hospitals, for certain types of care. The problem arises in some instances that there is insufficient land available in the right location. It is therefore important that the Planning Authority in consultation with NHS regularly monitors the position in order to access the need for possible future development, and land allocatons are reserved in the Local Plan and in future Plan Reviews.

CONCLUSION. Devon Senior Council would wish to continue to assist the South Hams authority in any way possible in order to achieve a successful Local Plan , and look forward to further consultation on the emerging plan in November 2014.

Yours faithfully,

Chairman, Devon Senior Voice,

Copies to:- Graham Rogers, RIBA; FRTPI(retd), DSV Planning and Housing Representative; Healthwatch; Association of Town and Parish Councils; Rural Housing Partnership, Community Council for Devon.

From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Stuart Watts (where relevant) Job Title: Chairman (where relevant) Organisation: Bigbury Parish Council Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Bigbury Parish Council is acutely aware that the initial ‘Our Plan’ consultation document says nothing about the widespread problem of second homes/ vacant homes affecting many parts of the South Hams. We have recently lost a pub (Royal Oak), garage (in Bigbury Village) and post office (Bigbury-on-Sea) partly, at least, as a result of the lack of year- round customers. We are not sure how accurate the SHDC data are for Comments: second home ownership since the disappearance of the council tax differential rates but to build any strategy obviously needs accurate data and the number of homes claiming business tax relief is not an adequate measure. The strategy needs to address the problem of ‘ghost’ communities. The reciprocal of this is that in summer, the local infrastructure of roads, sewerage, etc. cannot cope with the huge influx of people. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Striking the right balance between the needs of 'people' and their living Comments: environment ('place') is a key challenge. The AONB designation should carry greater weight in planning considerations. Is there anything else you think Our Plan should contain?

1 Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). The presentation of 'Our Plan' is so anodyne and lacking in hard facts and Comments: figures as to be almost worthless as a consultation document. Whether it will engender any valuable responses remains to be seen. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Richard Hosking (where relevant) Job Title: Chartered Surveyor, Devon County Councillor (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). The general topics are correct, however I would change the emphasis in Comments: some areas, for example an economic strategy in addition to an employment strategy. Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). We should look at the age and second home profile of the communities and Comments: redress imbalance Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). The geographic designation of AONBs and the powers to protect them need Comments: bolstering Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Council tax on second homes Housing number imposition relative to employment Consideration of areas to east in SHMNA and examination of inward and Comments: outward employment migration. Management of imbalance of second homes in coastal communities. Restoration of Planning decisions to District level with greater public 1 consultation - Neighbourhood Planning is too close to the community and puts too much emphasis on voluntary contribution. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Reg 18

Our Ref.: C/5877

Our Plan Scoping

Thank you for your email of 9 May consulting The Theatres Trust on the scoping stage for the new Local Plan. We note that this document is identical to that of West Devon BC and that the email address is for swdevon.gov.uk. We are puzzled as to whether this is a joint effort or not, as there is no mention in the documents regarding South West Devon. Our response will be the same to West Devon.

Please note we have not used the online response form because it wouldn’t accept our telephone number – said it was an invalid entry. The system probably only accepts local numbers.

The Theatres Trust is The National Advisory Public Body for Theatres, and was established by The Theatres Trust Act 1976 to ‘promote the better protection of theatres’. The Trust delivers statutory planning advice on theatre buildings and theatre use in England through The Town and Country Planning (Development Management Procedure) (England) Order 2010 (DMPO) requires the Trust to be consulted on planning applications which include ‘development involving any land on which there is a theatre.’

Our Communities With regard to community infrastructure, we suggest that for development to be sustainable, the document should first protect and enhance existing before building new. We would usually advise a general district/borough-wide policy for this purpose to reflect item 70 in the National Planning Policy Framework (NPPF) on page 17 which states that to deliver the social, recreational and cultural facilities and services that the community needs, planning policies and decisions should plan for the use of shared space and guard against unnecessary loss of valued facilities. Also to ensure that established facilities and services are retained and able to develop for the benefit of the community.

Item 156 of the NPPF states that local planning authorities should set out their priorities for the area in the Local Plan which should include strategic policies to deliver the provision of health, security, community and cultural infrastructure, and other local facilities.

Our Wellbeing The updated Planning Practice Guidance (March 2014) recommends that a range of issues could be considered through the plan-making and decision-making processes including social and cultural wellbeing. This takes this aspiration further than just access to doctors and playing fields. However, as neither the NPPF nor the PPG explain what they mean by the term ‘well-being’, we suggest that ‘well-being’ is having a sense of satisfaction with life. Social and cultural well-being includes the un- measurable personal experiences that make us happy and content. Such experiences are intangible, not financially rewarding, and can either be active (sports) or passive (theatre). The provision of a variety of community infrastructure for tourism (cultural heritage) and town centre vitality (cultural facilities) etc are vital for their contribution to residents’ and visitors’ life satisfaction.

Rose Freeman Planning Policy Officer The Theatres Trust 22 Charing Cross Road London WC2H 0QL

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2 From: Strategic Planning Subject: FW: Our Plan Response SH

Our Plan Response SH

Your details Name: Simon Rake (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). (I presume you are refering to page 6 rather than page 4) Whilst I have no particular argument with the different coloured boxes and their content I am worried that this "silo" approach to the topics will be mirrored in the plan and thence in policy and practice. It seems far more important to identify the links and relationships between the items in different boxes and to incorporate the need and mechanism for making and responding to these links. Comments: Even more importantly I believe that there should be a cloud above all these boxes called Inspiration, Innovation and Imagination putting these at the heart of the plan and establishing the possibility of the council daring to do things differently as a key part of its future. The alternative of working to the narrowly defined silos on page 6 runs the risk of the council becoming hidebound by its own plan, and framing future policy based largely on what has been done in the past. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). (I presume you are refering to the page nubmered 12 rather than 7) Again I think that encouraging innovation, imagination and insipiration is an essential element, not just in housing where this gets a passing mention, but in lifestyles, community engagement, employment, and many other areas. Comments: As with my comments on the "topics" I believe that there is a danger that the box will overcome the links between boxes, which are often more important. Understanding and shaping the relationship (say) between "responding positively to climate change" and "encouraging community planning and ownership" seems far more important than identifying either of these challenges on their own. 1 Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: See above comments on Topics and on People Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). I think that the council should plan to innovate, imagine and inspire. It should plan to take risks in doing so. It should set out how it will do Comments: this and should make community involvement in this process the first example of innovation, imagination and inspiration in practice. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 Our Plan

My first impression of the consultation document was one of confusion, as it seems that much of the content had been included on a haphazard basis. It is not a document which will inspire input from the public, whether individuals or community groups. Some of the terms used, such as ‘green infrastructure’ are meaningless to those not familiar with planning language. It is not clear that many of the items included are not within the remit of SHDC, but are dictated by government policy and also rely on close co-operation with partners, whether government and their agencies, local authorities or non statutory organisations. While many of the items included are admirable aspirations, they will remain just that unless a realistic, co-operative approach and attitude is taken to make the best use of limited resources. The voluntary sector, on which much of the implementation will fall, must be involved at the beginning of this process. What has been the role of the Connect Strategy, if any, in informing this document? It may well be that this document ha s been deliberately designed to provoke comment, so if this is the case, it has worked for me.

I do not consider the categories on p. 6-7 have been adequately considered. There is overlap and duplication. The decision to use ‘Our’ is limiting, but if it must be used ‘Our Partners’ would be a useful addition.

Our Vision This needs further definition. The assumption that ‘growth’ is what we all want is not one I support, though I acknowledge growth in some areas, such as low cost housing, can dependent on economic factors.

Our Homes To what extent do we cater for inward migration, as a third of new houses are sold to people from outside the Southwest? This skews the market, and lessens the ability to provide for existing needs. Homelessness, increased evictions in the private rented sector, empty homes, sheltered/supported housing, insecure tenancies, second homes, all need to be included.

Our Economy With agriculture and food production a significant and growing aspect, why has this been omitted?

Our Resources Much of what has been included is energy related, and other items, such as flood risk, climate change and sustainable construction are not what most people would include in this category. Water has been omitted, but what about considering the wider context? People, countryside, coast and rivers, our locally benign climate, good agricultural land, must be included. The need to protect land and encourage local and sustainable food related businesses is essential and will contribute to food security. Community renewable energy should be promoted not only to benefit communities, but also to aid energy security.

Our Wellbeing Equality and diversity should be included, as should fuel poverty and other impacts of welfare changes. The role volunteering can have is significant to wellbeing.

Our Communities A comprehensive Land Use Strategy, rather than a development strategy, would create far more opportunities and make better use of existing resources, whether town centres, brown or green field land. Rural isolation is a significant challenge. Volunteering should be included, as should support for local enterprises, community groups, Community Interest Companies. There should be a greater emphasis on preventing the loss of community infrastructure, such as day care centres, youth centres, libraries, etc. which merely pass the problem onto other agencies. Community hubs, maybe in existing libraries, or other community buildings, could be used to inform, engage and encourage community empowerment. As ‘sustainable development’ has been defined in the NPPF, why is this included? Most of us have our own ideas of what it means but have no choice to accept planning decisions based on an often narrow and subjective interpretation. There was considerable input into Sustainability Appraisals and Assessments by the public for the DPD Site Allocations procedure, and it was largely ignored.

Our Nature If Green Infrastructure is included, so must Blue Infrastructure. Of course trees and hedges are important, by why single these out?

Our Heritage Should include cultural heritage and designated landscape.

The People and Place information on p. 12 -13 have inevitable overlap, and would benefit from further clarification.

People Attracting and involving young people and families, rather than retaining, would be more appropriate. Accessible housing, and secure, not minimum wage employment, is key. Training, education, and continuous learning, as well as attracting a range of jobs (the emphasis should be on quality jobs). Include encouraging and enabling micro commissioning, particularly sustainable enterprises. Enabling waste reduction? Encouraging behaviour change to ensure the Waste Hierarchy is implemented would be more appropriate. The planning system can ensure facilities are included in new development, both for housing and employment. Supporting an increasing older population – add vulnerable groups, and carers. The housing related items should be in the Place section. This section must include effective means of communication. Much more information must be available to the public, both online, and by other means, to ensure greater understanding of, and engagement with the work of the Council. The recent decision to decrease the number of Councillors will have a negative impact on the democratic process leading to less, rather than more, understanding of the challenges faced, and the means to resolve them.

Place

Community transport and sustainable travel have not been included. Local commissioning of a range of services, rather than a reliance on big business, would have significant impact, not only on ‘Place’, but also on ‘People’. New technologies – access must be reliable and universal. Encouraging sustainable construction methods – as existing policies are not even implemented this is meaningless. The same applies to renewable energy and other areas. The role neighbourhood planning could play in achieving many of the aspirations referred to in this section is huge, but it is not even mentioned. It is odd that tourism, which plays such a significant role in the District, is not mentioned. Rather than use the term ‘affordable housing’, which is defined as up to 80% of market rates, so is not actually affordable, the term ‘low cost’ should be used. Rather than rely on the big developers to construct the majority of housing, much of which is of poor design and unsustainable materials, encouraging and enabling self and custom build, particularly on a not for profit basis, would have significant impact on meeting local need and many additional benefits.

Conclusion

The proposed timetable is not only over ambitious, but relies on input in July and August, when a large section of the community is otherwise engaged. Many members of the public and community groups spend a significant amount of time responding to consultations, then find their input largely ignored, with watered down policies not implemented. The challenges we all face are well documented, as are the dwindling resources to deal with them. Reliable means of making the best use of resources must be explored and implemented, with communities, and the people within them being among the most important, as these have to live with the results. The Council, by providing greater encouragement at a much earlier stage, could have seen many more communities undertaking neighbourhood planning, which would have empowered them not only to deal with matters relating to land use, but also to explore other areas.

Helen Kummer

19.6.2014

From: Strategic Planning Subject: Our Plan Consultation - South Hams

Please find below our comments in respect of this preliminary consultation:

The consultation document identifies that “Building a mix of housing to meet market and local needs” is a key challenge to be addressed by the plan. It is not clear why this phrase has been chosen/used as local and market needs for housing are not independent (as suggested by this phrase).

It is essential that, as part of facilitating the national ‘presumption in favour of sustainable development’, the new Local Plan addresses the national policy requirement to boost significantly the supply of housing, by using evidence to ensure that the plan meets “the full, objectively assessed needs for market and affordable housing in the housing market area”.

This policy requirement distinguishes between market and affordable housing only (rather than market and local housing) – market housing will be required to meet local needs.

It will be critical that the Council effectively engage in the Duty to Co-operate with neighbouring Local Planning Authorities to define the relevant Housing Market Area(s), and the objectively assessed need for housing. In the first instance the Council should be seeking to meet the objectively assessed need for housing in full. The delivery of housing is inextricably linked to the economic and employment strategy for the local area, and successful local economic growth is reliant on an effective strategy for housing delivery.

Rather than ‘Market and Local needs’ (which we consider does not reflect either national policy, or an appropriate aspiration for housing in the plan area) the new plan should be very clear about its headline aspiration/strategy for housing (which to accord with national policy should be to meet in full the objectively assessed needs in the area).

A fundamental part of the new plan will be identifying and planning for the objectively assessed housing need in the area, and making provision for the delivery of this through the identification of sufficient suitable sites (and general areas) for development, and co-ordinating (planning) this with the other aspects identified throughout the consultation document (such as the economy, infrastructure and environment).

We look forward to reviewing further evidence and draft policies when available and contributing further to the new Local Plan for South Hams.

Regards Andy Ross

On behalf of Turley

Andrew Ross Associate Director

turley.co.uk

Think of the environment, please do not print unnecessarily This e-mail is intended for the above named only, is strictly confidential and may also be legally privileged. If you are not the intended recipient please do not read, print, re-transmit, store or act in reliance on it or any attachments. Instead, please notify the sender and then immediately and permanently delete it. Turley is a trading name of Turley Associates Ltd, registered in England and Wales Registered No 2235387 Registered Office 1 New York Street, Manchester, M1 4HD.

1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Peter Rees (where relevant) Job Title: Co Chair (where relevant) Organisation: Totnes and District Traffic Forum Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Environmental Capacity Study:

The list of Topics covered should be extended to include the above; to consider specifically the ability of the existing infrastructures to cope with various levels of development, including taking account of that development already proposed by adjoining authorities; and to consider the extent of provision that might be required.

This topic should include an investigation of the practicality and consequences of a "minimal" response and include an assessment of; the costs, practicality and environmental consequence of providing what might be judged an adequate and sustainable level of infrastructure provision to Comments: cater for such development.

Failure to include such assessment will impose costs or have otherwise unforseen consequences and costs disproportionate to any benefits that might be gained from whatever development might be proposed.

We offer by way of example, the capacity limitations of the A385 corridor through Totnes (currently one of the three most congested routes in Devon); the well documented inability of Devon to improve capacity, other than by building a major by-pass of the Town; the strategic importance of this corridor to both South Hams and Torbay and the consequences for both authorities of further congestion and delay if the problem cannot be adequately addressed. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). 1 The Challenges faced are implicit in the above and include the problems of Comments: catering for public transport on an already congested road network and the environmental and social consequences of failing to do so. Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: As above Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: See the contribution from one of our members Helen Kummer Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: "Our Plan" - Initial Consultation

For: Strategic Planning South Hams District Council Follaton House Plymouth Road Totnes Devon TQ9 5NE Local Plan Consultation:

The Forum has asked me to draw your attention to the need for the Local Plan to take into account the limitations of the existing highway infrastructure in and around Totnes and the likely costs, environmental, social and financial, of dealing with such limitations. We ask that the list of Plan Topics include a study of the existing network and infrastructure limitations, the likely consequences of such limitations, for; visitors, the economy, the highway authority, the residents of South Hams, for our neighbors in Torbay and for the future of the infrastructure . A suitable title for this topic might be a study of “Environmental Capacity”.

Peter Rees Co-Chair Totnes and District Traffic & Transport Forum advisory body to TOTNES TOWN COUNCIL and a working group of TRANSITION TOWN TOTNES

1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Anthony Cosgrave (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). "Our Assets" - broadly covering what makes South Hams a desirable place to live - needs to be a separate Topic. These assets draw people to visit, to have a holiday, even to have a second home here. But this 'tourism' - temporary (or semi-permanent for second-home owners) - comes at a cost for those already living here, whereby the assets which exert this fundamental appeal are degraded, sometimes permanently, and other costs are imposed. Foisting traffic congestion, noise and fumes on residents is not fair. Neither is requiring that their water bills pay for the outcome of others' visits or the cleaning up of beaches residents can't easily get to. And the asset of having Cornwall as a neighbour generates even more traffic on road and rail. Nimbyism and its unwillingness to share is unattractive; Comments: but so is the attitude of the wealthy and powerful which identifies assets and exploits or appropriates them regardless, failing also to share. It is surely not beyond human wit to aim for a way which is neither of these, a middle way. That is what "Our Assets" needs to do. We cannot proceed effectively while ignoring the elephants in the room - both resident and visiting. They need telling that the attitude, "I can do what I like with my money if there's no law against it" is not acceptable if they wish to be involved with South Hams. "Our Assets" need to be identified and preserved so that they can be equitably shared now and by the generations of children and grandchildren who will be involved with South Hams in the future. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). "Improving people's experience of lives governed by justice, ethics and Comments: equity" needs to be a separate Topic. The nearest this document gets to it is the single word "wellbeing", which, on its own, fails to communicate 1 anything of its foundational need for 'justice'. People leading lives blighted by injustice, unethical activity and rampant unfairness are subject to corrosive resentment. And no amount of cycle paths, fresh air, mindfulness or Pilates can undo its damage and enable a true breakthrough into "wellbeing". Worth pointing out, also, is that other topics than "wellbeing" that would benefit from a proper commitment to "improving people's experience of lives governed by justice, ethics and equity". The three 'challenges' relating to housing already have conflicting interests underlying them, and that is without throwing into that mix the retention of young people and families. We do need a clear undertaking by 'Our Plan' to solving the problems raised by this multiplicity of 'People' challenges through applying the practice of justice rather than the procedures of expediency. All should be winners according to fairness. We must not have a situation where there are in fact losers - especially not those with least resources and most to lose - and who everybody knows are losers, yet whom the authorities, in connivance with the winners, tries to persuade that they are really winners too! Even worse would be trying to convince the losers of the next generations that they are in fact winners. Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). "Using justice, ethics and equity as foundational principles in meeting challenges" must figure here (as above) as an explicit undertaking. Otherwise "Maintaining services with less public spending" is not going to be possible, particularly if the 'less public spending' is taken as a given and not put to people's agreement. Some may in fairness wish to pay more in taxes if they can be sure of the fairness and transparency of those to whom they are committing their money. Likewise "Maintaining and enhancing infrastructure (e.g.Schools, roads, healthcare etc." needs confidence that these same fairness principles are being applied to solve the conflict of responding to this challenge and yet meeting the interests of visitors, and housing (see previous comments). "Recognising and promoting what makes the area special" needs great fairness and transparency in discernment and action. People will be wise to realise that what is 'special' for some might be 'notorious' for others. Transparency and fairness also need to be applied in "Enabling more Comments: affordable housing options". It is becoming increasingly known that 'affordable' is "1984"speak for 'not so expensive as top whack, but out of the reach of almost anybody living here', and calling affordable what is clearly not affordable discredits those who use the term in this way. No amount of "that's how it's defined in the regulations" will wash. And it adds insult to injury if developments which were permitted on the basis of a certain proportion of dwellings to be 'affordable' even on this ridiculous definition, turn out not to have respected even that very limited constraint on profit-making, and to have built fewer ...and got away with it. People are not fools and their wellbeing will be further diminished by witnessing such behaviour (see above). Lastly, though by no means the last that could be mentioned, "Improving transport links" will clearly need the 'transparent fairness' treatment. Links for whom? In all areas or just some? Will the clogging effect of unrestricted car use be tackled? Will the old and increasingly frail be given special privileges? Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Whether it is included in the individual 'People' and 'Places' sections (see above with the wording I have suggested) or as a separate all- encompassing undertaking here, there must be an explicit commitment to Comments: 'justice, ethics and equity' as guiding principles in all the Council's deliberations. That, however, is the easy bit. Well, not easy for anyone needing persuading of the overriding importance of justice, etc., but

2 nonetheless, in terms of a public statement, brief and simple to publish. The difficult bit is letting people know what this might mean in practice, as that involves working through how these principles are to be applied in responding to the challenges outlined by 'Our Plan': 14 for 'People' and 15 for 'Place', plus two more if my suggestions are adopted. Not all the challenges are in competition, some can be met in conjunction with others, but there are cases where a clear ethical 'steer' is required: We consider x to have priority over y (except where z comes into play)...and [MOST IMPORTANT, THIS!] these are our reasons why. Such a task is not easy - politics never was - but the debate that will ensue, within the Council and without, will deliver positive outcomes if all involved are committed to being guided by justice, ethics, and equity in their deliberations, and - for decision-makers - in their final decisions. And lastly, there must always be a spokesperson for the next generations. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

3 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Frances Pasfield (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Tim Padfield (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: t Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). The balance of population growth and services between towns and villages should be an item. The towns should be expanded and have good public services for sport and recreation and education. This will never be Comments: provided by small villages. Villages should be regarded as romantic relics, with development concentrated on Totnes, Dartmouth and Kingsbridge. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Encouraging social cohesion and caring is missing, in favour of 'increasing self reliance'. The other items are just conventional piety that anyone can nod agreement with.

Comments: Whatever climate change is in prospect, it will be gradual and I doubt there is much planning you can do. Sustainable energy is worth doing for energy independence and pollution abatement alone - no need to invoke climate change. Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). You assume less public funding. Why? This plan is for years ahead. Do you accept a nation in perpetual decline into poverty? I suggest: increase Comments: public funding for public benefit. Don't be so servile to an ideologically driven government which may not last.

1 Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). It should explicitly aim to increase public access to open land, particularly woodland and wild places. There is no right-to-roam anywhere in the South Hams - only the national trust and the woodland trust provide wild public areas. The footpath network is sparse in many areas. There Comments: should be a powerful initiative to give access to nature, by agreement, or by purchase. There should also be a strong emphasis on safe cycling with off-road paths to take cyclists off the main roads. I know this is mainly a county matter but south hams can keep up the pressure. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Katie Reville (where relevant) Job Title: Town Councillor in Ivybridge but responding as an individual (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Your key topics look like a bunch of phrases simply thrown at a document and do not make much sense in some instances. 'Our Resources' should cover: land, water, people, renewable energy, waste not be a load of guff about energy and flood risk (how is flood risk a resource??).

You should have a box called Our Partners as you cannot deliver everything Comments: on your own and in an age of dwindling budgets and the need for greater partnership working and delivering services differently you should at least refer to DCC, the health sector, education, police etc.

'Our wellbeing' should include poverty as a topic or at least fuel poverty and perhaps make reference to education and continued learning/skills development. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). I am not sure why you have so many references to building housing under your people heading and I would love to know how you plan to respond positively to climate change?

The key challenges related to local residents should include references to building vibrant communities in which people participate in local decision Comments: making, volunteer within their community and participate in groups and community events.

You mention self reliance and resilience quite a bit but it would be simpler to say 'encourage and enable sustainable behaviour' as this is what is needed in order for communities to become more self reliant (e.g. 1 for food, energy, care of the elderly and sick) and resilient to changes to our climate and economy.

Although you refer to improving access to services I think it is also appropriate to refer to 'keeping the population mobile' i.e. sustainable transport options. We still really need to encourage and enable people to walk and cycle more and ensure we have good bus, train services and community transport services. Locally run ring and ride schemes are lifesavers in some small communities and they need greater recognition for what they do in helping people to access services and saving statutory agencies lots of money.

I would argue that you do not wish to 'retain young people and families' but 'enable young people and families to live and work in the area'.

please remove 'enabling waste reduction' as a people challenge as that doesn't make sense. Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). I think you need to refer to tourism and agriculture specifically as these are two of our main industries that we need to support.

You should mention Sherford as a challenge to south hams communities as Comments: who know what impact it will have on housing need, employment etc.

Again, you should mention community transport and sustainable transport modes as opposed to improve transport links. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). a list of all the other plans that are being developed across the area by Comments: the CCGs etc so we can see that you have all talked to each other, know what each other is doing and are looking to actually work together more. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Geoffrey Osborn (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Broadly, you have most of the right topics; but the key isuses should be highlighted as :

Comments: Social housing; Renewable energy; Protecting landscapes; Especially the AONB. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). YOUR DOCUMENT ONLY GOES UP TO PAGE 6!

Re housing: adopt low initial targets for total housing as they can be Comments: raised later if the need arises; there are already too many housing allocations in the present local plan. Social housing should be at least 25 %/ Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). AGAIN, YOUR DOCUMENT ONLY GOES UP TO PAGE 6.

Renewable energy is ok in principle, but it must respect the landscape. do Comments: not allow the spread of solar arrays over agricultural land - enough is enough. Favour panels on roofs.

1 Wind turbines should be in scale with the properties they serve and they must not be allowed to dominate the landscape from miles around. Respect heritage buildings. Set separation distances from house. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Your topics and policies are very weak in the protection of the AONB. Government advice is to give them the same level of protection as national parks. SHDC is failing to do this. There is too heavy a bias towards the Comments: farming community. Local employment and enterprise is vital, but landscape must come first. Disrespect for the AONB damages tourism, the most vital income stream for the South Hams. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

South Hams Local Plan

Our Plan: Shaping our communities to 2031- Consultation Document

Representations on behalf of The Dartington Hall Trust

June 2014

WYG PLANNING & ENVIRONMENT Hawkridge House, Chelston Business Park, Wellington, Somerset, TA21 8YA Tel: The Dartington Hall Trust

1.0 Introduction

1.1 These representations are submitted on behalf of The Dartington Hall Trust (DHT).

1.2 Based at Dartington Hall in Dartington, Totnes DHT is a charity which has the vision ‘ to play our part in building more resilient and creative communities as a force for positive social change’ . Dartington wants to work in partnership with others to build on its contribution in three core areas:

• Food & Farming – exploring new ways to feed ourselves sustainably

• Jobs & Homes – helping to create sustainable jobs and better places to live

• Enriching Lives – supporting the arts and encouraging well-being.

1.3 Through the work and projects it undertakes DHT has three characteristics which run to the very heart of everything it seeks to do:

• Learning – helping others to lean, and evaluating and learning from what we do

• Inclusion – engaging all parts of the community

• Place – being a place of inspiration and beauty.

1.4 Dartington today occupies an exciting position, both as an important part of its own local community (community of place) and within a national and international community of thinkers, activists and artists who share our concerns (communities of interest). In the future, Dartington wants to bring together these communities of place and interest to harness the potential it has as a place to stimulate new thinking and drive practical change.

1.5 DHT is a significant land owner within the South Hams District and uses its commercial enterprises to generate funds which are then reinvested in the charity work it undertakes. Again these fall into main three areas:

• The Shops at Dartington

• Property & Lettings

• Dartington Hall (Conference Centre)

The Dartington Hall Trust

1.6 DHT’s off-site activities including its property and land portfolio help it fund on-site educational related activities and support the management and maintenance of the on-site heritage assets. The overarching strategy for DHT is well aligned to the themes as set out on pages 6 & 7 of the consultation document. DHT welcomes the opportunity to be involved in the consultation process and given the role and function it plays within the local community considers its involvement in every stage of the Plan process vital.

The Dartington Hall Trust

2.0 National Planning Policy Context Framework

National Planning Policy Framework 2.1 Although we appreciate that this is the initial consultation on the new Local Plan, it is important at the outset to be mindful of the requirement for any future Local Plan document to be sound (i.e. positively prepared, justified, effective and consistent with national policy) as required by Paragraph 182 of the National Planning Policy Framework (the Framework)).

2.2 It is imperative that the emerging Local Plan takes full account of the advice set out within the Framework. At the heart of the Framework is a presumption in favour of sustainable development , which should be seen as a golden thread running through both plan-making and decision taking. For plan-making this means:

• Local planning authorities should positively seek opportunities to meet the development needs of their area;

• Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change.

2.3 Local Plans should proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities.

2.4 The Framework advises that a local planning authority should submit a plan for examination which it considers is “sound” – namely that it is:

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; • Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

The Dartington Hall Trust

• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and • Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2.5 The Framework advises that local plans should include strategic policies to deliver the homes and jobs needed in the area; the provision of retail, leisure and other commercial development. They should also indicate broad locations for strategic development on a key diagram and land-use designations on a proposals map; allocate sites to promote development and flexible use of land, bringing forward new land where necessary, and provide detail on form, scale, access and quantum of development where appropriate.

2.6 "To boost significantly the supply of housing ", the Framework advises that local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the policies set out in this Framework, including identifying key sites which are critical to the delivery of the housing strategy over the plan period.

2.7 The Framework highlights that the planning system has an important function in helping to facilitate social interaction and the creation of healthy, inclusive communities. As a result there is a requirement for local planning authorities to involve all sections of the community in the development of their Local Plans.

2.8 In relation to the historic environment Local Plans should seek to identify a positive strategy for the conservation and enjoyment of the historic environment. It further advises that local planning authorities should take into account the “ desirability of sustaining and enhancing the significance of heritage assets and putting them to a viable uses consistent with their conservation” .

National Planning Practice Guidance

2.9 Furthermore the recently published Planning Practice Guidance contains three fundamental points in respect of calculating objectively assessed housing needs:

1) Use DCLG projections as a starting point only as they do not take account of suppressed demand created by historical undersupply and worsening affordability.

The Dartington Hall Trust

2) Ensure that growth in the working age population matches projected job growth over the plan period. 3) Consideration should be given to increasing the supply where market signals (land prices, house prices, affordability index, etc) indicate it appropriate.

2.10 DHT considers that although the Council is still at an early stage in terms of plan preparation it should pay particular regard to the previous failings on a number of the above identified issues of many of other Councils across the south west.

The Dartington Hall Trust

3.0 Overarching Themes

3.1 DHT considers that the ‘big challenges’ identified on pages 10 and 11 of the consultation document are broadly the headline issues/drivers. It will be crucial for the plan’s success to meet as many of these challenges head on.

3.2 Whilst these challenges are not unique to the South Hams District, as many of the issues raised are fairly typical of many of the district authorities across the south west, it is important that South Hams District approaches these challenges in a proactive and creative manner.

3.3 Like all stakeholders in the Local Plan process DHT wishes to work with the Council so as to ensure that its objectives for the Local Plan process are achieved. For DHT, these essentially fall into two areas:

1. On Estate - Bespoke special policy treatment that supports DHT’s objectives (as identified in Section 1 of this response) including its commercial on-estate activities. This would seek to update a previous, outdated policy.

2. Off Estate – Allocation of land for development in order to allow DHT to use the capital receipts to support DHT’s ability to support and pro-actively develop local communities and achieve its wider objectives.

3.4 Beyond these wider objectives DHT has a series of detailed considerations which it wishes the Council to consider.

Heritage

3.5 DHT is responsible for a significant number of important designated and undesignated heritage assets, many of which are to be found on the Estate itself, most notably Dartington Hall, Aller Park, Foxhole and the Old Postern to name but just a few.

3.6 The maintenance and long term protection of such assets does not come without significant financial implications for DHT. Whilst their protection is of the utmost for DHT, the most beneficial way of protecting such assets is through ensuring that they have an active and sustainable use.

3.7 Whilst any new use will have to be assessed against the particular significance of the heritage asset, including its setting, DHT is keen to explore appropriate policy treatment for its on-site aspirations and

The Dartington Hall Trust

assets as the Council develops its Local Plan and would welcome further specific dialogue with the Council on this issue.

Housing

3.8 Whilst the overall quantum of housing growth required for the District will be determined as a result of further evidential technical work (e.g. completion of the Strategic Housing Market Assessment (SHMA)), DHT considers that South Hams must give careful consideration as to how they will deliver the overall requirement so as to ensure that the overall mix across the key settlements within the District, including at Dartington, is appropriate to the role and function that the settlement plays. This is particularly important where there are opportunities for increased levels of growth when compared to the overall trend of the last plan period.

3.9 DHT considers that South Hams should give careful consideration to housing delivery and seek to ensure that the Plan is clear on where development is going to be considered acceptable, even if it does not allocate specific sites.

3.10 In particular, Totnes itself is very limited in terms of strategic employment or housing sites. It is likely therefore that a series of smaller sites will need to be allocated across a wider number of smaller settlements i.e. villages such as Dartington.

3.11 If this is the case it will be important for a clear and joined up masterplan to be required to help ensure a consistent form of development quality is achieved, an example of this would be for the NW quadrant of Totnes which DHT has discussed previously with the Council.

3.12 Whilst the provision of sufficient levels of market housing is one important issue, DHT also considers that the levels of affordable housing provision should also be appropriately assessed and provided for. DHT is committed to helping to shape balanced communities which allow for all members of society to benefit from healthy, sustainable and fulfilled lives.

3.13 DHT considers that South Hams can learn valuable lessons from the previous failings of other Local Planning Authorities, as recent Local Plan examinations have highlighted the fundamental importance of demonstrating a robust position in relation to the overall housing requirement and its delivery. We consider that getting the appropriate evidence base in place quickly will be especially important for the Council, if its intent of having a new plan adopted by the middle of 2015 is to be achieved.

The Dartington Hall Trust

Employment

3.14 Local Plans have typically allocated employment sites on the basis of an overall quantum of land i.e. x ha. DHT are of the view that a mere allocation in itself does not guarantee that the market will ever deliver on those committed sites especially where allocated sites are not commercially viable.

3.15 DHT would note that the use of a hectare aspiration rather than a more sensible evidenced based assessment of required floorspace is not helpful to any stakeholder involved. At present the delivery of commercial floorspace is effectively provided at nil development value by the developer. As a result careful consideration should be given to applying in effect a cross subsidy from market housing if sufficient and worthwhile commercial floorspace is to be delivered.

Communities & inclusion

3.16 One of DHT’s core areas is focussed on social inclusion and the enrichment of learning experiences. With this in mind DHT would welcome an open dialogue with the Council as to how DHT can be of assistance in delivering, via its property and land portfolio, appropriate facilities for some of the more hard to reach communities.

3.17 Dartington is embarking on a new strategic journey. Ninety years after it was founded, as a unique experiment into the enrichment of human society and the development of more sustainable economic models, DHT is focussing on communities. In taking forward its tradition of stimulating social change, Dartington will focus on the ways in which communities function most effectively to enable all of their members to lead healthy, sustainable and fulfilled lives. DHT would welcome a dialogue with the Council as to how can assist the Council in this regard.

3.18 DHT is supportive and would like to engage with the Council particularly in relation to improvement of the health and well-being of communities and how hard to reach sections of the community can be supported.

From: Strategic Planning Subject: South Hams District Council - Our Plan Consultation

Dear Strategic Planning

As discussed on the phone this morning.

It isn’t clear to me, acting on behalf of the Diocese of Exeter, how best to engage with the Consultation in the terms in which it is set out. As our track record concerning Sherford hopefully attests, unless we have land holdings of our own in a particular area (and are therefore behaving more as a landowner or potential developer), the Diocese would not want to adopt a particular viewpoint on the basic strategy that is to be pursued or the location or quantum of development.

However, once the overall objectives have started to come into focus and the scoping process has started concerning the nature, location and timing of larger scale development areas, we are eager to engage at as early a stage as possible with any specific ideas and proposals so that we can take a view on their potential impact on our future delivery of services. Whether that engagement takes place in the context of a service users group (or similar), or whether by some other means, probably isn’t that important. We’d be willing to work within whichever mechanism you think most appropriate.

I hope that this is helpful and if you have any comments or questions, please don’t hesitate to let me know.

With best wishes

Ed Moffatt Assistant Diocesan Secretary Diocese of Exeter

www.exeter.anglican.org

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CONFIDENTIALITY NOTICE : This message is intended for the addressee(s) and may contain confidential information. If you are not the intended recipient, we would be grateful if you would notify the sender and delete the message. Any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the Diocese of Exeter. The Exeter Diocesan Board of Finance Limited is a company limited by guarantee and is registered in England (No. 186001) and a charity (No. 249798). Registered office: The Old Deanery, The Cloisters, Exeter, Devon EX1 1HS

1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Hilary Winter (where relevant) Job Title: Forum Officer (where relevant) Devon Countryside Access Forum (DCAF). The DCAF is a statutory local access forum Organisation: under the Countryside and Rights of Way Act 2000. Members represent land managers, access users and other interests. Aim to improve recreation and enjoyment Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). The Devon Countryside Access Forum advises that the topic 'Our Economy' should include some reference to supporting agriculture and land-based Comments: businesses. There is a strong and integral linkage between this use of land and some of the other topics such as landscape, green infrastructure, trees and hedges highlighted under 'Our Nature'. Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). The Devon Countryside Access Forum advises that the reference to Comments: 'improving transport links' should incorporate 'and encourage greater use of sustainable transport.' Is there anything else you think Our Plan should contain? Additional No If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Comments: 1 Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: South Hams - Our Plan: Shaping Our Communities to 2031

Dear Sir/Madam,

I refer to your current consultation on the above Plan which sets out the needs and aspirations of the area to 2031.

In general Imerys is supportive of the key challenges and objectives as described in the consultation document.

Imerys' property, situated, at Lee Moor offers significant opportunities to deliver projects which could work towards contributing, to the District's challenges.

Following internal reorganisation a significant proportion of Imerys land holding at Lee Moor is now non-operational land and is going through a decommissioning programme. The company's China Clay Calciner has seen significant investment in recent years and continues to produce nationally and internationally important industrial mineral products. Restoration of part of the mineral workings are also ongoing employing new soil improvement techniques to accelerate the growth of vegetation which, have been endorsed by the Environment Agency and the Mineral Planning Authority.

Redundant pits, tips and infrastructure at Lee Moor offers significant potential to assist with economic growth in the from of sustainable waste management; renewable energy schemes; commercial/industrial parks; housing and office space. However to assist in the delivery of such development Imerys require supportive, flexible planning policies to encourage and deliver those aspirations for the site.

Imerys would therefore like to see a local planning policy framework which sets out criteria by which a variety of sustainable development schemes could be assessed in a robust yet positive manner.

Imerys would also wish to see a balanced approach when it comes to weighing up the merits of planning applications for development, whilst recognising the economic driver, which is the NPPF.

Thank you for the opportunity to make these initial representations at this early stage of the plan. Imerys would be keen to engage with you on the journey to Plan adoption and with this we would be more than happy to meet with you and/or arrange a visit to our operations and non-operational property to show you what opportunities exist at Lee Moor.

Please do not hesitate to contact me on either of the telephone numbers below to discuss further.

Yours faithfully,

Gary Staddon Planning & Estates Manager ______

PL24 2SQ - England www.imerys.com

IMERYS Minerals Limited is a business name of IMERYS Company No. 269255 - Registered in England and Wales Registered Office: Par Moor Centre - Par Moor Road - Par - Cornwall - PL24 2SQ - England

1 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Chris Brook (where relevant) Job Title: N/A (where relevant) Organisation: N/A Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Do you mean Page 10 or page 12??? But yes, generally the correct Comments: challenges are identified Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Sustainable Development - this is THE single most influential and challenging issue that the South Hams faces. The national position of a presumption in favour of sustainable development is one that I am sure SHDC would support, therefore, what constitutes sustainable is the key issue. The infrastructure in the south hams is anything but sustainable - SWW have the highest rates in the country, yet can not afford to maintain or upgrade their existing Comments: infrastructure and continue to pollute SSSI estuaries. The Highway Authority is facing massive cuts to their maintenance budget whilst facing higher traffic levels. The existing highways are constrained with no margin for improving. Public transport is almost impossible to deliver in a economically justifiable way due to low population density, narrow roads and large distances.

On top of that - housing targets are set nationally and higher property

1 values in the South West mean commercial developers focus their efforts where the most profits are to be made. We are behind on delivering our housing targets, and so we are under pressure to consent to development. All of these factors result in one thing only - lots of unsustainable development. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). If the south hams needs more housing we should ensure it is delivered to the people that need it - local people. Opportunities for self build should be included in allocated sites, affordable houses should be just Comments: that - rather than contributions that don't get spent. Houses should have covenants on them for local works - that would keep the value low, so local people could actually afford them, especially in places that have high second home demand (often on the coast). Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Local Plan - public consultation reponse Attachments: Local Plan response re Renewable Energy 20 6 2014.docx

Dear Sir,

I am concerned that the agenda and timetable published in relation to the SHDC Local Plan does not appear to allow for a proper public consultation on the draft plan when that becomes available. I see that schools and certain groups are to be consulted, but not, it seems, the wider community of local residents.

I should be grateful if you could confirm that this is an unintended omission from the timetable and that that there in fact will be a period of public consultation on the draft plan.

I attach a list of proposals for the plan in relation to renewable energy.

Yours faithfully,

N C McDonnell

1 Renewable Energy

1) On Shore Wind Turbines in South Hams

a) Environmental Impact Assessments [EIAs] should be required for: i) all turbines with a maximum height to blade tip of 15 metres or more and ii) for all turbines of any size within 2 kilometres of the AONB or National Park.

To date, EIAs have almost never been required by SHDC for wind turbine proposals, not even those of 100m height or more, and, given the environmental sensitivity of the South Hams, the result has been that no effective screening process is currently in place.

b) Bat and bird surveys should be required for all turbine applications of all sizes, from very large scale turbines down to roof-mounted micro-turbines. The South Hams has an internationally important bat population, with bat roosts widely distributed in barns, lofts, trees and caves. All species of bats are European Protected Species which means that SHDC must have evidence upon which to base their decisions in every case. The existence of the South Hams Special Areas of Conservation [SACs] for greater horseshoe bats with their extensive network of sustenance zones and strategic flyways also requires SHDC to have a specified level of evidence wherever a turbine proposal might affect the conservation objectives of the SAC.

c) Parish Councils within 10 kilometres and neighbours within 1 kilometre of the proposed site should be routinely informed of scoping requests. There needs to be a definition of the minimum standard of public consultation before an application will be validated and this should be sufficiently stringent to ensure people have a real say in what happens in their area.

d) Minimum Separation Distances should be adopted in line with Lord Reay’s Bill and Wiltshire County Council with additional distances specified for some smaller turbines. According to a paper published by the Renewable Energy Foundation “Wiltshire Council Wind Turbine Separation Distances from Dwellings” on 26 November 2012 [Appendix B], these “distances are only borderline sufficient to protect amenity based on the ETSU-R-97 principles, and in the case of the turbines exhibiting blade swish noise in excess of that anticipated by the guidance, the separation distances would not protect amenity” and so these separation distances are the absolute minimum which should be required.

The separation distances specified, subject in all cases to exceptions where all affected neighbours agree otherwise in writing, should be as follows:

Turbine height to blade tip maximum Separation distance

Greater than 10 metres but not exceeding 15 250 metres metres Greater than 15 m but not exceeding 25 m 500 metres

Greater than 25 m but not exceeding 50 m 1000 metres

Greater than 50 m but not exceeding 100 m 1500 metres

Greater than 100 m but not exceeding 150 m 2000 metres

Greater than 150 m 3000 metres

The result of the recent judicial review of the Milton Keynes revised minimum distance was misreported in some parts of the Press but in fact does not prevent or discourage the adoption of minimum distances by local authorities.

The judgment confirmed that local authorities can set exclusion zones to protect local people from inappropriate development and provides significant encouragement for this. The single ground on which the judicial review succeeded for the wind farm developers was that Milton Keynes had already specified a buffer zone of 350m in its 2002 local plan. The judge ruled that the amended separation distances in the Supplementary Planning Document [SPD] were in conflict with the pre-existing buffer in the local plan. If a pre-existing separation distance had not already been part of the local planning policies, Milton Keynes Council would have succeeded on all four grounds. The judgment suggests that separation distances should be phrased positively rather than negatively i.e. that policies should not be phrased in terms of planning permission being refused if turbines are within x metres of a dwelling, but rather that planning permission may be granted if turbines are more than x metres from a dwelling, provided that there are no significant adverse environmental or other impacts. The judgment also concludes that the adoption of minimum separation distances does not conflict with the National Planning Policy Framework [NPPF] or with the Overarching National Policy Statement for Energy [EN-1]. We refer you, in particular, to paragraphs 142, 144 -146, 166-167, 171-175 and 214 of the judgment. e) The imposition of an effective and legally enforceable noise condition needs to be an absolute requirement in every case, whether or not minimum distances are imposed, as some turbines prove noisier than predicted. The ‘Den Brook’ condition clearly offers wind turbine neighbours the best protection. In the event there is substantial reason not to apply this particular condition, the ‘Chiplow / Jack’s Lane’ condition in its entirety should be applied.

It is not sufficient to rely upon ETSU-R-97 to protect local residents from excessive noise. ETSU is widely understood to be seriously flawed in its methodologies and inadequate to provide protection for residents. There are more than 70 documented cases in the UK where ETSU has seriously failed to protect neighbours from noise nuisance. In particular, ETSU does not deal adequately with amplitude modulation associated with wind shear. It is appreciated that SHDC is not in a position to reject the use of ETSU guidance; therefore in order to offer South Hams residents adequate protection from noise, SHDC needs instead to supplement ETSU with more effective forms of protection i.e. minimum separation distances combined with an effective noise condition.

In its submission to the Welsh Assembly in response to a petition requesting legislation to control noise nuisance from turbines, Hayes McKenzie stated that distances of up to 1.5 kilometres might be required to comply with ETSU where background noise levels are low. The same Welsh Assembly petition includes harrowing accounts by residents personally affected by excessive noise.

Similarly the legal remedy of statutory nuisance is in practice ineffective as the process is lengthy, expensive and burdensome for the council and/or resident. Even if an abatement notice is served, failure to comply only carries a fine which a wind power operator is likely to regard as trivial. It is unlikely to result in the cessation of the nuisance.

Furthermore, the independent noise consultants RdB Associates, whom SHDC appointed in relation to the planning application at Luscombe Cross, advised on pages 2 and 3 of their letter of 19th December 2012, that “reliance on Statutory Nuisance under The Environmental Protection Act does not provide the degree of protection required under the NPPF.” f) Landscape and Heritage – It should be a requirement that photomontages provided by the applicant are prepared using a camera lens with a 75mm focal length. Photomontages are, in themselves, inadequate to represent the effect of wind turbines on the landscape or upon heritage assets. The number of viewpoints adopted by the developer is often very limited in number and sometimes subject to distortion and omission. We would refer you, for example, to English Heritage’s comments on the misleading nature of the Luscombe Cross photomontages. A study by Dr P D Hunter of the University of Stirling “The Effect of Focal Length on Perception of Scale and Depth in Landscape Photographs – Implications for visualisation standards for wind energy developments” published on 17 May 2012 recommended a focal length of 75mm as providing the most accurate result for wind farm developments. The report states: “the vast majority of participants in the main survey (n=334; 96.5% of the sample) were of the opinion that a 50mm single frame image for visualisation made the specified focal point (or area) appear too small and too far away relative to its appearance in the actual landscape.” Thus the focal length adopted as the “wind industry standard” appears to give a misleading impression for the vast majority of people. There is a further difficulty with photomontages in that the human brain registers vertical height differently than horizontal distances. Although photomontages may be useful as an aide memoire there is no substitute for seeing a physical height marker flown above each turbine site. g) Physical height markers should be required in every case to demonstrate maximum blade tip height. i) Physical height markers will enable local residents, councillors and planning officers to make informed decisions based upon objective evidence and will avoid much waste of planning departmental resources. ii) The days that the flight markers are flown should be advertised in advance, but deferred and re-advertised if bad weather prevents their use. iii) The days when height markers are flown should include both weekdays and weekends so that those away at work have an opportunity to view them. iv) The scale of the markers should be proportionate to the height of turbines as smaller markers will not be easily visible at the distances where the actual turbine blades would be highly visible. A minimum 1 metre diameter weather balloon may be considered adequate for turbines up to 15m high and a blimp (normally 6m x 2.5m) for taller turbines. h) Either wind speed figures supplied by the Met Office’s Virtual Met Mast, or a full year of measured wind speed data should be provided with the planning application together with details of the performance characteristics for the particular model of turbine proposed. “Planning practice guidance for renewable and low carbon energy” issued by the Department for Communities and Local Government in July 2013 (paragraphs 12 and 38) encourages local planning authorities to consider the predicted wind resource for turbines as well as emphasising that the need for renewables does not override environmental protections and the planning concerns of local communities. Wind speed data from NOABL has been declared obsolete by both DECC and the Met Office and should not be relied upon for the purposes of SHDC’s consideration of wind resource.

Consideration of a planning application requires a weighing-up of the benefits of the development against the harm. It is reasonable to require that the negative effects of a wind turbine upon the landscape, heritage assets and nuisance to neighbours etc should be balanced by reasonably efficient production of power.

Professor Gordon Hughes in his paper “The Performance of Wind Farms in the United Kingdom and Denmark,” published on 19 December 2012, notes, at paragraphs 14-16, the surprisingly wide variation between the best and worse performers for UK onshore wind farms as compared with Danish. “A plant at the upper quartile of the distribution of UK onshore wind farms will generate an annual output that is about 40% higher than a plant at the lower quartile.” “Outside the range between the upper and lower quartiles, the top and bottom segments of the distributions extend further up and down for UK onshore wind farms than for those in Denmark.” He continues “It is somewhat surprising to observe the magnitude of the differences in the performance in onshore wind farms in the UK. Given the nature of the subsidy regimes and the high capital cost of developing new installations, it might be expected that operators have a strong incentive to identify the best locations and then choose equipment that will deliver the maximum amount of electricity at a high level of reliability. For onshore UK operators it seems that good or bad performance is somewhat of a lottery. However, if the subsidies provided by ROCs are sufficient to underwrite investment in inefficient plants - as appears to be the case – then those subsidies are extremely generous for plants that operate close to the efficient frontier. As location is likely to be the main factor that determines the performance of a specific plant relative to all other plants, the inference must be that many wind plants have been developed on sites with poor wind characteristics [emphasis added].”

Either Met Office Virtual Met Mast figures or measured wind data for a year together with the performance characteristics of the particular model of turbine will enable an informed decision to be made on the appropriateness of the proposed site for power generation. As average wind speeds vary significantly with the seasons, a year’s wind data will normally be the minimum required. The power output of a wind turbine is roughly proportional to the cube of the wind speed between the ‘cut in’ speed (below which the turbine does not operate) and the ‘rated’ wind speed (the wind speed required for maximum output above which any increase in wind speed results in no additional power output). Therefore between the ‘cut in’ speed and the ‘rated’ speed, small reductions in wind speed can result in large reductions in power output. The Energy Saving Trust say that they do not recommend that domestic small scale wind turbines are installed in areas with wind speeds of less than 5 metres per second as speeds less than this are unlikely to provide a cost- effective way of producing electricity with current technologies. i) Similarly, in the interests of requiring reasonably efficient production of power to set against the harm created by wind turbines, ‘powering down’ should be discouraged. This term refers to the practice of specifying inappropriately tall turbines compared with the expected power output. A developer may do this in order to qualify for FITs rather than ROCs, in other words to manipulate the subsidy scheme for which the turbine will qualify. There should therefore be a maximum hub height specified commensurate with expected power output. j) Direct reference should be made in Our Plan to the importance of tourism to the local economy and local jobs and to the need to consider the effects upon tourism in assessing the sustainability of a planning application. Tourists are drawn to the South Hams for its natural beauty and tranquillity, and its wildlife. These will be destroyed by large turbines or by excessive proliferation of smaller turbines.

The demographic of tourists to the South Hams is predominantly middle-aged – an older demographic than, for example, Cornwall where tourist activity is centred on the beaches for families with small children and for water sports. In the South Hams, preservation of the landscape of the central areas is vital for maintaining tourism revenues and jobs as well as the landscape at the coast.

The Scottish Parliament commissioned a report “The economic impacts of wind farms on Scottish tourism” published in March 2008 which suggested that nearly 20% of current and potential tourists in an internet survey would not visit an area if a wind farm was constructed. 63% of those polled preferred a landscape without a turbine from their hotel bedroom window.

More recently, the Mountaineering Council of Scotland’s survey dated March 2014 states that two thirds (68%) of respondents said that due to the presence of wind farms, there were places in Scotland that were already less appealing for walking and climbing while a similar proportion (64%) said that there were places they were less likely to visit or revisit because of the presence of wind farms. Nearly three-quarters (73%) would choose accommodation without a wind farm view. The report’s summary also noted that surveys of the general public also suggest a trend of rising visitor discouragement due to wind farms, from under 10% before 2008 to 17% in 2011 and 26% in 2013.

Holiday accommodation in the South Hams is distributed throughout the whole area in the form of holiday cottages and bed & breakfast establishments, rather than concentrated in hotels near to the beaches. k) The precise definition of Shadow Flicker should be set out, as it is otherwise likely to be misunderstood. Shadow Flicker refers only to the strobing effects of sunlight from behind turbine blades falling upon a window and does not apply to external work places, gardens and roads. Therefore any mitigation conditions defined in respect of Shadow Flicker will not protect these latter areas at all. l) There should be separate evaluation of the effects of strobing on exterior workplaces in frequent use, and on roads, bridleways, footpaths and gardens. This evaluation needs to extend to a wider radius from the proposed site than 10 rotor diameters. m) For both Shadow Flicker and other strobing nuisance, it should not be left to the affected residents to pursue a remedy, which will involve logging the nuisance for periods of up to a year. Computer programs exist which can map the affected areas with considerable precision and these, combined with light sensors attached to the turbine, can automate the prevention of such nuisance from the areas to be protected as part of a planning condition. n) The British Horse Society’s recommendation of a separation distance from bridleways of four times the fall-over distance should be endorsed. o) The Civil Aviation Authority’s recommendations for minimum separation distances between wind turbines and airports/airfields should be adopted as SHDC policy. p) Ministry of Defence recommendations in respect of air safety, low flying consultation zones and Defence Infrastructure Organisation Safeguarding recommendations in respect of onshore radar coverage should be adopted as SHDC policy. q) The full cost of decommissioning, including the removal of the concrete base should be required to be placed in escrow before construction commences. r) Wind turbines can cause interference with TV, broadband and mobile phone reception. Identification of potential interference and a plan for full mitigation should be required to be submitted with the planning application.

s) The community benefit fund is not a material planning consideration and should carry no weight in the determination of a planning application. It is a fundamental of the Planning System that planning permission cannot be bought or sold. The Community Benefits Protocol encourages payment of “compensation” to parish councils rather than to the individuals who actually lose out. This practice was described in the House of Lords debate of 10 June 2011 by Lord Reay as “both corrupt and divisive. The people who will receive the advantage will not be the same as those who suffer the injury. How will a community playground, while it may sway a planning committee, compensate someone who has seen his environment immeasurably degraded and the value of his house fall by 35%?” (Wind Turbines (Minimum Distance from Residential Premises) Bill , House of Lords 10 June 2011).

t) Micro Scale Turbines - Permitted Developmen Given the extensive greater horseshoe bat flyways and sustenance zones associated with the South Devon SACs which are protected by European law, any ‘permitted development’ without appropriate bat surveys and SHDC evaluation using specified criteria would appear to breach European law. It has previously been suggested by a consultant engaged by SHDC that permitted development rules are handed down by central government and not subject to amendment by local government. The question was raised with the Planning Minister at a private meeting arranged by Dr Wollaston MP and the Minister gave his informal opinion that there are no permitted development rights in an SAC or SPA. SHDC’s own advice from Michael Oxford of Kestrel Wildlife, obtained in relation to a specific planning application, stated “But by law, SHDC must consider all applications that, alone and in combination, are likely to affect the integrity of the SAC wherever those applications occur within their jurisdiction.”

2) Solar Arrays in South Hams

a) Large-scale solar PV arrays should not be located on green field sites which should be reserved for food production and which form an intrinsic landscape asset for this area. Instead they should be guided towards previously developed/contaminated land; industrial land and its margins; and adjacent major transport corridors.

b) All solar farms should be required to use removable foundations rather than concrete so that at the end of the panels’ life the land can revert to agricultural use and remain greenfield sites, where applicable, rather than being converted to brownfield sites.

c) Where it is intended to store some electricity on site rather than simply supply the National Grid, careful consideration should be given to the associated storage arrangements and machinery, including the effects upon residential amenity for neighbours and the risk of pollution of land, ground water and water courses, as many of these arrangements involve toxic chemicals and noise. d) Solar panels need to be removed and recycled at the end of their lives. The developer should be required to make provision for this at the outset and place a sum in escrow equal to the full cost of removal and recycling. e) A strong preference should be expressed for horizontal sites which are not overlooked and can be screened effectively by vegetation, rather than hillsides which are overlooked and cannot be screened effectively. f) There have been disturbing instances of solar farms effectively surrounding neighbours’ properties. There should be a restriction that a neighbour’s property should not be faced with more than 120 degrees of solar farm unless the neighbour agrees otherwise in writing. From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Alan Stapleton (where relevant) Job Title: (where relevant) Organisation: Soil and Land Management Consultancy Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). The categories (Vision,Homes,Economy etc) seem fine but within these I would like to see the following additions: Under Our Economy, Social Enterprise Comments: Under Our Heritage, Geoheritage Under Our Resources, Flood risk should be widened to incorporate Water Management , Soil Protection should be added. Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Some of these are too aspirational and outside the scope of the spatial plan. Most important are Comments: Supporting and retaining jobs Finding innovative and flexible housing solutions Responding positively to climate change Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Some of these are too aspirational and outside the scope of the spatial plan. Most important are: Enabling the right amount of development in the right places (includes the supporting infrastructure) Comments: Recognising and promoting what makes the area special/Making the most of our historic environment geoheritage and wildlife Protecting and enhancing our natural landscapes (in the face of land use and climate change) 1 Enabling waste management Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Specific plans for the four towns and the most remote areas Comments: Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 Unit 2 Eclipse Office Park High Street Staple Hill Bristol BS16 5EL

Strategic Planning Date: 20 June 2014 South Hams District Council Follaton House Our Ref: FT M4/1012-16 Plymouth Road M4/1203-07 Totnes Your Ref: Devon TQ9 5NE

By email only: [email protected]; [email protected]

Dear Sir or Madam

RE: SOUTH HAMS AND WEST DEVON LOCAL PLAN – SCOPING, JUNE 2014

We represent the South West HARP Planning Consortium which includes all the leading Housing Associations and Registered Providers (HARPs) across the South West. Our clients’ principal concerns are to optimise the provision of social/affordable housing and to ensure the evolution and preparation of consistent policies throughout the region.

How many plans?

It is not entirely clear from the consultation documents the relationship that West Devon and South Hams’ Local Plans will have. Is there to be a single Local Plan which covers both districts, or two separate plans which are coming forward together? This must be clarified. If it is the first, then we would encourage the Councils to produce single consultation documents to a single consultation request. It seems artificial to produce two different documents that say exactly the same thing, and it adds an element of confusion which is not necessary. We would also suggest the use of a single website/page containing both local authorities’ evidence bases, as cross referencing between the two local authority websites is not effective.

If there are two distinct Local Plans proposed, we would ask the Councils to draw some distinctions. For example, changing the names so they are not the same, creating distinctive and individual consultation documents and undertaking consultation at slightly different times.

We would draw the Councils’ attention to the ongoing examination of Bromsgrove and Redditch Local Plans; specifically that the Inspector has been highly critical of their approach, which has resulted in the duplication of documents, and confusion as to the relationship between the local authorities.

Dartmoor National Park

We would ask the Councils to clarify the relationship with Dartmoor National Park. Both maps include the National Park in the area that the Plans will cover. However, Dartmoor has an adopted Core Strategy and its own associated DPDs and SPDs. We would assume that the National Park area is therefore excluded from the Local Plans, but with the Local Authorities and National Park Authorities requiring a proactive relationship in line with the NPPF’s Duty to Cooperate.

Plan Preparation

Whilst there is an element of flexibility in respect to consultation requirements within the local plan process, we would question the Councils’ decision to issue the current document as a Regulation 18 consultation. It provides little basis for consultation, and essentially highlights generic issues and

considerations highlighted in the NPPF. It is unlikely that the Councils will receive detailed representations as a response, thus providing very little basis upon which to progress the Local Plan. In particular, we would encourage the Councils to present Preferred Growth Options in respect to the Local Plan, to ensure local communities can consider the relative options over the plan period. Against the Councils’ current plans, the next consultation would present the final option – presenting no opportunity for informed debate.

We support the Councils’ efforts to progress the Local Plan as efficiently as possible and commend the Councils’ efforts to adopt a new Local Plan within a short timeline. However, this should not be to the detriment of providing sufficient opportunity for members of the community and interested parties to comment and engage. Presenting all the detail in the final Regulation 19 consultation does not provide the Council will sufficient opportunity to respond to detailed comments, with the only option available to request the Inspector accept modifications both prior, during and following the examination process. This does not represent good plan making. The nature of the examination precludes a majority of persons from participating both due to its complexity but also the costs associated with securing specialist consultants to participate in the examination as required.

A Local Plan should be sound at submission. Not reliant on proposed modifications. Thus indicating the necessity to undertake two detailed consultations.

We note that the NPPG indicates a preference for all local planning documents to be contained within the single Local Plan, rather than numerous additional site allocations and development management development plan documents. We would encourage this approach, of a single comprehensive plan, as a more efficient plan making process. Evidently, SPDs would still form part of the Councils’ planning policy, however the remit of SPDs should reflect their role as supplemental to, rather than providing an integral part of the delivery of Local Plan objectives. SPDs should not seek to bolster or add additional weight to adopted policy.

Local Plans

The Councils will be aware of the significant issues which have arisen throughout England as Local Plan Examinations have come forward. We would not reiterate these here, as they are well documented elsewhere. But we would note for the Council, that in the South West, the following Local Plan Examinations should be of note: Bath and North East Somerset, North Somerset, South Gloucestershire, East Devon, Teignbridge, West Dorset-Weymouth & Portland, Stroud, South Somerset and Wiltshire.

What is clear across England, is that the most significant issues in respect to Local Plans Examinations is in relation to the Duty to Cooperate and Housing Numbers, we thus discuss these in more detail below. It is also noted that affordable housing has been raised in a considerable number of these Examinations, and we draw the Councils’ attention to such

We are aware that there are a number of other Local Plans coming forward in the South West and we would caution the Councils from using these as any indication of Local Plan development. There are significant issues in respect to emerging Local Plans; not least Cornwall and Torbay’s Pre-submission Local Plans.

We also note that a number of Local Plans adopted in the South West came forward both before the NPPF, but also the NPPG. Whilst not immediately evident, we would ask the Council to note that the NPPG does contain a number of significant amendments in respect to the expectations of the Government, and thus Local Plan Inspectors, in relation to a number of matters; notably housing needs.

Duty to Cooperate

The Duty to Cooperate is of particular importance both between the two Councils and Dartmoor National Park, but also neighbouring local authorities.

It is noted for example that Torbay’s Pre-submission Local Plan has indicated that it is unable to meet the objectively assessed need within that plan area by some 2,300-4,000 units, and that there is a requirement for South Hams and Teignbridge to meet this housing requirement. It is evident that this must be resolved at this stage of the Local Plan, or should the Councils indicate that there is no capacity within the plan area to meet some of Torbay’s housing requirement, it would evidently be necessary for this to be highlighted at the outset. It is also noted that Teignbridge objected to Torbay’s housing requirement in the previous local plan consultation.

It is also noted that Plymouth, Cornwall, Mid-Devon and Torridge are all progressing local plans currently. Thus it is possible for the Councils to reach agreement with all their neighbouring authorities, bar Teignbridge1, at this stage of the Local Plan as to any cross-boundary housing issues.

It is further noted that housing should not be the only purpose of the Duty to Cooperate, with employment aspirations, significant employment land developments, educational needs and environmental concerns all of particular interest at a regional level.

We would also encourage the Councils to engage proactively with the Local Enterprise Partnership, both in relation to regional growth aspirations but also detailed employment projections and affordability concerns.

Housing Numbers

We are aware that the Councils have participated in a joint SHMNA (2013) with some neighbouring local authorities, and we commend this approach.

At this stage of the Local Plan, we will not seek to consider the relative merits of the SHMNA (2013), as this is more appropriately undertaken once the Councils have selected a housing target. We would however make the following comments:

- The SHMNA evidence base is from 2012/2013 evidently indicating that there will have been a degree of change by the time the Local Plan is examined in 2015. Notably, it will be necessary to re-evaluate market signals over this period. Any significant delay in examination would question the evidence base’s reliability;

- We note that since the SHMNA, the 2012-based Subnational Population Projections have been published. Consideration of these must be undertaken – in particular it is noted that West Devon’s population is projected to increase at significantly greater numbers than the re- based SNPP 2010 projection;

- It is evident from a cursory reading of the SHMNA that a demographic based housing target would not be appropriate for South Hams or West Devon, with the lowest job projection exceeding the re-based SNPP 2010 household projection;

- The NPPG’s requirements to consider the need to retain an appropriate working age population base is of particular relevance to the two local authorities, notably so in South Hams;

- It is evident that affordable housing need is significant within both local authorities and that “an increase in the total housing figures included in the local plan should be considered where it could help deliver the required number of affordable homes” (paragraph 029, section 2a, NPPG) would be appropriate;

- It is noted that the SHMNA does not consider affordable rent, in terms of an assessment of affordable housing need it is therefore flawed; and

1 who recently adopted their Local Plan

- The implications of migration trends need careful consideration, particularly in respect to any recessionary-trends used within projections.

It has become well established that Councils must be able to appropriately justify the assumptions selected in setting their housing requirements. In particular, the relationship between job growth and housing growth has been particularly highlighted in numerous local plan examinations, notably South Worcestershire’s Development Plan, whereby housing requirements which fail to reflect projected employment growth, have been indicated as unsound.

It is also noted that more recent local plan examinations have integrated in a more comprehensive manner the national Government’s ambitions in relation to housing supply and delivery. Notably, the selected housing requirement has been considered in relation to previous delivery rates, with local authorities coming unstuck where the housing requirement does not deliver a “significant boost” in housing delivery from historical rates; see for example Stroud and North Somerset.

Affordable Housing

As we mention above, the Councils have a significant need for new affordable housing over the plan period. This necessitates consideration of increasing housing delivery to boost delivery of affordable housing, but also a consideration of the relative delivery mechanisms available to ensure affordable housing delivery.

At the outset, it is noted that the timing of the Councils’ Local Plan indicates a significant opportunity to be both proactive and imaginative in securing the delivery of affordable housing across the plan area; drawing upon best practice elsewhere and embracing new and emerging delivery mechanisms.

Evidently, the standard practice of securing affordable housing through s106 planning obligations should be pursued, and set at an appropriate level in accordance with a viability appraisal.

It is also evident that the use of a rural exception site (RES) policy is integral to the delivery of rural housing within the two districts. Since the Councils’ Core Strategies were adopted there have been significant developments in the policy and practice of RESs. There are a range of policy approaches across the South West, which have had varying degrees of success in securing the necessary delivery of housing. What is evident from an examination of recently adopted plans is that RESs must be justified by an appropriate assessment of need – whether that be a local housing needs assessment or the presentation of general needs information relative to the location, and that flexibility in relation to site selection is important (notably Councils which have sought to apply detailed criteria ie site must adjoin the settlement boundary, have had such criteria removed or modified by Inspectors, ie to site must be well related to the settlement). It is also noted that no local plans post NPPF have been found sound which do not allow for cross-subsidy in the delivery of RESs. It is further noted that in the South West, only 7 rural authorities do not currently allow cross-subsidy:

- Forest of Dean – Core Strategy pre-NPPF (Oct 2011) – indicated in correspondence that exceptions would be allowed

- North Somerset – Core Strategy April 2012 – Remitted policies unsound

- Poole – Core Strategy Feb 2009 – Rural area is in Green Belt, but note significant numbers of recent planning appeals allowing cross-subsidy RES in Green Belt

- Torbay – very old Local Plan - significant issues with the emerging Local Plan

- West Dorset, Weymouth and Portland – Local Plan Examination suspended – Inspector specifically queried delivery of affordable housing

- West Somerset – very old Local Plan – emerging Plan has been through many iterations, not yet submitted to examination.

It is clear that cross-subsidy is now an expected element of any RES policy, and impetus is added in respect to the two districts and their respective housing markets, and the high values attributed to potential housing sites.

Finally, it is noted that the role of community support in delivering rural housing has been examined in detail in many examinations. It is evident that community engagement and involvement should be encouraged throughout a RES process, from housing need surveys to design and location, however it is evident, and as demonstrated in planning appeals throughout the region, that local community support is not necessary to bring forward a scheme, with the delivery of rural housing seen as a strategic objective across the region.

Across all the delivery mechanisms, the issue of affordable housing tenure is complex. Evidently the Councils should undertake an appropriate assessment of affordable housing need and indicate the relative needs of the different tenures; social rent, affordable rent and intermediate. However, it is evident that the range of intermediate models coming forward is growing exponentially, following significant encouragement from the national Government, it is therefore important that any policy indicates that Council’s willingness to apply flexibility across tenure requirements.

We would encourage the Councils to adopt a policy which encourages alternate delivery models; for example 100% intermediate or affordable rent schemes, or cross-subsidy schemes which delivers low cost homes for sale (with market housing providing the ability to discount housing to 50-60% open market value). Such models are becoming increasingly popular with a range of housing providers, and play a role in many HARP’s delivery programs now grant is limited. We would note that there are two elements required to ensure the Councils effectively embrace alternate delivery models. Firstly, the recognition that the Councils will engage with any developer into discussions of alternate models on identified sites. But secondly, the assumption that alternate schemes will not require negotiation away from the standard s106 expected tenures.

Viability

It is evident that viability is a significant issue across the range of policies. It is standard practice that viability issues can alter policy requirements to enable schemes to come forward. We agree that this is an appropriate approach. We have a practical comment to make, in that the Councils should encourage an element of flexibility when requiring viability assessments. It is a common misconception that the production of a detailed viability assessment by a RICS-qualified surveyor is a standard practice, and that the imposition of this requirement on a developer is not significant. We would disagree, a full RICS viability assessment is significantly more detailed than the open book assessments undertaken by a developer. We would encourage the Councils to adopt a flexible approach to the submission of viability assessments, in that sufficient details must be submitted in an open book manner, and that alone should be the Councils’ requirement.

We would also suggest that the Councils seek to obtain appropriate training of key staff, to enable review of any submitted viability appraisals to occur in-house, rather than requiring the time and expense of outsourcing reviews.

Specialist Older Person’s Housing

Analysis within the SHMNA (2013) clearly indicates a significant projected increase over the plan period of the age group 65+. Whilst it considers the implications of this projection on the need for additional care homes spaces, at some 363 new beds over the plan period, it does not consider all the needs of this demographic group, with the NPPG requiring assessment of future need for older persons housing to be broken down by “tenure and type (e.g. sheltered, enhanced sheltered, extra care and registered care) should be assessed” (2a paragraph 021 06/03/2014). Given the significant projected increases in older persons over the plan period it is vital that the Councils ensure their

evidence base considers the range of housing models which may be required, not just provision of standard care beds. It is also noted that there is no assessment as to the specialist older persons housing needs of those requiring affordable housing, and this should also be assessed.

The NPPG references the toolkits available to local authorities when addressing specialist housing needs. One such toolkit is Housing in Later Life: planning ahead for specialist housing for older people (December 2012); this contains an example policy which would be appropriate for South Hams and West Devon, although there are numerous adopted and emerging Local Plans2 which the Council could also draw from. It is not clear if the proposed Local Plan will allow for site allocations or whether they will come forward in a different document, however we would note the following policy example:

“The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations.

The Council aims to ensure that older people are able to secure and sustain their independence in a home appropriate to their circumstances and to actively encourage developers to build new homes to the ‘Lifetime Homes’ standard so that they can be readily adapted to meet the needs of those with disabilities and the elderly as well as assisting independent living at home.

The Council will through the identification of sites (in any forthcoming Site Allocations DPD), allowing for windfall developments and/or granting of planning consents in sustainable locations, provide for the development or retirement accommodation, residential care homes, close care, Extra Care and assisted care housing and Continuing Care Retirement Communities.”

It is also important to recognise that viability issues are frequently associated with specialist care housing, which prevents delivery. Land values for standard C3 housing are frequently too high, given the higher relative build costs and the returns of specialist housing; this will be emphasised in the particular hotspots of high land value across the plan area. This could be particularly important given that the Council have significant housing affordability issues.

The scale of specialist housing and care developments can be substantial given the range of accommodation provided and the additional facilities expected within such developments. The Council must recognise that in some instances, planning applications will come forward outside of development boundary areas, however the need for such developments and the availability of suitable land (at an appropriate land value) within urban limits, render the consideration of an exception to policies of restraint within these areas.

In these instances, additional policy wording along the lines of South Gloucestershire’s Core Strategy Policy CS20 would be appropriate:

“Extra Care schemes should be located so they are accessible to local facilities, proportionate in scale to the locality and provide ancillary facilities as part of the development. These ancillary facilities should complement locally available amenities and be made available to the wider community.”

Custom/Self Build

It is noted that, in line with national policy, the role of custom and self build housing as part of a development plan is growing. There are multiple approaches throughout the region, however policies have had mixed reception from Local Plan Inspectors.

What is evident from examinations across the South West, is that firstly, custom build and self build are different and it is important to recognise the relative differences between the two housing models. Secondly, neither of the products are automatically ‘affordable’ and as such cannot be used interchangeably with an affordable housing requirement. As per standard affordable housing, should the Councils seek to pursue custom/self build as an alternate affordable product, this must be secured

2 In particular we would note emerging policies in East Devon and Mendip

as such through appropriate policy and legal agreement. Finally, it is noted that any policy requiring provision of such housing products must be tested as part of the local plan viability assessment.

CIL and Planning Obligations

We would encourage the Councils to consider at the outset the relative roles that CIL and planning obligations will play in the delivery of required infrastructure over the plan period. This should be reflected throughout the Local Plan.

It is also evident that the Councils must set their affordable housing target before considering relative levels of CIL. With the cost of affordable housing provision, and an appropriate assessment of other development costs relating to local plan policies, a consideration in the setting of the CIL rates.

Development Management Policies

It will be necessary to create appropriate development management policies and we would encourage the Councils to apply a flexible approach across all policies, to enable appropriate development to come forward, but also to prevent inappropriate development.

It is also noted that the Councils should include reference to changing Government policies, for example the Housing Standards Review, to ensure that it is clear that subsequent national changes will require amendment of adopted policy, or will provide the basis for the decision-making over any inconsistent local planning policy.

Neighbourhood Plans

The role of Neighbourhood Plans in encouraging and facilitating development is by no means clear. A number of NPs are coming forward, with many now at the advance stages. It is evident that these do have some roles in allocating and identifying land for future development, but that this is an option available to communities to pursue but not a requirement – with many NPs not seeking to identify development land.

It has been made clear in a number of examinations that Councils cannot depend on the delivery of any neighbourhood plan. For example, in Wiltshire’s Local Plan Examination the Inspector raised concerns:

“considerable risk that, for example, Neighbourhood Plans will not be delivered across the county in a comprehensive or timely fashion. Such an outcome would, in the context of the CS Settlement and Delivery Strategy, potentially stymie development initiatives on the basis of an unjustified evidence base and therefore not represent a positive form of planning” (procedural letter dated 02/12/2013, page 8).

The above comments are intended to be constructive. We would like to be kept informed of the Local Plan’s progress and consulted on further stages; please ensure that the South West HARP Planning Consortium are retained on the LDF database, with Tetlow King Planning listed as their agents. It is noted that the Councils indicate that there may be future consultation events; we would confirm to the Council that we would consider attendance at any future event, and that we would seek to notify all members of the consortium in sufficient time.

Yours sincerely

cc: Aster Group DCH Guinness Partnership Sanctuary Housing Group Sovereign Housing Association Spectrum Housing Group Westward Housing Group

Liam Reading, South Hams District Council Debbie Holloway, South Hams District Council Stephen Forsey, South Hams District Council Cassandra Harrison, South Hams District Council Marion Playle, West Devon Borough Council

From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Elaine Trewick (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). I think there should be more emphasis on preserving the countryside, coastline and heritage of Devon. Such as The Estate at Bantham, currently Comments: for sale. The Plan should contain restrictions to protect and preserve areas such as this for future generations as it can never be replaced.. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes

1 Data Protection

2 From: Strategic Planning Subject: FW: Our Plan Response SH

Our Plan Response SH

Your details Name: Cllr Jacqi Hodgson (where relevant) Job Title: District Councillor for Dartington and Town Councillor for Totnes (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Feels very much like business as usual rather than a resilient plan that will support local communities across the next seventeen years where we need to seriously address climate change, climbing energy costs and Comments: increasing austerity measures.

(Please see end box 'what else' for additional comments / outside the 3000 characters permitted here) Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Encouraging young people and families Supporting educational and cultural needs beyond the classroom Inclusive policies that prevent people from feeling excluded due to reduced economic circumstances or cultural differences or other marginalisation. Encouraging and supporting innovation Encouraging visitors and tourism Comments: Providing local Leadership to support local resilient communities in times of change Offer apprenticeships Building community engagement and supporting localism Support research into best practice Vibrant places to encourage vibrant society Education for all ages Do you think that we have identified the right challenges for Place? (page 7) Place No

1 If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). General: Too vague and suggests ideas without commitment Add:- Community transport, cycle networks, electronic charging points (at car parks via PV panels) Sustainable transport Enabling a greater diversity of affordable and social housing such as Co- housing, multiple shared houses, houseboats and innovative eco-houses. Reducing climate change through energy efficiencies being prioritised Local production of renewable energy through solar panels on roofs – rather than on green fields, and water and wind turbines Comments: Waste management that promotes the waste hierarchy, reduction, reuse and supports local economic development through local recycling etc. Avoidance of unnecessary journeys for delivery of public services, e.g. waste should be recycled locally, healthcare Attractive town and village centres that nurture local distinctiveness Improvements to public and community transport links Joined up systems for biodegradable waste to produce local energy supplies (through anaerobic digestion) Maximise opportunities for passive solar gain (without covering green fields), ie all rood spaces, car parks, roadways, train roofs etc and orientation in new buildings Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Our Vision Assumes we want growth – we don’t need this Dartington and Totnes are full Add:- A new vision for sustainable settlements with infrastructure and supports for improved community development in revitalised parishes and villages (rather than increasing urban sprawl around towns). A comprehensive land use strategy that makes better use of existing buildings and includes supports for farming, renewable energy provision, wild spaces, food growing, as well as provision for community amenities. Revitalised village and town centres that support resilient local communities with thriving Post offices, market places, village greens, and public amenities.

Our Homes Add:- Building houses in places that encourages synergy between services (such as former railway stations, e.g South Brent), bus routes etc. Innovative collective design, new models to meet future needs. Policy for Comments: dealing with second homes (extremely destructive), providing for local housing needs that attract young people as well as meeting local elderly, special needs and truly affordable. Well-designed sustainable homes (that avoid fuel poverty into the future) Smaller more organic growth in house-building rather than ‘fields of houses’ Policies to ensure use of empty buildings rather than build new ones Develop brown field sites before green fields

Our Economy Add:- Farming, agriculture and economy, and allotments that support the domestic economy and community development. Alternative economies such as bartering, local currencies and exchange that support people on low budgets. Supports for farming, in particular Local branding for local (high quality) food production. Collective supports for local food products, e.g market place development,

2 new distribution networks (eg food boxes), Revitalising former economic systems, such as cider industry, that requires local orchards, heritage species of trees and provides work. Economic policies that ensure the Living wage.

Our Heritage Add:- Supports for heritage buildings that retain both the integrity of the building and its curtilage, however with options for measures for improvements to improve energy efficiency and comfort, reduce bills and maintain the fabric of the building, e.g. double glazing, insulation etc.

Our Communities Add:- Amenities including community centres, libraries, youth centres, day care centres, play areas, community gardens, orchards and allotments. Community development that nurtures education, cultural vibrancy and local distinctiveness. Supports for community of interest such as local heritage, educations, community groups, crafts etc.

Our Nature Add:- Ensure supports for habitats and ensure protection for SACs. Saving seeds and supporting local seed banks Protection and nurturing for local and distinctive habitats such as Devon Banks, woodlands, ancient woodlands, rivers, estuaries and the coastline. Support biodiversity and natural habitats; replace and develop community orchards and community gardens. Enhance the landscape Support organic farming Ban dangerous pesticides and Genetically modified organisms (GMO)

Our Resources Add:- food growing energy production Revitalise local water supplies, (rather than high energy imported water from North Devon) Joined up systems for maximum efficiency, eg Use of sewage and compostable waste through an anaerobic digester to provide energy (eg gas for community buses. All car parks to have solar PV panels Ban Fracking Conduct research into best practice Policies that favour green field sites are retained for food production (rather than solar arrays) Make all roofs solar collectors

Our Wellbeing Add:- Faith communities, intergenerational networks Local access to all public services including healthcare facilities Holistic healthcare, ie. including access to green spaces, peaceful places and affordable centres for activities such as municipal leisure centres, gyms etc for all age groups. Reduced exposure to noise and white-light pollution Permit access to the countryside

Infrastructure – additional topic for inclusion (too large to have as a sub-heading) Park and st/rides at railways etc, i.e. transport hubs sustainable transport systems and networks Sustainable localised waste management amenities and network that supports local recycling and associated economic benefit Local health facilities

3 Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

Our Ref: /RU

19th June 2014

Mr Phil Baker Strategic Planning Officer South Hams Borough Council Follaton House Plymouth Road Totnes Devon PL19 5NE

Dear Mr Baker

‘OUR PLAN’ CONSULTATION

As you will be aware I act for Millwood Homes (Devon) Ltd that has a controlling interest in a number of allocated sites within the South Hams, including Allocation D1 at Townstal, Dartmouth. We note that the ‘our plan’ consultation is the first stage of plan preparation and that at this time there is no published supporting evidence base to support any new policies. Having said that at this stage it would useful to set out the issues that Millwood Homes as a representative of the development industry would like to see tackled through the emerging new plan process. These issues are as follows:

Affordable Housing – The current policy requirement for 55% affordable housing is clearly not viable. For example 11% affordable housing was found to be the maximum viable at a recent appeal in Totnes. A robust Strategic Affordable Housing Viability Study should be undertaken. Care must be taken not to fall into the trap of encouraging a high % of affordable housing thinking that this will return the highest levels of affordable housing. A lower and more deliverable level of affordable housing coupled with a realistic housing requirement will in practise deliver a steadier supply and greater overall quantum of housing and affordable housing.

Housing Requirement – I have attended 3 Local Plan EiP’s recently that have all been found unsound due to a lack of objectively assessed evidence and in particular that which informs housing supply. The PPG provides clear guidance on the production of Strategic Housing Market Assessments that we expect to be adhered to.

Hawkridge House, Chelston Business Park, Wellington, Somerset TA21 8YA Tel: +44 (0)1823 666 150 Fax: +44 (0)1823 666 631 Email: [email protected] www.wyg.com

WYG Environment Planning Transport Limited. Registered in England & Wales Number: 3050297 Registered Office: Arndale Court, Headingley, Leeds, LS6 2UJ

5 Year Housing Supply – Despite the recent Housing Position Statement produced by the Council it is clear that the Council cannot genuinely demonstrate an adequate supply of housing land. Ignoring this fact is a disingenuous barrier to the delivery of much needed housing and affordable housing.

Existing DPD Allocations – Whilst it is appropriate to review allocations, this should be an open process undertaken with development partners such as Millwood Homes that has invested significantly in bringing forward a number of allocations within the District that should not be overlooked.

Proposed Allocations – As with existing allocation, the review of newly proposed allocations should be an open process with development partners as well of course with the local communities. We look forward to hearing the timescales for when potential allocations are to be considered bearing in mind the intention is to go to EiP in February 2015. This only leaves 8 months to prepare an evidence base, consider allocation sites and carry out 2 further rounds of consultation/review. We doubt whether the February 2015 EiP target is realistic.

Employment Allocations – The Core Strategy employment allocations have not worked. One factor in this was that the DTZ report found a pre-recession total for the District and recommended that it be concentrated along the A38 corridor. The Core Strategy however chose to disperse the employment allocations evenly throughout the settlements resulting in the majority of this sites not coming forward. Again, the employment land evidence will be scrutinised heavily by the EiP Inspector that should be objectively assessed for it to be sound.

Neighbourhood Plan Preparation – The Our Plan consultation does not refer to Neighbourhood Plan (NP) preparation. Whilst NP’s can be prepared in conjunction with Local Plan’s their purpose is to decide where planned growth should occur. NP’s should therefore generally follow Local Plan preparation once factors such as the housing requirement is set.

SHLAA Process – When we spoke this week you mentioned that draft SHLAA statements will be issued to representors in the next few weeks for comment. We look forward to engaging in this process.

CIL – There is no mention of CIL in the ‘our plan’ consultation. Does the Council intend to pursue this concurrently with plan preparation?

Hawkridge House, Chelston Business Park, Wellington, Somerset TA21 8YA Tel: +44 (0)1823 666 150 Fax: +44 (0)1823 666 631 Email: [email protected] www.wyg.com

WYG Environment Planning Transport Limited. Registered in England & Wales Number: 3050297 Registered Office: Arndale Court, Headingley, Leeds, LS6 2UJ

We trust that these representations will be taken into account in consideration. We look forward to engaging with you in the preparation of the plan.

Yours sincerely Robin Upton

Robin Upton Associate Director

For and on behalf of WYG Environment Planning Transport

Cc: Mr Mike Smith, Millwood Homes

Hawkridge House, Chelston Business Park, Wellington, Somerset TA21 8YA Tel: +44 (0)1823 666 150 Fax: +44 (0)1823 666 631 Email: [email protected] www.wyg.com

WYG Environment Planning Transport Limited. Registered in England & Wales Number: 3050297 Registered Office: Arndale Court, Headingley, Leeds, LS6 2UJ From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Carol Wellwood (where relevant) Job Title: (where relevant) Organisation: Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Clear definitions of "affordable housing" related to median (not mean) Comments: local wages, and of sustainable development, which includes intra- generational justice. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

Shaping the future to 2031 Response form

For office use only All comments should be received no later than Reference number …………………...... 5.00pm on Friday 20th June 2014. Date acknowledged ......

Your details

Name Marina Auburn on behalf of

Job Title (where relevant)

Organisation Ermington Parish Council (where relevant)

Address and Telephone number Postcode

Email address

Do you think that we have identified the right topics for Our Plan? (pages 6/7)

Yes No

If you have answered “No”, please tell us what other topics you think we should consider.

The topics for the Our Plan are all encompassing; the key will be how these areas in the plan will be developed.

Do you think that we have identified the right challenges for People? (page 12)

Yes No No

If you have answered “No”, please tell us what other challenges for People you think we should consider. Need to consider:

1. Skills development for people in the South Hams to be able to adapt to new job opportunities linked to growth sectors in the district and surrounding districts (tourism, care, food/agriculture, maritime)

2. Services provision for an ageing population

3. Sustaining and developing community cohesion

Do you think that we have identified the right challenges for Place? (page 13)

Yes No NO If you have answered “No”, please tell us what other challenges for People you think we should consider.

Need to consider:

1. Business Growth and Business Creation to increase job opportunities in the South Hams

2. How people, in the near future will be able to access food – growing opportunities in the South Hams vs.

importing food and adding to food miles 3. Address affordable housing needs for local people including self-build

4. Protecting the AONB and the area’s distinctive environment and high quality landscape and heritage assets

5. Promoting regeneration of market towns and villages through sustainable development/revitalising market towns/village centres

6. Promoting Tourism

Is there anything else you think Our Plan should contain?

Yes No NO If you have answered “No”, please tell us what else you think Our Plan should cover.

 How broadband will be made available to all and upgraded so that local people can benefit from new

technology

 With regards to renewable energy, determine REAL need for renewables (vs. needs which are defined by

consultancies that promote renewables for their businesses’ benefits

Keeping in touch: If you wish to be kept informed of progress with Our Plan in South Hams, please tick here; YES PLEASE th Marina Auburn 16 June 2014 Signature Date

(A typed name is acceptable for electronic submission)

Please return this form by 5pm on Friday 20th June 2014 to:

Email: [email protected] Post: Strategic Planning Team, Follaton House, Plymouth Road, Totnes, TQ9 5NE

For any enquiries please call 01803 861234

To keep up to date with Our Plan progress, follow us on Twitter @OurPlanSH, find us on Facebook (www.facebook.com/ourplanSH) our visit our website www.southhams.gov.uk/ourplan

Data Protection Please note that comments cannot be treated as confidential and may be made available for public inspection at the Council offices and available to view on the Council’s website (www.southhams.gov.uk). Your personal information will be held by South Hams District Council for the above purpose, in accordance with the Data Protection Act 1998 and will be held securely at all times.

Our Ref: /AJB

20th June 2014

Mr Phil Baker Strategic Planning Officer South Hams Borough Council Follaton House Plymouth Road Totnes Devon PL19 5NE

Dear Mr Baker

‘OUR PLAN’ CONSULTATION

WYG act for Persimmon Homes (SW) Ltd that has a controlling interest in a number of sites within the South Hams, including at Old Newnham, Plympton. We note that the ‘our plan’ consultation is the first stage of plan preparation and that at this time there is no published supporting evidence base to support any new policies. Having said that at this stage it would useful to set out the issues that Persimmon Homes as a representative of the development industry would like to see tackled through the emerging new plan process. These issues are as follows:

Housing Requirement – WYG have attended 3 Local Plan EiP’s recently that have all been found unsound due to a lack of objectively assessed evidence and in particular that which informs housing supply. The PPG provides clear guidance on the production of Strategic Housing Market Assessments that we expect to be adhered to.

Hawkridge House, Chelston Business Park, Wellington, Somerset TA21 8YA Tel: +44 (0)1823 666 150 Fax: +44 (0)1823 666 631 Email: [email protected] www.wyg.com

WYG Environment Planning Transport Limited. Registered in England & Wales Number: 3050297 Registered Office: Arndale Court, Headingley, Leeds, LS6 2UJ

5 Year Housing Supply – Despite the recent Housing Position Statement produced by the Council it is clear that the Council cannot genuinely demonstrate an adequate supply of housing land. Ignoring this fact is a significant barrier to the delivery of much needed housing and affordable housing.

Proposed Allocations – The review of newly proposed allocations should be an open process with development partners as well of course with the local communities. We look forward to hearing the timescales for when potential allocations are to be considered bearing in mind the intention is to go to EiP in February 2015. This only leaves 8 months to prepare an evidence base, consider allocation sites and carry out 2 further rounds of consultation/review. We have strong reservations as to whether the February 2015 EiP target is realistic.

SHLAA Process – We understand that draft SHLAA statements will be issued to representors in the next few weeks for comment. We look forward to engaging in this process.

CIL – There is no mention of CIL in the ‘our plan’ consultation. Does the Council intend to pursue this concurrently with plan preparation?

We trust that these representations will be taken into account in consideration. We look forward to engaging with you in the preparation of the plan.

Yours sincerely Alex Bullock

Alex Bullock Senior Planner

For and on behalf of WYG Environment Planning Transport

Cc: Mr Shaun Pettitt, Persimmon Homes (SW) Ltd

Hawkridge House, Chelston Business Park, Wellington, Somerset TA21 8YA Tel: +44 (0)1823 666 150 Fax: +44 (0)1823 666 631 Email: [email protected] www. wyg .com

Dear Mr Baker and Ms Black

Thank you for inviting the RSPB to comment on the above; I hope these brief comments are helpful.

DO YOU THINK WE HAVE IDENTIFIED THE RIGHT TOPICS FOR `OUR PLAN’ – No, please see comments below on improving the biodiversity protection/enhancement content: We are concerned there is little reference to biodiversity (wildlife/nature) and no mention of the District’s internationally and nationally important biodiversity sites and species. For example, South Hams hosts a significant proportion of the UK’s greater horseshoe bat (a European protected species) and cirl bunting (a priority species) populations. The District has part of the European protected site, the Plymouth Sound and Estuaries SAC, and several estuaries that are nationally important and protected. These require safeguarding from developments, including on land, that may have indirect effects on their wildlife value. `Our Plan’ should highlight the region’s special biodiversity, including the statutorily protected and other important wildlife sites, and set out strong policies for appropriate protection and enhancement of these, and similar recognition and protective policies for the District’s priority habitats and species.

To this end, we do not consider that the `Our Nature’ list properly reflects the District’s biodiversity resource, because it does not mention European protected or priority habitats and species. Also we recommend that the reference should be to “Designated and protected wildlife habitats and landscapes”. In our view, protecting and enhancing biodiversity should be one of the big challenges of `Our Plan’; it is closely linked with the quality of life of people as well as an integral part of the special qualities of the South Hams (so important for People and Place).

With regard to cirl buntings, this sedentary bird of mixed farmland comes under pressure from built development, particularly because it chooses often to live around the margins of settlements which are often the target of new built development. Nationally important numbers are present in the District but most of the population is not protected by site designation. It is important to safeguard the existing numbers and range of this species as well as promoting further recovery (the species was once found across southern England and parts of Wales, and now, despite some population recovery, is still confined mainly to coastal south Devon). There is an important role for South Hams District Council in this, both in targeting new development away from sites that support important numbers of this species and, where development occurs that results in a loss of some cirl bunting habitat, requiring appropriate mitigation (which can include provision of off‐site replacement habitat adjacent to the development or, where adjacent provision is not possible, a financial contribution from the developer to be used by the Council to fund the acquisition and management of habitat for cirl buntings elsewhere in the local area. The RSPB has worked with Teignbridge District Council and an agreed process has been applied successfully for those developments where loss has been unavoidable. We can supply more information.

The Council has obligations under the National Planning Framework and the NERC Act 2006 to protect and enhance biodiversity and `Our Plan’ needs to reflect these both in terms of conserving existing biodiversity and furthering its recovery and enhancement.

We believe that there is sufficient evidence to suggest that good design of the public domain and "greening the built environment" is essential to mitigate the implications of climate change and enhance the health and wellbeing of the resident population as well benefiting the natural flora and fauna. 1

With regard to the section `Our Wellbeing’, we recommend that contact with nature is an important component; research has shown that people’s mental and physical wellbeing is enhanced by experiencing wildlife – this is both in the context of being outside in a nature‐rich countryside and being able to see wildlife day to day in more urban environments (so new housing developments should incorporate nesting sites for swifts and have green spaces that support invertebrates, flowering plants, etc).

DO YOU THINK THAT WE HAVE IDENTIFIED THE RIGHT CHALLENGES FOR PEOPLE? A missed opportunity to highlight the value of the natural environment: People – please include the importance of the natural environment here. Wildlife‐rich places and access to these encourages healthy lifestyles, they are also part of the economic value of an area in terms of its attractiveness for people and businesses.

DO YOU THINK THAT WE HAVE IDENTIFIED THE RIGHT CHALLENGES FOR PLACE? No, need to specifically recognise the importance of wildlife. Place – please include the need to protect and enhance (restore) biodiversity, so `Protecting and enhancing our natural landscapes, habitats and species’. Targeting of development (including housing and renewable energy) is important to avoid damaging impacts to important places for wildlife or populations of species. There are also opportunities with properly targeted developments to provide enhancements. The presence of wildlife (habitats and species) is part of what makes an area special. Green infrastructure can provide opportunities for wildlife, enhance an area’s value for people and also help with mitigating the effects of climate change (eg, SUDS to absorb surface water instead of hard‐surfaces that increase flood risk).

The RSPB can provide more detail on request/at later stages of the consultation process.

Helene

Helene Jessop, Assistant Conservation Officer South West England Regional Office, Keble House, Southernhay Gardens, Exeter, Devon, EX1 1NT rspb.org.uk

The RSPB is the country’s largest nature conservation charity, inspiring everyone to give nature a home. Together with our partners, we protect threatened birds and wildlife so our towns, coast and countryside will teem with life once again. We play a leading role in BirdLife International, a worldwide partnership of nature conservation organisations.

The Royal Society for the Protection of Birds (RSPB) is a registered charity: England and Wales no. 207076, Scotland no. SC037654

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: John Stansell (where relevant) Job Title: Chairman (where relevant) Organisation: Wembury Parish Council Address: Roy Fairclough, Clerk Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Comments: See final section Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Comments: As above Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Comments: Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). What South Hams needs

1. More employment – in innovative, productive, sectors as well as traditional ones of agriculture and tourism, commerce, retailing, Comments: construction and services 2. Focussed educational institutions – whose aim is to educate young people so that they want to stay in the area and start, or work in, new profitable businesses and efficient public services 3. More housing – to accommodate younger, aspirational people with the

1 means and energy to build, buy or develop new housing while improving the utilisation of existing properties (including unused homes), plus social housing and market affordable housing 4. Better infrastructure – energy, roads, rail, telecoms, broadband, water supplies, sewage treatment, airports, environmental management 5. Better welfare and health services catering to every sector of the community 6. Efficient, people-focussed, local authority services designed to approach and manage the types of problems, challenges and conditions experienced in 2014 and onwards

These major areas for action need to be broken down into the key constituent parts and analysed by professionals to decide on priorities and realities. For example, it is implausible to endeavour to attract high tech (high revenue generating) businesses into the South Hams unless there is a supply of suitable people, adequate (or good) infrastructure and a minimum of red tape. Studies of how places such as Cambridge and more recently London have become centres of excellence in high tech businesses should be used to create plans to use the strengths of local institutions – marine, biological, agriculture, electronic and political analysis—to emulate their success in bringing talent and revenue into the region.

Many people in South Hams – such as residents, politically motivated people and local authority insiders -- will probably say these are not achievable objectives due to existing practices, employment terms and conditions, lack of availability of funds and of people who really wish to see change. But all successful institutions and companies have been led by people who had the vision and determination to see their ambitious plans through to fruition, despite the doubts and problems that faced them. We hope that our leaders in South Hams have that same vision and determination.

We think that the structure of “Our Plan” – even though it covers in detail more than the areas for action mentioned above – is about re- enforcing the status quo for another 15 years, not creating a new vision. We urge both the elected representatives and the officials of SHDC to reshape their outline plan to project a much more profitable future for the district so that all its residents have a better chance to improve their lives.

Authors: John Stansell, Janet Gibbons, Andy Cammack, Wembury Parish Councillors Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

2 From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Oliver Tringham (where relevant) Job Title: Chairperson (where relevant) Organisation: Dartington Community Action Group Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics No If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). Our Homes: • Building houses in places that encourage synergy between services e.g. railway stations, bus routes etc. • Innovative collective design, & new models to meet future needs. • Policy for dealing with second homes (extremely destructive), • Local housing affordable for young people as well as meeting the needs of local elderly & special needs. • Well-designed sustainable homes, avoiding future fuel poverty • Smaller more organic growth in house-building rather than ‘fields of houses’

Our Economy: • Farming, agriculture, horticulture, allotments that support the domestic economy & community development. Comments: • Complementary economies such as bartering, local currencies & exchange for people on low budgets. • Local branding for quality food production. • Support for local food products – market place development, new distribution networks (eg food boxes) • Revitalising former economic systems, such as cider industry, that requires local orchards, heritage species of trees. • Living Wage.

Our Heritage • Support for heritage buildings that retain the integrity of the building & its curtilage, with options for improvements to improve energy efficiency & comfort, & maintaining the fabric of the building, eg double glazing, insulation

1 Our Communities • Amenities including community centres, libraries, youth centres, day care centres, play areas, community gardens, orchards & allotments. • Community development that nurtures education, cultural vibrancy & local distinctiveness. • Support for communities of interest such as local heritage, spies, old sailors etc.

Our Nature • Ensure support for habitats & protection for SACs. • Supporting local seed banks • Protection & nurturing for local & distinctive habitats such as Devon Banks, woodlands, rivers, estuaries & the coastline. • Support biodiversity & natural habitats; develop community orchards & gardens. • Support organic farming; ban dangerous pesticides & GMOs

Our Resources • Local food production • Energy production • Revitalise local water supplies, • Synergistic systems for maximum efficiency, eg Anaerobic digestion of sewage & compostable waste providing gas for community buses. • All car parks to have solar PV panels • Ban Fracking • Conduct research into best practice

Our Wellbeing • Faith communities, intergenerational networks • Local access to all public services including healthcare facilities • Holistic healthcare, ie. including access to peaceful & green spaces; affordable activity centres for all age groups. • Reduced exposure to noise & white-light pollution • Permit access to the countryside

Infrastructure • Transport hub Park & st/rides • Sustainable transport systems & networks • Sustainable localised waste management amenities & network that supports local recycling & associated economic benefit • Local health facilities Do you think that we have identified the right challenges for People? (page 7) Challenges No If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). Challenges for People should include…

• Encouraging young people & families • Supporting educational & cultural needs beyond the classroom • Inclusive policies that prevent people from feeling excluded due to reduced economic circumstances, cultural differences or other marginalisation. Comments: • Encouraging & supporting innovation • Encouraging visitors & tourism • Providing local Leadership to support local resilient communities in times of change • Offering apprenticeships • Building community engagement & supporting localism • Support research into best practice Do you think that we have identified the right challenges for Place? (page 7) Place No If you have answered 'No', please tell us what other challenges for Places you think we should consider (in 2 less than 3000 characters). Challenges for Place should include… • Community transport, cycle networks, electronic charging points (at car parks via PV panels) • Sustainable transport • Enabling a greater diversity of affordable & social housing such as Co-housing, multiple shared houses, houseboats, innovative eco-houses, etc. • Reducing climate change through prioritisation of energy efficiency • Local production of renewable energy through solar panels on roofs Comments: – rather than on green fields, & water & wind turbines • Waste management that promotes the waste hierarchy, reduction, reuse & supports local economic development through local recycling etc. • Avoidance of unnecessary journeys for delivery of public services, e.g. healthcare, local recycling of waste. • Attractive town & village centres that nurture local distinctiveness • Improvements to public & community transport links • Joined up systems for biodegradable waste to produce local energy supplies (through anaerobic digestion) Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Our Vision assumes growth: this assumption is not shared by DCAG.

Our Vision should include… • Sustainable settlements with infrastructure & support for community development in revitalised parishes & villages (rather than increasing Comments: urban sprawl). • A comprehensive l& use strategy that makes better use of existing buildings & includes support for farming, renewable energy, wild spaces, food growing, & community amenities. • Revitalised & resilient village & town centres with thriving Post offices, market places, village greens, & public amenities. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

Strategic Planning South Hams District Council Follaton House Our ref: AONB/RE Plymouth Road Your ref: Date: 20th June 2014 Totnes TQ9 5NE

Dear Jo,

“Our Plan” Consultation

On behalf of the South Devon AONB Partnership I am writing to you in response to the current consultation on the South Hams ‘Our Plan’.

The purpose of the response is two fold:

1. The statutory duty to have regard to the purpose of AONB designation should be fully incorporated into the plan and subsequent decision making

“Our Plan” needs to emphasise the significant importance of the South Devon AONB and recognise the environmental, economic, social and heritage benefits of the designated area to the South Hams. The Council has a specific duty under s85 of the Countryside and Rights of Way Act 2000 to have regard, in all its activities, to the purpose of

“…conserving and enhancing the natural beauty of the AONB”

“Our Plan” needs to assess, embed and monitor this duty throughout policies and actions. Planning related policies need to be strong and robust in relation to the AONB. Throughout “Our Plan”, full regard needs to be given to the recently adopted “South Devon AONB Management Plan 2014-2019” which helps to translate the s85 CROW Act duty and illustrate what it means in the context of the South Devon AONB. The South Devon AONB Management Plan formulates the policies of its local authorities for the management of the Area of Outstanding Natural Beauty and for the carrying out of their functions in relation to it.

2. Offer of active involvement of the AONB Partnership and AONB Unit in the development of Our Plan

The AONB Partnership has a clear remit set out in its terms of reference and constitution to provide a strategic lead on the protection, conservation and enhancement of the South Devon AONB. The Partnership Committee comprises representatives of local and statutory authorities

and elected community representatives and the work programme of the AONB Unit is set by the partnership.

Both the Partnership and Unit see “Our Plan” as a key document that will sit alongside the AONB Management Plan in delivering the statutory duty to conserve and enhance the AONB.

The AONB Partnership has expressed a wish to have a close involvement in the development of “Our Plan” and requests that the AONB Unit be kept fully involved in the development of policies within the plan.

Yours sincerely,

Roger English South Devon AONB Project Officer

From: Strategic Planning Subject: Our Plan Response SH

Our Plan Response SH

Your details Name: Leaf Lovejoy (where relevant) Job Title: N/A (where relevant) Organisation: N/A Address: Please enter the post code in the following format PL21 0PP Post code: Contact number: Email: Your thoughts Do you think that we have identified the right topics for Our Plan? (page 4) Topics Yes If you answered 'No', please tell us what other topics you think we should consider (in less than 3000 characters). My answer above was yes; it is important to me to appreciate SHDC's efforts to represent topics and issues that can be addressed by growth. Acknowledgement that many appropriate topics have been identified should not seem to be seen as an alternative to proposing other topics. At this scoping stage SHDC might usefully indicate the strategies and techniques used to identify the indicated proposed topics and issues. Visions of good futures and steps to achieve them can be developed without projecting Comments: present concerns onto the future in sets of disparate topics and issues. SHDC's vision as presented on pp 6-7 seems to take for granted that South Hams community members agree both with the aim of growth, and the priorities and challenges identified by SHDC. It would have been very helpful to know if challenges and constraints for local plans have been actually prescribed by central government. Envisioning, backcasting and feedforward might have identified other issues in a coherent view of South Hams future place and people. Do you think that we have identified the right challenges for People? (page 7) Challenges Yes If you answered 'No', please tell us what other challenges for People you think we should consider (in less than 3000 characters). SHDc has identified some challenges which face all communities in a world in which population demographics change over generations (and by the way the header 'People' seems to occur only on p 12). However, the topics agenda seem to have been prompted by and effectively be a mixture of tabloid headlines and list of government policy initiatives, that seems to Comments: apply more or less everywhere. I do appreciate that this is a scoping exercise, but the scope as presented seems set by someone somewhere else. There is little evidence that already existing local features and initiatives could provide a joined up approach to scoping (fi, transition and community initiatives). 1 Do you think that we have identified the right challenges for Place? (page 7) Place Yes If you have answered 'No', please tell us what other challenges for Places you think we should consider (in less than 3000 characters). Same as above for people. And by the way, 'shaping the community' isn't an appropriate aim, as it puts the cart before the horse, approached from the wrong direction. The district community (of which we are all members, Comments: therefore which already exists prior to any plan, or indeed to any local authority devising a plan, as all of us are people in this place, shapes the plan, through participation, engagement and involvement, if this works well, or through disengagement, alienation and cynicism. Is there anything else you think Our Plan should contain? Additional Yes If you answered 'Yes', please tell us what else you think Our Plan should cover (in less than 5000 characters). Please note that this question is in fact the first invitation to responders to contribute to the scoping, which doesn't put the responder into the the position of having to seem to criticise what has been written simply in order to propose additional ideas. Please don't underestimate the perverse incentive to just agree ('yes') so as not to seem to grumble, complain, find fault or criticise'.

As noted already, it seems vital to propose possible solutions already existing even inchoately, as it is solution-focussed invitations that can get people involved. In the foreword, new technology is put forward as a Comments: means to wider engagement. Only if it really promotes flexibility in response. This form really doesn't.

As already noted, the various categories of topic and issue identified seem either state the obvious, or are too grandiose and general to inspire easy engagement. Most of this I have already registered with James and Graham in telephone conversations, and other issues have arisen about the role of development, housing, infrastructure, green, blue, grey and social, as community services and facilities. As this has run past the deadline, it isn't clear to me whether it can still be sent. However, I will copy and paste and send in an email. Keeping in touch Would you like to be kept informed of prgress with Our Plan? Updates Yes Data Protection

South Hams District Council - Our Plan Consultation

Response made of behalf of The Flete Estate

June 2014

smiths gore .co.uk

Project: Our Plan Consultation Response

Client: The Flete Estate

Job Number: 1037359

File Origin: External

Document Checking:

Prepared by: Mark Richards Signed:

Checked by: Steve Briggs Signed:

Verified by: Steve Briggs Signed:

smithsgore.co.uk

Contents

Page No

1.0 Introduction ...... 1

2.0 Local Plan Preparation – Tests of Soundness ...... 2

3.0 Preparing the Plan ...... 3

4.0 Our Homes ...... 4

5.0 Our Economy ...... 10

6.0 Future development in Holbeton ...... 13

APPENDIX A – RTPI Research Briefing No. 3

APPENDIX B – Inspector’s letter re. East Devon Local Plan

1.0 Introduction

1.1.1 This consultation response has been prepared by Smiths Gore on behalf of The Flete Estate. The response has been prepared following an invitation from South Hams District Council to comment on its ‘Our Plan’ consultation document.

1.1.2 The Flete Estate is a significant owner of land, property and woodland in South Hams, particularly in Holbeton and the surrounding area. The Estate considers its stewardship of the natural and built environment to be a key responsibility and has carried out this role for generations.

1.1.3 The Flete Estate also feels a strong sense of responsibility for the community in the local area which comes from its longstanding relationship with it, particularly in Holbeton. In an area where owner occupation is dominant the Estate provides and alternative tenure through its portfolio of let properties. The Estate also makes an important contribution to the local economy by directly employing local people, providing workspace for local businesses and by attracting visitors to the local area. Further contributions from the Estate can be seen through the provision of community facilities such as village orchards, allotments and the post office.

1.1.4 The Estate is keen to ensure that the social, economic and environmental needs and desires of the local community are met over the coming plan period. It is therefore keen to ensure that the policies set out in the ‘Our Plan’ support, rather than constrain the development that the local community (and indeed the wider district) requires to meet their needs.

1.1.5 The sections of the consultation document to which the comments relate are clearly identified by sub-headings.

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2.0 Local Plan Preparation – Tests of Soundness

2.1.1 Before Local Plans can proceed to adoption, they must be found sound by an independent Inspector at Examination. To be found sound Local Plans must accord with certain tests which are outlined within the National Planning Policy Framework (the Framework). A sound Plan is described in paragraph 182 of the Framework as being:

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2.1.2 This consultation response has been prepared with these tests in mind and specific comments will be made as to the approach the Council should take in forming the policies for the new ‘Our Plan’.

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3.0 Preparing the Plan

3.1.1 On page nine of the consultation document there is a diagram which sets out the Council’s proposed timeline for preparing the ‘Our Plan’.

3.1.2 The Flete Estate is pleased to see that the Council is committed to work with local communities and other stakeholders to explore different options for responding to the district’s various challenges. However, the Estate is concerned to see that the Council will then undertake only one further round of public consultation on the ‘Proposed Plan’ before submitting it for examination.

3.1.3 This effectively means that the Council’s first draft of the ‘Our Plan’ will be the version that is submitted for examination. It also means that the Council will not be able to make any meaningful amendments to the ‘Proposed Plan’ to take account of comments made by the public and other consultees before it is submitted for examination. Inevitably the result will be that the Plan will be submitted for examination with unresolved objections which could jeopardise its chances of being found sound. If the Plan is found to be unsound its adoption could be significantly delayed, leaving the Council vulnerable speculative applications and ‘planning by appeal’.

3.1.4 It is therefore strongly recommended that, before preparing the final version of the Plan the Council should first prepare and consult upon a draft version. This will give interested parties an opportunity to identify aspects of the Plan which they support or to raise objections to policies they disagree with. The Council can then use this feedback to make amendments to the Plan where appropriate before preparing the final version to be submitted for Examination. In this way the Plan will stand a far better chance of being found sound and proceeding to adoption.

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4.0 Our Homes

4.1 Future housing numbers

4.1.1 The Flete Estate is pleased to see that the Councillor John Tucker (Leader of South Hams District Council), in the ‘foreword’ to the consultation document, recognises that one of the biggest challenges for the district is enabling growth and providing much needed homes. This challenge is then reiterated on page 10 of the document where it states that “we have a sustained need for more market and affordable housing”.

4.1.2 At this stage the Plan does not provide any indication of what the district’s housing target will be for the coming plan period or how future homes will be distributed across the district. This response therefore sets out the principles to be applied by the Council when preparing its strategy on this matter.

4.1.3 One of the Government’s key objectives is to significantly boost the supply of housing in order to meet growing need. This objective is embedded within national planning policy as set out in the National Planning Policy Framework (Framework) and Local Plans must be prepared in accordance with this Framework.

4.1.4 Paragraph 14 of the Framework sets out the Government’s presumption in favour of sustainable development. This specifically states that “Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change”. Paragraph 17 goes on to state that “every effort should be made objectively to identify and then meeting the housing, business and other development needs of an area”. This paragraph goes on to state that Plans should “set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities”.

4.1.5 This approach is reinforced in chapter 6 of the Framework which deals specifically with delivering new homes. Paragraph 47 states that local planning authorities should “use their evidence base to ensure their Local Plan meets the full, objectively assessed needs for market and affordable housing”.

4.1.6 According to National Planning Policy Guidance (NPPG) the starting point for establishing the estimated need for housing should be the household projections published by the Department for Communities and Local Government (DCLG) which are based on trends observed in Census and Labour Force Survey Data. However, even this data should be used with caution. New research suggests that using the 2011 census data to assess future housing needs could result in Councils underestimating housing need by up to 30%. This potential deficit has been identified in a RTPI commissioned

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study carried out by the University of Cambridge’s Centre for Housing and Planning Research. There report, which is provided in appendix A, states that:

“There are two reasons why the trends that have been projected forward in the official projections may not continue unchanged. Firstly, increased international migration in the first decade of this century may have been responsible for a significant proportion of the changes to previous trends in household formation patterns. Secondly, it seems likely that the 2011 census results were influenced by both the economic downturn and the effects of a long period of poor housing affordability. This raises the question of whether planners should assume that household size will remain stable or resume the previous falling trend. For some authorities, this could affect the number of homes required by 30% or more.”

4.1.7 On the basis of this evidence it is likely that the Council will need to set a housing target for the district over and above that which is suggested by the 2011 census data.

4.1.8 Of course, the Council will set a housing target which is based on its own assessment of housing need. However it is important to bear in mind that all evidence used by the Council in determining the proposed housing target will be rigorously assessed and tested. If this evidence is found not to be sufficiently robust the plan will be found unsound and will delay its adoption, leaving the Council vulnerable to ‘planning by appeal’. It is important to note that the vast majority of Local Plans rejected at examination are due to the fact that their housing targets are too low and do not meet the projected growth in households, i.e. the full, objectively assessed needs. This point is emphasised by the recent example of the examination of East Devon District Council’s Local Plan, which was found to be unsound as the housing target was considered to be unjustified (see Inspector’s letter in appendix B). Furthermore the Inspector specifically referred to the validity of choosing low migration models when other supporting documents lean towards higher figures.

4.2 Rural housing

4.2.1 In smaller rural communities the key issue is often whether those with a strong local connection, either because they grew up and/or work there, can have the opportunity of affording a home to rent or buy in that community. In these settlements it is decisions about small scale development schemes that are of key importance and are crucial to the sustainability of those communities. Although it is of course crucial to conserve the character of these settlements and their wider rural settings, if planning policies are too restrictive then local housing and employment needs will not be satisfied. As a result, certain groups of people, namely the young, especially young

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families, and those working on relatively low wages, will continue to find it difficult to afford to rent or buy properties on the open market, or find an appropriate affordable non market alternative. This has been the experience in the South Hams district where average house prices have increased on average by 91.6% whereas the average weekly wage has only increased by 25.5%. As a consequence local people are effectively being priced out of their own communities and this kind of exclusion undermines the sustainability of rural communities. This is a significant issue which can only be addressed by increasing the supply of new homes (both open market and affordable) that are delivered over the coming plan period. This must therefore be a key objective of the emerging Plan.

4.2.2 All too often Local Plans take the overly simplistic view that a settlement should have access to ‘x’ number of facilities and services in order to be deemed a sustainable location for development. This simplistic approach is considered to be flawed as it fails to recognise the complex inter relationships that exist between settlements which should be considered together in a holistic way. A small settlement may have limited access to services and facilities when considered in isolation but may actually demonstrate more sustainable patterns of living and working when you take account of its shared functional relationship with surrounding settlements. For example one settlement may have a primary school, another might contain employment units, whilst a third may be the centre of social life with a community hall and active local clubs and societies. Any or all may be appropriate locations for modest housing and economic development on the basis that all combine to provide a sustainable community life.

4.2.3 This view is supported with the recently published National Planning Practice Guidance (NPPG), which emphasises the importance of providing sufficient housing growth in rural areas. The NPPG is an important material consideration when preparing Local Plans and considering development proposals. The following is an extract from paragraph 001 of the NPPG section on rural housing.

“It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements. This is clearly set out in the National Planning Policy Framework, in the core planning principles, the section on supporting a prosperous rural economy and the section on housing.

A thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Rural housing is essential to ensure viable use of these local facilities.

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Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However, all settlements can play a role in delivering sustainable development in rural areas – and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence. [own emphasis]

4.2.4 The Flete Estate would also encourage the Council to avoid relying on the concept of ‘settlement boundaries’ to determine whether or not a development proposal is considered to be sustainable. It is entirely inappropriate that a judgement should be made on the sustainability of a proposal based solely on whether it is positioned on the correct side of an arbitrary line. In fact by taking this approach, no ‘judgement’ is made at all. Rather development proposals should be judged on their planning merits, weighing the benefits against the harm, taking account of the three dimensions of sustainability set out in paragraph 7 of the Framework.

4.2.5 Allocating sites for residential development in rural areas

4.2.6 South Hams District Council currently has an adopted ‘Rural Areas Site Allocations Development Plan Document’ (RASADPD). The purpose of this document was to enable the delivery of sustainable housing growth in the district’s rural settlements.

4.2.7 The Flete Estate would strongly encourage the Council to adopt this approach again as part of the emerging Plan. However one criticism of the current RASADPD is that it was prepared without undertaking sufficient consultation with local communities and landowners. The result of this is that a number of the sites which were allocated for development in the RASADPD often did not reflect local preferences and in some cases did not present viable development opportunities - as was the case in Holbeton.

4.2.8 As the principal landowner in Holbeton the Flete Estate is conscious that it has an important role to play in helping to meet local housing and other community needs in the village. The Estate is therefore keen to work closely with South Hams District Council, and indeed other relevant stakeholders to ensure that the development needs of Holbeton are provided for in a sustainable manner and in a way which secures real benefits for the village.

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4.2.9 Converting rural buildings to residential use

4.2.10 Traditional rural buildings make a fundamental contribution to the richly varied character of South Hams’ rural building stock, landscape and local distinctiveness. They illustrate a long history of farming and settlement and exemplify the crafts and skills associated with local building materials and techniques. However significant structural changes which have taken place in the farming industry over the last century have led to the construction of new buildings that economise on labour and conform to animal welfare regulations. These changes have resulted in many of the district’s traditional buildings becoming redundant. To prevent such buildings from falling into disrepair and indeed to prevent their demise as part of the wider rural landscape, it is important that they are given a new and viable use so that heritage assets can be retained and appreciated long into the future.

4.2.11 The South Hams district has many redundant buildings with the potential to be converted to alternative uses and these have the potential to play an important role in meeting housing needs over the coming plan period.

4.2.12 The principle of allowing traditional rural buildings to be converted to residential use is established in paragraph 55 of the Framework which sets out a number of ‘special circumstances’ under which new isolated homes in the countryside should be considered acceptable. These include:

• where such development would represent the optimal viable use of a heritage asset or would be appropriate enabling development to secure the future of heritage assets; or

• where the development would re-use redundant or disused buildings and lead to an enhancement to the immediate setting.

4.2.13 As such there is no longer a requirement to explore alternative uses for rural buildings before residential use can be considered.

4.2.14 The principle of residential conversion schemes has subsequently been reinforced by the new Permitted Development rights which allow such conversions to take place without planning permission in certain instances.

4.3 Affordable housing

4.3.1 The Flete Estate acknowledges that there is a significant shortfall in the supply of affordable housing in South Hams and is pleased to see that this is identified in the ‘Our Plan’ consultation document as a challenge to be addressed over the coming plan period.

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4.3.2 However, in setting policies for addressing affordable housing needs across the district, the Council must ensure that the issue of development viability is carefully considered. This is a requirement which is set out in the Framework which places a great deal of emphasis on the need for local planning authorities to pay careful attention to viability in plan making and decision taking to ensure that Local Plans are deliverable. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, housing mix, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable.

4.3.3 Paragraph 174 then goes on to explain that the cumulative impacts of these standards and policies should not put implementation of the plan at serious risk and should facilitate development throughout the economic cycle. It is important the local planning authorities take this guidance into account in preparing the ‘Our Plan’ as consideration of overall viability is part of the evidence base which will be subjected to test, challenge and debate when it is eventually examined. Demonstrably failing to consider this issue will almost certainly result in the Local Plan being found to be unsound.

4.3.4 Paragraph 47 of the Framework states that local planning authorities must ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing. When considering affordable housing need, it is important to recognise that this need goes beyond just the ‘social rented’ and ‘intermediate housing’ tenures (for which there is now very limited funding) which local authorities have historically sought to provide.

4.3.5 When assessing needs for affordable housing the Council must consider the full range of housing tenures including affordable rent, part ownership, low cost, self-build and so on. The Council needs to have a robust understanding of need for all types of affordable housing as part of its evidence base.

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5.0 Our Economy

5.1 Supporting the Rural Economy

5.1.1 Historically opportunities for rural businesses have not been adequately supported in South Hams. The consequence of this is that rural communities have been unable to fulfil their economic potential. The ‘Our Plan’ consultation document recognises that some of the challenges that face the district include the trend of out-migration of young and working age people and a decrease in the number of full-time workers. As such the new Plan should be treated as an opportunity to enable rural businesses to deliver more for local economies.

5.1.2 Strong rural economies offer those living in rural areas better opportunities to work in their local community. They help reduce the level of out-migration of young people and retain skilled graduates by providing more and better quality local employment opportunities. Being able to live and work in the same place also helps to deliver the Government’s other sustainability objectives because working closer to home reduces the need to commute long distances to work which reduces harmful vehicle emissions. This is particularly the case with ‘live-work’ developments.

5.1.3 In seeking to support the rural economy in South Hams the Council must have regard to the Framework, which states at paragraph 28 that planning policies should support economic growth in rural areas in order to create jobs and prosperity. The Framework identifies a number of ways in which a strong rural economy can be promoted:

• Through support of sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and enterprise in rural areas, both through conversion of existing buildings and well- designed new buildings .

• Promotion of the development and diversification of agricultural and other land based rural businesses.

• Support for sustainable rural tourism and leisure developments that benefit businesses in rural area, communities and visitors, which respect the character of the countryside.

• Promotion of the retention and development of local services and community facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.

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5.1.4 The Framework also provides a useful reference within paragraph 25, which explains that a sequential approach for the location of small scale rural offices or other small scale rural development should not be applied.

5.1.7 Therefore, in order to be compliant with the Framework, South Hams District Council is strongly encouraged to provide a policy framework which is supportive of sustainable economic development in rural areas.

5.2 Potential for live-work units

5.2.1 Fuelled by the impact of new technology (such as improved internet access in rural areas), a growing frustration with the stress and time wasting associated with the daily commute and a desire for a better work/life balance, self-employed people in rural areas are increasingly choosing to opt for home-working. In fact this is now a well- established trend with live-work units being delivered through both new build and conversion schemes. Both should be supported in local planning policies.

5.2.2 This type of development is specifically supported within paragraph 21 of the Framework which states that local planning authorities should “facilitate flexible working practices such as the integration of residential and commercial space within the same unit”. The Council is therefore strongly urged to support this form of development within the Our Plan; an approach which is being taken up by many other local authorities in the south west and nationally.

5.2.3 Across the South Hams countryside there is a significant supply of buildings, traditional and more modern, which are well suited to providing this type of live-work arrangement. The conversion of rural buildings and construction of new build to establish a live-work arrangement offers a wide range of benefits, not only to individuals and their businesses, but also to the wider economy and environment as well.

5.2.4 In May 2013 the Trade Union Congress (TUC) published an analysis of the number of people working from home in the UK. This analysis found that the number of people working from home has increased by 13% in the last five years. Just over four million employees usually worked at home in 2012, a rise of 470,000 since 2007. The Office of National Statistics (ONS) also reported an increase in the level of home working, based on 2011 census data, and attributes this increase to a greater prominence of home businesses in rural areas. Furthermore, the Annual Population Survey 2010/2011 carried out by the ONS identified working from home as being more common in rural areas of England than in urban areas.

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5.2.5 Over recent years the principle of live-work units within the countryside has become more acceptable as a means of promoting the sustainable re-use of existing buildings. Such schemes are inherently sustainable as they help to meet local demand for housing (socially sustainable) and they provide local employment opportunities (economically sustainable). They also serve to reduce the need to travel by car by removing the need for a daily commute and also safeguarding the character and appearance of rural buildings which might otherwise fall into disrepair (environmentally sustainable).

5.2.6 The local planning authority is therefore strongly encouraged support live-work developments within the emerging Plan.

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6.0 Future development in Holbeton

6.1.1 Holbeton is a village located to the west of the River Erme in South Devon. The settlement is located approximately half way between Yealmpton and Modbury, approximately 1.5 km south of the A379. Despite the small size of the village it offers a range of community facilities including a primary school, post office / stores, village hall, two pubs, a church, allotments, a community orchard and a children’s play park. As such the village acts as a community hub to other small rural communities in the local area.

6.1.2 The continued existence of these community facilities cannot be taken for granted. Each of them require a critical mass of local people to provide the children for the school, the throughput for the shop and post office, the clientele for the pub, the support for the church and the people to run the various village enterprises and organisations. At present all of these are operating at below their optimum throughput and some, including the school, local shop and post office are on the verge of becoming unviable. To ensure the future viability of these services and facilities the village needs to be allowed to grow, however this must happen in a sustainable manner.

6.1.3 The Flete Estate has already begun the process of consulting with the local community and the district Council on the matter of how and where new development could be brought forward in the village. Through this process of engagement it has also been possible to identify additional community needs/ambitions of the village including a new village hall and a village car park. As such the Estate is committed to facilitating the delivery of these community assets through future development in the village.

6.1.4 The Flete Estate is keen to continue to work closely with the local planning authority and indeed the local community in bringing forward sustainable development in Holbeton which meets social, environmental and economic needs of the village.

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APPENDIX A

RTPI Research Briefing No. 3

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APPENDIX B

Inspector’s letter re. East Devon Local Plan

smiths gore .co.uk

Smiths Gore Taunton Office t 01823 445030 f 01823 445031 [email protected]

smiths gore .co.uk

RTPI Research Briefing No. 3 January 2014

Planning for housing in England

The 2011 census raises big issues for There are two reasons why the trends that planners. In particular, it shows that average have been projected forward in the official household size did not fall as expected projections may not continue unchanged. between the censuses but stayed constant. This is probably because the 2011 census Firstly, increased international migration in the results – and the official household projections first decade of this century may have been that were based on them – were influenced by responsible for a significant proportion of the increased international migration, the changes to previous trends in household economic downturn and the effects of a long formation patterns. Secondly, it seems likely period of poor housing affordability. This that the 2011 census results were influenced suggests that planning on the basis of these by both the economic downturn and the effects projections could lead to an under-provision of of a long period of poor housing affordability. housing in some areas. This raises the question of whether planners This briefing, based on research conducted for should assume that household size will remain the RTPI by the University of Cambridge, stable or resume the previous falling trend. For suggests how planners and others might some authorities, this could affect the number respond. of homes required by 30% or more.

Who should read this? Consequently, three main issues should be Policymakers, decision-makers and taken into account in using DCLG household practitioners in England involved in planning projections at the local authority level: for housing and related areas for which provision is influenced by changes in the • The extent to which the pattern of number and type of households. household formation in the area been affected by an increase in international Key messages for policy and migrants (which may vary greatly). • The extent to which household formation practice patterns have departed from previous DCLG’s 2011 household projections for trends. England (published in April 2013) are the latest • Whether there have been significant official household projections and take account changes in the projected net flow to or from of the 2011 census results. As suggested in other local authorities, which may be a planning guidance, they are the starting point consequence of the use in the interim estimates for looking at household growth and projections of flow rates from earlier housing requirements. projections. In such cases it might be appropriate to adjust the projected flows. However, for the reasons explained in this briefing, local authorities need to consider their Suggestions for how planners and others might specific situation carefully in the light of what respond when planning for households in the latest projections suggest for their area. England are included in this briefing. They should ensure that their plan anticipates the range of potential outcomes and review the plan regularly to see if changes are needed.

RTPI Research Briefing No. 3 January 2014

Main findings 375,000 difference between the estimated and Compared to 2010 projections, the 2011 actual number of households. census found 450,000 more people in England than expected. There were also 375,000 fewer Changes in living patterns households than anticipated (compared to A comparison of actual and expected 2008 projections). The average household size household numbers by age of the household was larger than expected: it had remained at representative person shows that most of the the 2001 level rather than falling as expected shortfall is in the 25-34 and 35-44 age groups.

This raises some important questions: What Analysis of the types of households that are caused these changes? Are they likely to “missing” and other evidence from the Labour continue? And how should DCLG’s household Force Survey suggests that there has been a projections be used in assessing housing reduction in people in this age group living requirements? (It should be noted that this alone and an increase in the numbers living report relates only to England; different with their parents or in shared accommodation. approaches to projecting household numbers are used in the other parts of the UK.) The chart below shows how the number of 20- 34 year olds living with parents has increased: What changed? in 2011 there were ½ million more 20-34 year A detailed analysis of the census and other olds living with parents than in 2001. Although data points to two main reasons for the census some of the increase may be due to an finding fewer households than expected: increase in number of people in this age group, increased international migration; and changes the most of it is due to changing household in the types of households in which younger formation patterns. adults are living.

Increased international migration People arriving in England from abroad tend to live in larger households than the rest of the population. This means that if there are more people in the population who have recently arrived than anticipated, the average household size will be larger than expected.

The trends in household formation patterns which underpinned the previous set of official projections – DCLG’s 2008-based household Further, the following chart shows how the projections – were based on international proportion of 25-34 year olds living alone in migration flows from the 1990s and earlier. single person households fell over the same Compared with that period, the inflow of period. international migrants in the first decade of the century was 193,000 a year higher (offset in part by increased “out” migration so the growth in the net inflow was much smaller). It is therefore unsurprising that there were fewer households in 2011 than expected as more people than anticipated were living in larger households.

Analysis carried out by Alan Holmans at the University of Cambridge suggests that this may be responsible for some 200,000 of the

RTPI Research Briefing No. 3 January 2014

Are these changes likely to continue? Using DCLG’s latest household What happens to the number of “missing” projections households attributable to increased in DCLG’s household projections take as migration depends on what happens to their starting point the actual number of migration flows in the future. If there is no households in 2011 and household further significant increase in international formation rates indicated by the census. in migration (which seems a reasonable They are the starting point for looking at assumption given UK Government policies household growth and housing to reduce migration), there should be no requirements. increase in the number of recent migrants in the population. This is because the However, they are trend-based projections previous decade’s migrants will either (rather than forecasts), meaning they tell have left or become established residents you what would happen if the trends on living in similar household sizes to the rest which they are based were to continue. A of the population. As a result, there should view needs to be taken on whether that is be no further impact on average a reasonable assumption or whether some household size for this reason. change in the trends is more likely.

It seems likely that changes such as more This chart shows how the number of people living with their parents and more households per person is envisaged to people living in shared accommodation rise in the two projections and indicates are “forced” changes caused by those how different the latest projections are concerned not being able to afford from the 2008-based projections. separate accommodation, rather than free choices. Insofar as they are “forced”, it is likely that they will reverse if and when conditions improve.

The question then becomes, “What conditions would need to improve?” The two main factors are likely to be the economy, including incomes and the availability of mortgage finance, and the affordability of housing.

The graphs on the previous page, showing The lower starting point, in 2011, of the the growth in the number of young adults 2011-based projections reflects what the living with their parents and the falling census found, i.e. a smaller number of proportion of 25-34 year olds living on their households per person (which equates to a own, both indicate that the changes were larger average household size). The well underway before the economic projected forward trend gives rise to a downturn. This suggests that a return to flatter line, which implies a slower growth in stronger economic growth and better the proportion of the population that will be access to mortgage finance will be ‘household representative persons’. insufficient on its own to produce in a return to previous patterns of household However, this approach does not make formation. There would also need to be an allowance for either: improvement in the affordability of housing to buy and to rent – which depends on • The likelihood that “recent international house prices and trends in incomes and migrant” effect was a one-off; interest rates. • The possibility that conditions in the housing market and the economy more

RTPI Research Briefing No. 3 January 2014

generally will improve and there will be international flows at the local authority level. some return toward previous trends in The new methods should give more reliable household formation. (Note that the latest results. projections imply that the proportion of 25- 34 year olds who set up home on their own How might Government help? continues to fall and does not just remain The projections are a major asset for those at the 2011 level.) planning for housing, but they could be even more useful if government could: Both factors suggest that the latest projections are likely to underestimate the • Publish in an easily accessible form data growth in household numbers. showing how the projections for key drivers of change – birth, deaths and flows into and Using the latest projections for local out of a local authority – relate to what has authority areas happened in the recent past. This would The main issues which need to be taken allow users to understand the underlying into account at the local authority level are: trends and take a view, in the light of their local knowledge, as to whether they are a • The volume of international migration sensible basis for planning. varies significantly from area to area, • Provide sensitivity analysis at the local implying that the extent to which increased authority level so that users can gauge the international migration will have affected amount of uncertainty they need to plan for. the household projections could also vary considerably. • The extent to which household formation About the research patterns have departed from previous This briefing is based on research conducted trends also varies from area to area. for the RTPI by Neil McDonald and Peter For some authorities the new projections Williams at the University of Cambridge, suggest that household formation rates for funded through the RTPI’s Small Projects some groups will continue to fall. The Impact Research (SPIRe) scheme. impact which any move back towards previous trends would have will also vary Further information from area to area. The full report is available on the RTPI website • The latest projections are ‘interim’ at: www.rtpi.org.uk/spire projections prepared before the full results of the 2011 census were available. This About the RTPI means that it was necessary to use some The Royal Town Planning Institute holds a trend data from previous projections, unique position in relation to planning as a including data on flows between local professional membership body, a charity and a authorities in the UK. As a result these learned institute. We have a responsibility to flows, which are major drivers of population promote the research needs of spatial planning change for many authorities, may have in the UK, Ireland and internationally. been under or over-estimated for some areas. Where there are big changes More information on our research projects can between the 2008-based and 2011-based be found on the RTPI website at: projections in this area the new projections www.rtpi.org.uk/knowledge/research/ should be compared with past flows and a view taken on whether they are a reasonable basis for planning. You are also welcome to email us at: [email protected] It should also be noted that some of the differences between the 2008-based and 2011-based projections are the result of improved methods used to estimate

4 Examination of the New East Devon Local Plan 2006-26

Mr M Dickins Inspector: Anthony Thickett BA(Hons) BTP Planning Policy Manager MRTPI Dip RSA East Devon District Council Knowle Programme Officer: Amanda Polley Sidmouth Devon EX10 8HL Knowle By email only Sidmouth Devon EX10 8HL

Dear Mr Dickins,

At the last hearing I promised to write to you giving a date for my report or setting out what further work is required. Unfortunately I do not consider that the Local Plan is sound nor at this stage can it be made so by main modifications.

Housing Numbers

1. I do not consider that the 15,000 housing target is justified by the evidence submitted to the examination. The National Planning Policy Framework (NPPF) requires local planning authorities to ensure that Local Plans are based on adequate and up to date evidence1 and to prepare a Strategic Housing Market Assessment (SHMA) to assess their full housing needs over the plan period2. The 2007 SHMA3 was updated in 20114 and it was accepted by your consultant at the hearing that it was prepared before the most recent guidance was issued. The 2011 update is founded in part on survey work done in 2007 and so its reliability is questionable. Further, it only covers 2011 to 2016 and is criticised by your other consultants, Roger Tym and Partners who produced the 2011 Housing and Employment Study5.

2. In any event, it is clear from the hearing that the 15,000 target in Strategy 1 is not based on the SHMA but the low migration scenario figure for East Devon given in Table 6.3 of the Roger Tym report (10,800) plus about 4,000 for overspill from elsewhere (largely Exeter) which has no empirical evidential basis. The National Planning Practice Guidance (NPPG)6 advises that the starting point for estimating need should be the latest population and housing projections. I acknowledge that the 2011 projections should be used with caution but Roger Tym’s estimates are based on the 2008 population and household projections. I could question the validity of choosing the low migration model given that the Roger Tym report

1 Paragraph 158 2 Paragraph 159 3 CD/Hsg019 4 CD/Hsg020 5 CD/Hsg002, paragraphs 6.29 to 6.33 6 Reference ID: 2a-015-20140306 leans towards a higher figure but there seems little point given the shortcomings in the evidence base overall.

3. I give little weight to the County Council’s work given that it is county wide and is based in part on demand rather than objectively assessed need. I cannot, therefore, conclude that the figure of 15,000 is justified by up to date and appropriate evidence. The absence of an up to date SHMA is a serious failing and makes a full assessment of need difficult. To rectify this, the Council should produce an up to date SHMA to assess the need for housing and affordable housing. If an updated SHMA indicates levels of need greater than provided for by the Plan you should test the impact of higher levels of growth through SA/SEA. Subject to the results of that exercise, you should consider making provision for an increased number of dwellings and/or set out results of discussions with neighbouring authorities in relation to meeting any un met need in the District.

4. As discussed at the hearing its seems most unlikely to me that parts of West Dorset and East Devon do not fall into the same housing market area. I see that according to the 2007 SHMA and 2011 update the Coastal Towns sub market area includes part of West Dorset and Lyme Regis in particular. However, none of the survey work appears to include any parts of West Dorset. As you know the Inspector examining the West Dorset, Weymouth & Portland Local Plan has indicated that further work needs to be done with regard to assessing housing needs. There would, therefore, seem to be an opportunity to work with West Dorset in preparing evidence.

5 year housing land supply

5. The NPPG states that; ‘Local planning authorities should aim to deal with any under-supply within the first five years of the plan period where possible’7. That and the aim of the NPPF to significantly boost the supply of housing weighs against the Liverpool approach to meeting your backlog. Turning to the arguments in favour of Liverpool in Topic Paper 1; whilst adopting Sedgefield may result in a marked drop in the rate of provision after 5 years this is an argument that could be repeated many times and the high rate is due to past failures in delivery. To accept a longer period to address the shortfall is counter to the aim of significantly boosting housing supply and would run the risk of leaving households in need for longer.

6. Dangers of overdevelopment, directing development to the best sites and where it is needed, sustainability and matching development to infrastructure should all be addressed through planning i.e. the Local Plan. As you say in the Topic Paper, plan led provision lies at the heart of the NPPF and I see nothing in the Sedgefield approach which would prevent this in East Devon.

7. The ‘5 year land supply update - Sedgefield Approach’ assessment produced by you at my request shows a housing land supply of 4.04 years as of October 2013. Paragraph 49 of the NPPF warns that relevant polices for the supply of housing

7 Reference ID: 3-035-20140306 should not be considered up to date if a 5 year supply cannot be demonstrated. The District Council needs to be able to demonstrate a 5 year supply on adoption of the Local Plan and I look forward to hearing how you intend to ensure this will be the case.

Housing Distribution

8. No doubt any work on a new SHMA will consider distribution and I would expect, in accordance with the objective of achieving sustainable development, that new development would be directed to settlements that have the capacity to accommodate and sustain new development. I am aware that the numbers allocated for villages in Strategy 27 are based on consultations with local communities. However, I am concerned that these figures are not based on an assessment of the ability of the small towns and villages to accommodate growth and that the blanket application of a 5% minimum growth is too crude a tool. Further, the post submission changes to Policy 27 strongly imply that the 5% will be treated as a maxima. I suggest, therefore, that you revisit Strategy 27 in light of the Settlement Appraisals which, if applied consistently, do not support some of the figures in Strategy 27.

Plan period

9. The NPPF advises that plans should preferably have a life of 15 years8. This is not fixed in stone but if adopted in 2014, the plan would only have a life of 12 years. I am aware that provision is made for development beyond the plan period at the West End. However, I consider that this approach offers less certainty and a longer plan period would give developers, landowners and you greater confidence in the long term delivery of the Growth Point. Further, it leaves less time to deliver and react to changes that may threaten delivery in the rest of the District, particularly as it is envisaged that the Villages Development Plan Document and Neighbourhoods Plans are to follow, all of which will take time to produce, examine and adopt before they become effective.

10. The 2011 Housing and Employment Study9 projects housing and employment requirements to 2031. Should any further work/studies to address my concerns regarding evidence of housing need cover a period beyond 2026 then I would ask that you give serious consideration to extending the plan period.

Gypsies and travellers

11. The last assessment of the accommodation needs of gypsies and travellers was carried out in 2006 and only addressed provision up to 2011. I was informed at the hearing that you sought to work with some of your neighbours to produce a new assessment in time to inform the Local Plan but, for reasons outside your control, that did not prove possible. I agree that rather than commission an independent assessment it would be better to pursue a joint approach and I

8 Paragraph 157 9 CD/Hsg002 understand that a new assessment has just been commissioned and that it should be completed by this summer of 2014.

12. It is proposed that, should a need be identified, you would then produce a Gypsy and Traveller Plan. This is not ideal and runs counter to the advice in the NPPF which discourages multiple plans. A suspension of the examination to allow you to produce additional housing evidence may provide an opportunity for any need identified through a gypsy and traveller needs assessment to be addressed through the Local Plan rather than a separate plan.

I would now ask you to give careful consideration to the above matters. The production of a new SHMA may take some time and I would appreciate an indication of how long you consider you will need to produce this information in order that we can plan ahead with regard to the length of any suspension and any further hearings that may be required. I will do all I can to help the Council in relation to the way forward, although you will appreciate the restricted nature of my role in this regard and that any advice given is without prejudice.

Yours faithfully

A Thickett

Inspector

South Hams District Council Our Plan – Shaping our Communities to 2031 Consultation Document

Response made on behalf of The Cann Estate

June 2014

smiths gore .co.uk

Project: Our Plan Consultation Response

Client: Tuckett Cann

Job Number: 1047822

File Origin: Internal

Document Checking:

Prepared by: Claire Alers-Hankey Signed:

Checked by: Mark Richards Signed:

Verified by: Steve Briggs Signed:

smithsgore.co.uk South Hams District Council Our Plan – Consultation Response The Cann Estate

Contents

Page No

1.0 Introduction to the consultation response ...... 1

2.0 Local Plan preparation – tests of soundness ...... 1

3.0 Our Vision ...... 2

4.0 Our Homes ...... 3

5.0 Our Economy ...... 6

6.0 Our Communities ...... 8

7.0 Our Resources ...... 9

8.0 Potential site allocations ...... 10

9.0 Further Consultation ...... 10

Appendix A - Potential site allocations

Appendix B - Completed representation form

South Hams District Council Our Plan – Consultation Response The Cann Estate

1.0 Introduction to the consultation response

1.1 This consultation response has been prepared by Smiths Gore on behalf of the Cann Estate. The submission has been prepared following an invitation from South Hams District Council to comment on its Our Plan Consultation Document.

1.2 As a significant owner of land and property in South Hams the Cann Estate is keen to ensure that the policies within the emerging Our Plan are responsive to local circumstances and support, rather than constrain the development that South Ham’s urban and rural communities and businesses require to meet their social and economic needs.

1.3 The form of this response follows the advice given by South Hams District Council in that comments have been made on the online response form. However as these forms do not allow for an adequate level of detail to be provided, the main body of the submission is included within this written report. Therefore the comments submitted in the forms and in this written submission should be read together to appreciate the full response to this consultation. The full written response has been submitted both electronically and as a hard copy to South Hams District Council.

1.4 This written report makes detailed comments on particular sections of the consultation document, identifying the relevant issues and topic areas to be considered, how these issues/topics can be addressed, the requirement for appropriate evidence to support each area, and how the land and property under the ownership of the Cann Estate can contribute towards delivering the plan policies and targets. The sections to which the comments relate are clearly identified by each subheading.

2.0 Local Plan preparation – tests of soundness

2.1 Local Plans at the pre-submission stage should accord with certain tests which are outlined within the National Planning Policy Framework (the Framework). The tests are in place to allow a planning Inspector to assess whether a plan is ‘sound’. A sound plan is described at paragraph 182 of the Framework as being:

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2.2 This consultation response has been prepared with these tests in mind and considers the topics for consideration contained within the South Hams District Council Our Plan Consultation Document against each of them. It also tests the proposed topics against the other relevant policies within the Framework in order to ensure it is consistent with national policy.

South Hams District Council Our Plan – Consultation Response The Cann Estate

3.0 Our Vision

3.1 The consultation document produced by South Hams District Council sets out a number of challenges that South Hams currently faces and also outlines topics that the new plan may cover in order to address these challenges. It also makes reference to where the priorities within South Hams should lie when addressing such challenges.

3.2 The Cann Estate encourages an overarching approach to be taken in achieving the aims and priorities of South Hams, with the principles of sustainable development being central to achieving this. A key factor to achieving sustainable development is ensuring that equal weight is given to all aspects of sustainability.

3.3 All too often in recent years the environmental component of sustainable development has been given a disproportionate level of weight in planning policy and development management decisions. This has had significant impacts on the social and economic sustainability of communities, particularly in rural areas, where a lack of housing and employment provision has forced, and is still forcing people to leave the communities in which they were raised. This is clearly the case within South Hams, where the consultation document recognises that there is an out migration of young and working age people, and an increase in the older age population within South Hams.

3.4 Although the environmental component of sustainability is clearly an important consideration to take into account it must be balanced against the need to meet social and economic needs in order to allow communities to be vibrant and prosperous. In considering the future development of South Hams it is important to understand that sustainable development is not solely confined to environmental issues but also encompasses a wide range of factors including economic prosperity, the promotion of strong, vibrant and healthy communities as well as the protection and enhancement of the natural and built environment. This view is supported within paragraph 7 of the National Planning Policy Framework (the Framework) which states,

There are three dimensions to sustainable development: economic, social and environmental. These dimensions given rise to the need for the planning system to perform a number of roles:

• An economic role – contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;

• A social role – supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community’s needs and support its health, social and cultural well-being; and

• An environmental role – contributing to protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.’

3.5 The Framework goes on to state,

South Hams District Council Our Plan – Consultation Response The Cann Estate

‘These roles should not be undertaken in isolation, because they are mutually dependent. Economic growth can secure higher social and environmental standards, and well-designed buildings and places can improve the lives of people and communities. Therefore to achieve sustainable development economic, social and environmental gains should be sought jointly and simultaneously through the planning system.’

3.6 In accordance with the Framework and the sustainability principles detailed above, South Hams’ Our Plan should embrace a presumption in favour of sustainable development, with clear policies that guide how the presumption can be applied within South Hams. This would allow the objectively assessed development needs of South Hams to be met in a timely fashion, with sufficient flexibility to adapt to rapid change.

3.7 The Vision of the South Hams Our Plan should also include reference to key planning principles, that can be applied to the majority of development within the district and provide a framework for future growth. The Framework sets out a number of core planning principles, to which the Our Plan document makes some reference. Accordingly it is pleasing to see the encouragement of local stakeholder involvement at this only consultation stage as well as at the proposed plan stage, and in accordance with the first core principle of the Framework.

3.8 Another core principle of the Framework is that planning should always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings. There is little reference within the Our Plan consultation document to these core principles and as such, in the interests of achieving high quality design as well as an appropriate standard of amenity, the inclusion of such a principle within the Vision of the Our Plan would be encouraged.

4.0 Our Homes

4.1 Future Housing Numbers

4.1.1 In order to provide an appropriate housing target for the district, it is necessary for the Council to cultivate an evidence base to ensure that the Our Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area. This should include the identification of key sites which are critical to the delivery of the housing strategy over the plan period.

4.1.2 A standard methodology for the assessment of housing need is set out in the National Planning Practice Guidance (NPPG) – Housing and economic development needs assessing (ref ID: 2a-014-20140306), and its use is strongly recommended because it will ensure that the assessment findings are transparently prepared. South Hams District Council should assess their development needs working with the neighbouring local authorities, including Plymouth, West Devon, Teignbridge, Torbay and Dartmoor National Park, in the relevant housing market area, as such needs are rarely constrained precisely by local authority administrative boundaries. It is encouraging to see that in this instance, South Hams appear to be working alongside West Devon Borough Council in preparing their respective Plans.

4.1.3 According to guidance contained within the NPPG - Housing and economic development needs assessing (ref ID: 2a-015-20140306) the starting point for establishing the estimated need for housing should be the household projections published by the Department for Communities and Local Government (DCLG) which are based on trends observed in Census and Labour Force Survey data.

South Hams District Council Our Plan – Consultation Response The Cann Estate

4.1.4 New research suggests that using the 2011 Census data to assess the future housing need could result in Councils underestimating housing need by up to 30%. This deficit has been identified in a RTPI commissioned study carried out by the University of Cambridge’s Centre for Housing and Planning Research. Their report describes that:

“There are two reasons why the trends that have been projected forward in the official projections may not continue unchanged. Firstly, increased international migration in the first decade of this century may have been responsible for a significant proportion of the changes to previous trends in household information patterns. Secondly, it seems likely that the 2011 Census results were influenced by both the economic downturn and the effects of a long period of poor housing affordability. This raises the question of whether planners should assume that household size will remain stable or resume the previous falling trend. For some authorities, this could affect the number of homes required by £0% or more.

On the basis of this evidence the local authority should be seeking to provide over and above the number of new homes suggested by the 2011 Census data.

4.1.5 At Examination all evidence used by the Council in determining the proposed housing target will be rigorously assessed and tested. If this evidence is found not to be sufficiently robust the plan will be found unsound and will delay its adoption, leaving the Council vulnerable to ‘planning by appeal’. It is important to note that the vast majority of Local Plans rejected at examination are due to the fact that their housing targets are too low and do not meet the projected growth in households, i.e. the full, objectively assessed needs. This point is emphasised by the recent example of the examination of East Devon District Council’s Local Plan, which was found to be unsound as the housing target was considered to be unjustified. Furthermore the Inspector specifically referred to the validity of choosing low migration models when other supporting documents lean towards higher figures.

4.2 Affordable Housing

4.2.1 The Our Plan consultation document identifies a sustained need for more market and affordable housing within South Hams. Accordingly it is acknowledged by the Cann Estate that the local housing market within South Hams does not reflect the income of those living and working locally. This is evidenced by the statistics within West Devon’s Our Plan consultation document which show average house prices are up 91.6%, but average the average weekly wage is up only 25.5%. Furthermore, the number of households on the Council’s Housing Register is up 146%. The current situation is both socially and economically unsustainable, with an out migration of young and working age people also identified as an issue within the Our Plan document.

4.2.2 In order to calculate the affordable housing need for the district, the Council will need to estimate the number of households and projected households who lack their own housing and who cannot afford to meet their housing needs in the market. This calculation requires the current unmet housing need and the projected future housing need to be subtracted from the current supply of affordable housing stock. A detailed methodology for calculating affordable housing need is included within the NPPG - Housing and economic development needs assessments (ref ID: 2a-020-20140206).

4.2.3 When setting the level of affordable housing contribution to be sought from residential developments it is important that the Our Plan takes into account the potential impact of such requirements on the financial viability of developments. Financial viability needs to be taken into account when negotiating affordable housing contributions on a site by site basis. In order to ensure that housing developments are deliverable over the

South Hams District Council Our Plan – Consultation Response The Cann Estate

coming years it will be important for the Council to take a flexible approach which takes account of the financial viability of individual developments. This approach is supported in paragraph 50 of the Framework which states that policies for meeting affordable housing need “should be sufficiently flexible to take account of changing market conditions over time.”

4.2.4 The Framework goes on to advise local planning authorities in paragraph 54, to consider whether allowing some market housing would facilitate the provision of significant affordable housing to meet local needs. In this paragraph the Framework places the onus on local planning authorities to make an informed judgement on this issue, based on an understanding of the financial viability of developments, particularly as grant funding for such schemes is seldom available.

4.2.5 Affordable housing goes beyond just social rented and intermediate housing. Accordingly, to meet the full range of need the Council should encourage a mix of affordable tenures, for example, affordable rent, self build, shared ownership, and so on. The Council should have evidence of the need on all types of affordable housing.

4.3 Self-build

4.3.1 Advice contained within the NPPG - Housing and economic development needs assessments (ref ID: 2a-021-20140306) states that the Government wants to enable more people to build their own home and wants to make this form of housing a mainstream housing option.

4.3.2 There is strong industry evidence of significant demand for such housing, which can be identified for the Self Build Portal. However such data is unlikely to provide reliable local information on the local demand for people wishing to build their own homes. The Council should therefore establish demand/need for self build as part of its evidence base.

4.3.3 A recent example has been set within Devon with the approval of the Teignbridge Local Plan in South Devon, which encourages more self/custom build by requiring developers of large housing schemes to provide five percent of their new homes as plots for self- builders. They argued that the new policy would help deliver more self-build plots, would support the local economy, increase the diversity of housing available in the area and encourage more sustainable building practices. The threshold for this policy is all housing developments of twenty or more homes, prospective self builders will be required to build out their properties within three years, and if a developer finds there is no demand for their quote of self build plots after a twelve month period, they can be built out for market sale or as affordable housing. Therefore the policy allows a reasonable amount of flexibility, and South Hams District Council should include a similar policy within the Our Plan.

4.4 Housing Mix and Type

4.4.1 To ensure that a suitable supply of housing is provided, it is not enough to simply encourage housing growth. It is essential that South Hams’ housing market is appropriate to meet the needs of existing and future populations. In planning for future household growth it will be important to cater for families, young people leaving home, home workers, households forming as a result of marriage failure, and the elderly. Therefore a range of housing types and tenures will need to be provided to meet the diverse needs of future households.

4.4.2 This approach is supported by paragraph 50 of the Framework that states,

South Hams District Council Our Plan – Consultation Response The Cann Estate

‘To deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities, local planning authorities should…identify the size, type, tenure and range of housing that is required in particular locations, reflecting local demand.’

4.4.3 Advice contained within the NPPG – Housing and economic development needs assessments (ref ID: 2a-021-20140306) goes on to state that,

‘When considering future need for different types of housing, plan makers will need to consider whether they plan to attract a different age profile eg increasing the number of working age people.’

The Our Plan consultation document has already identified an increase in the older age population and an out migration of young and working age people. Therefore it is necessary for the Council to consider how they can encourage the retention of young people and families, and how they can support an increasing older age population.

4.4.4 Housing in smaller settlements

The Council should make provision for a significant proportion of growth to take place outside of the district’s main settlements, in order to maximise the potential to meet the required housing targets within the area. If such provision is not included the Council risks undermining the delivery of housing, which could cause a shortfall in the Council’s five year housing land supply. As the Council will already be aware, the speculative delivery of housing within South Hams is very low and continued under- delivery will cause the Council to be in a weak position to resist developments which are contrary to local housing policies, on sites which it might otherwise look to resist. This is because local policies relating to the supply of housing cannot be considered up to date if the local planning authority is unable to demonstrate a five year supply of deliverable housing sites, as per paragraph 49 of the Framework which states, ‘Relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five year supply of deliverable housing sites.’ Recent appeal decisions also emphasise the requirement of Council’s to provide a five year housing land supply, as in the case of appeal no. APP/U1105/A/13/2210594.

4.4.5 To ensure the delivery of sufficient levels of housing outside of the main settlements the Cann Estate would like to encourage the local planning authority to identify strategic sites (of an appropriate scale) within, and adjacent to, a range of smaller settlements and to allocate these sites within a Site Allocations document. This is a tried and tested process for allocating sites which ensures a far greater certainty of outcomes. Furthermore this process also allows for meaningful involvement and engagement with local communities to take place through effective techniques such as workshops, exhibitions etc.

5.0 Our Economy

5.1 Supporting the rural economy

5.1.1 The on-going decline in employment within agriculture has reduced rural employment opportunities, which has meant that people in small rural communities often have to journey long distances to reach their place of work. It also means that the life of rural communities is affected by a downward spiral in terms of economic activity and an increasing change from formerly vibrant rural communities to a dormitory settlement providing increasingly expensive housing for non indigenous house purchasers.

South Hams District Council Our Plan – Consultation Response The Cann Estate

5.1.2 The key aim underlying Greg Clark’s Ministerial Statement on 23rd march 2011 is to ensure that the planning system does everything possible to support economic growth and sustainable development in order to rebuild the nation’s economy. This message has also been supported within the TCPA’s recent publication entitled ‘A vision for rural England’ which states that it will be important to “encourage and support local rural economic opportunities (including new businesses and home-working as well as diversified land-based enterprises) in rapidly changing and growing rural economies”.

5.1.3 Historically opportunities for rural businesses have not been adequately supported in South Hams. The consequence of this is that rural communities have been unable to fulfil their economic potential. The new Our Plan should be treated as an opportunity to enable rural businesses to deliver more for local economies. Barriers preventing South Hams from fulfilling its economic potential and concerns raised by rural businesses include a lack of appropriate premises, extremely limited scope for expanding or modernising existing premises, and inflexibility within the planning system with regards to economic growth. The Our Plan should seek to overcome these issues.

5.1.4 The Our Plan consultation document recognises that some of the challenges that face the district include attracting a range of jobs and supporting and retaining existing jobs and local businesses. Paragraph 19 of the Framework demonstrates a commitment to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Accordingly, significant weight should be placed on the need to support economic growth though the planning system. Paragraph 20 of the Framework goes on to states local planning authorities should plan proactively to meet the development needs of business and support an economy, in order to achieve economic growth.

5.1.5 Further detail is provided in paragraph 21 of the Framework, which sets out criteria that local planning authorities should consider when drawing up Local Plans. The criteria include:

• set out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth; • set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period; • support existing business sectors, taking account of whether they are expanding or contracting and, where possible, identify and plan for new or emerging sectors likely to locate in their area. Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances; • plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries; • identify priority areas for economic regeneration, infrastructure provision and environmental enhancement; and • facilitate flexible working practices such as the integration of residential and commercial uses within the same unit.

5.1.2 The Cann Estate encourages the inclusion of such supportive policies towards economic growth within the district, as demonstrated in the Framework. As a landowner of sites adjacent to Devonshire Meadows Industrial Estate and Belliver Way Industrial Estate in the parish of Bickleigh, the delivery of new businesses and the retention of existing business in such areas could then be promoted.

South Hams District Council Our Plan – Consultation Response The Cann Estate

5.2 Potential for live-work units

5.2.1 Fuelled by the impact of new technology (such as improved internet access in rural areas), a growing frustration with the stress and time wasting associated with the daily commute and a desire for a better work/life balance, self employed people in rural areas are increasingly choosing to opt for home-working. In fact this is now a well- established trend with live-work units being delivered through both new build and conversion schemes. Both should be supported in local planning policies.

5.2.3 In May 2013 the Trade Union Congress (TUC) published an analysis of the number of people working from home in the UK. This analysis found that the number of people working from home has increased by 13% in the last five years. Just over four million employees usually worked at home in 2012, a rise of 470,000 since 2007. The Office of National Statistics (ONS) also reported an increase in the level of home working, based on 2011 census data, and attributes this increase to a greater prominence of home businesses in rural areas. Furthermore, the Annual Population Survey 2010/2011 carried out by the ONS identified working from home as being more common in rural areas of England than in urban areas.

5.2.4 Over recent years the principle of live-work units has become more acceptable as a means of promoting the sustainable working practices. Such schemes are inherently sustainable as they help to meet local demand for housing (socially sustainable) and they provide local employment opportunities (economically sustainable). They also serve to reduce the need to travel by car by removing the need for a daily commute.

6.0 Our Communities

6.1 Infrastructure

6.1.1 New developments can, individually or cumulatively, result in increased pressure on existing infrastructure. The Cann Estate therefore acknowledges that there may be a need to secure financial contributions from applicants in certain circumstances in order to make such developments acceptable in planning policy terms.

6.1.2 When considering the appropriate level of contributions to be derived from a particular development it is important that the local planning authority has a detailed, up to date, evidence base which outlines the infrastructure requirements for the area. The Hardicott Estate therefore encourages the Council to work in partnership with infrastructure providers and other delivery agencies to keep an up to date infrastructure delivery plan. This will provide developers with an indication of what is likely to be required and provides useful information on infrastructure constraints which might impact upon certain developments. This will provide landowners and developers with a greater sense of certainty.

6.1.3 It is however, important that the local planning authority carefully considers the value to be gained from imposing such requirements upon developments. When considering the level of infrastructure provision to be required it is essential to weigh the desirability

South Hams District Council Our Plan – Consultation Response The Cann Estate

of funding infrastructure against the potential effects of that imposition upon the economic viability of new developments. These decisions should therefore be based on detailed evidence about the likely effects on financial viability. If an appropriate balance cannot be achieved there is a real risk that much of the development that Devon needs over the coming plan period will be unviable and consequently undeliverable. If this is the case then it is likely that the Our Plan will be found unsound when it goes through the examination process.

6.1.4 The Cann Estate would also like to see some flexibility built in to the wording of the policy which allows for negotiations to take place regarding infrastructure requirements where appropriate.

7.0 Our Resources

7.1 Sustainable Construction

7.1.1 The consultation document identifies the need for the district to respond positively to climate change and encourage sustainable construction methods. As a nation we need to reduce overall energy demand and consumption, therefore this should be the priority for energy polices within the Our Plan. Planning policy within South Hams should encourage energy efficiency in order to reduce the carbon footprint of the borough.

7.1.2 The inclusion of such policies is supported by the Cann Estate, however there needs to be an acknowledgement of how such requirements will impact upon development viability. While the Estate does not contest that clear targets should be aspired to wherever possible, planning policy must recognise that in certain circumstances, achieving that target or standard may render some development schemes unviable.

7.1.3 The Framework, in paragraph 173, places a great deal of emphasis on the need for local planning authorities to pay careful attention to viability and costs in plan making and decision taking in order to ensure that Local Plans are deliverable. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. Paragraph 174 then goes on to explain that the cumulative impacts of these standards and policies should not put implementation of the plan at serious risk and should facilitate development throughout the economic cycle. It is important the local planning authority takes this guidance into account in preparing the Our Plan as consideration of overall viability is part of the evidence base which will be subjected to test, challenge and debate when it is eventually examined. Demonstrably failing to consider this issue will almost certainly result in the Our Plan being found to be unsound.

7.1.4 Although developers vary in their approach to profit and risk, the key point is that a development which is not viable will not be delivered. This can mean that housing targets will not be met and delivery over the plan period will fall behind and fall short. In such cases, developers will await better market or financial conditions and put their resources into developing more profitable schemes elsewhere instead.

7.1.5 Echoing the Framework, Viability in the NPPG (ref ID: 10-016-20140306) states where the deliverability of the development may be compromised by the scale of planning obligations and other costs, a viability assessment may be necessary. The Guidance recognises viability should be informed by the particular circumstances of the site and

South Hams District Council Our Plan – Consultation Response The Cann Estate

the proposed development in question. For a site to be viable the value generated by its development must exceed the costs of developing it, and it must provide a sufficient incentive for the land to come forward and the development to be undertaken.

8.0 Potential site allocations

8.1 The Cann Estate is the landowner of the following sites within the district. A brief assessment of each site is given, along with an assessment of the suitability for allocation within the Our Plan for either residential or economic development. These sites are all suitable to be allocated for future development, which is a requirement of the Council as already discussed in this response. Site location plans for all of these sites are contained within Appendix A.

8.2 Land at West Trehills, Tamerton Foliot

This site is located on the northern outskirt of Tamerton Foliot, and falls within the parish of Bickleigh. The site sits between Allern Lane and Roborough Lane, and is served by an existing access off Roborough Lane. It is directly opposite built form to the west with existing housing development on Cunningham Road and falls within a Flood Zone 1. The site is considered to be suitable for a small scale housing scheme, that would contribute towards the housing requirements of the district as well as maintaining support for local services and facilities within the local area.

8.3 Land at Devonshire Meadows, Broadley Park Road

The site is located to the west of Devonshire Meadows Industrial Estate, within the parish of Bickleigh. The site falls within a Flood Zone 1. The main part of the site is served by an existing access off Soper’s Hill, but also has a direct link to Broadley Park Road – the road that runs through the industrial estate. Accordingly it would be very easy to link the site as an extension to the existing business. In light of this, it is believed the site is suitable for allocation as an employment site, with a range of commercial uses being considered, thereby contributing towards building a strong and competitive economy in the district.

8.4 Land north of Belliver Way Industrial Estate

The site is located directly adjacent to the Belliver Way Industrial Estate, with Devonshire Meadows just to the north. The northern end of the site falls within flood zone 2 & 3, however the large remainder of the site (closest to the Belliver Way Industrial Estate) falls within flood zone 1. The site is served by two existing accesses off Tamerton Road. It is considered the development of this site as an extension to the industrial estate would be suitable, with a range of commercial uses being considered. This would contribute towards supporting and retaining existing jobs and local businesses as well as attracting a range of new jobs to the area.

9.0 Further Consultation

9.1 The Cann Estate requests the right to take part in the upcoming consultation events so that it can contribute towards the input into the draft Our Plan as a stakeholder. Although the schedule for consultation events is not yet know the Cann Estate would like to participate in sessions and events dealing with the following issues:

Our Vision

South Hams District Council Our Plan – Consultation Response The Cann Estate

Our Homes

Our Economy

Our Communities

Our Resources

Potential site allocations

South Hams District Council Our Plan – Consultation Response The Cann Estate

Appendix A

Potential site allocation site location maps

South Hams District Council Our Plan – Consultation Response The Cann Estate

Land at West Trehills, Tamerton Foliot

Land at Devonshire Meadows, Broadley Park Road

South Hams District Council Our Plan – Consultation Response The Cann Estate

Land north of Belliver Way Industrial Estate

Planning Team Planning Services

Planning applications and statutory processes

• Advice on strategy and approach

• Site appraisals and development briefs

• Pre-application and stakeholder negotiations • Community consultation • Preparation, co-ordination and submission of planning applications • Planning appeals – written representations, informal hearings and public inquiries • Planning agreements • Lawful development certificates • Enforcement matters

Rural planning projects

• Alternative use assessments

• Residential development and affordable housing

projects

• Employment development • Agricultural and equestrian projects • Farm diversification • Barn conversions • Agricultural occupancy conditions • Tourism and leisure development • Conservation and historic buildings advice • Renewable energy and energy conservation • Rights of way

From: Strategic Planning Subject: Comment on SHDC 'Our Plan' Attachments: SHDC Scope for the 'Our plan' .rtf

Dear Sirs

In line with the public consultation I wish to submit the following comments concerning the scope of the plan being suggested.

- see attached file

I would also like the following questions addressed;

I would like to know if members of the public can attend any of the meetings on the 'engagement event schedule'? If not, why not?

At what level does public opinion convert into a change of inclusion into the plan?

Who decides what is in the plan or not?

How does that process take place?

If this is by committee, who decides who is on that committee?

Are the interests declared by those people and are they available for the public to see?

On a separate note;

Natural England have identified that 3 of the SSI's within the South Hams have been effected in a negative way, what action are SHDC taking to mitigate this?

I would appreciate confirmation that my submission has been received and acknowledged. Yours sincerely

Mrs G A Davidson

Comments regarding the Scope of 'Our Plan' as submitted by SHDC.

Wildlife - none mentioned or included under headings.

Biodiversity in Devon and in The South Hams forms a vital part of the character and amenity of the area, and as such needs to be recognised within the scope of the plan, not just in a precautionary way, but with a pro-active and enhancement strategy, with recognised status.

Food Security - none mentioned and becoming increasingly important.

Intrinsically linked with carbon reduction (policies developed to reduce the necessity for importation and encourage local consumption of food resources). Food security is recognised as vital nationally and will be come an ever more important issue with population increases and additional pressures on the limited resource of land. Since Farming forms a key platform to the character and economy of the area, it needs inclusion. The majority of the South Hams is rural and to marginalise the food production of the region is a missed opportunity for employment as well as in keeping with the sustainability of rural communities.

Need acknowledgement of the importance of the Rural nature of the area.

Energy consumption - Need to include the positive strategy of the Management and Encouragement of energy saving initiatives, either through education, co-operatives, programmes linked to government initiatives and funds available now and in the future.

Accountability and process - Clear and accountable process for balanced enforcement of planning conditions or breaches, none in place currently nor any mentioned. Vital for the public to feel confident that the council representing their interests is able to ensure abuse of the system of planning is brought under control. Open and transparent process that is properly resourced.

Right to be heard - be able to address the development committee with or without the support from a ward councillor, residents must have the right to be able to request that an application go before a committee. It would need to be from those most affected, and require a certain percentage of objections to be filed to invoke the right. This would bring the council in line with the spirit of localism and democracy.

Public Consultation - Definition refined for public consultation process to ensure people have a real say in their own environment.

Mr. Phil Baker Our ref: South Hams District Council DC/2014/115020/OR-01/IS1-L01 (& Planning Policy DC/2014/115021/OR-01/IS1-L01) Follaton House Plymouth Road Totnes Devon Date: 20 June 2014 TQ9 5NE

Dear Mr. Baker

SOUTH HAMS AND WEST DEVON – OUR PLAN CONSULTATION

Thank you for your email 09 May 2014 providing us with the opportunity to comment of the topics and challenges identified in consultation documents for both South Hams and West Devon.

The water environment (quality, resource and ecology) We have met recently to discuss issues about growth and water quality and are therefore disappointed that the water environment is not considered in higher regard. The document does not specifically mention water (resources or quality). Whilst we acknowledge that the issues and aspirations on pages 6 and 7 can be read as comprehensive, assumptions need to be made. For example, water quality could come under ‘Our Nature’ or ‘Our Resources’. Likewise, water quality and quantity aspects could be addressed by ‘protecting natural landscapes’ under ‘Place’ (page 13). However, it is our view that both Local Plans should recognise the importance of the water environment and address this in a specific section within the plan

It is important that water is viewed as the essential resource that it is and that its value is recognised in Local Plans. The economic benefit local communities can receive from their water environment (e.g. drinking water, bathing waters, shellfisheries, angling, recreation, tourism, industry, etc.) needs to be recognised and Local Plans should highlight and build upon the importance of the water environment to the local economy. This relates not just to water quality but to quantity too. Local Plans therefore need to reflect the importance of the water environment and the impact (both negative and positive) that development can have.

We consider it would be beneficial to present a connective thread through the plans to demonstrate that many aspirations/issues are interdependent and that these interconnectivities should be considered to ensure better quality and inclusive planning decisions.

Environment Agency Sir John Moore House Victoria Square, Bodmin, Cornwall, PL31 1EB. Customer services line: 03708 506 506 www.gov.uk/environment-agency Cont/d..

The environment as a whole flows through the natural and the built and could be drawn as a cross cutting aspiration. Good environmental management can support economic growth. Building environmental factors into development strategies helps to support climate change adaptation, whether that is encouraging tree planting to shade rivers from warming or incorporation of renewable energies. Creation of open space and Green Infrastructure can help to create and connect habitats, improve water quality and reduce flood risk as well as supporting wellbeing and protecting heritage. Promoting the connection of urban areas to their rural surroundings can provide catchment solutions to flood risk.

Developing strategies that clearly incorporate these environmental opportunities in these sorts of ways enable Local Authorities to demonstrate their commitment to delivering responsibilities under broader legislation such as Water Framework Directive (WFD). We welcome this opportunity to work with you to develop the environmental benefits within your Local Plans.

Flood risk and surface water drainage We are pleased to see flood risk specifically mentioned under ‘Our Resources’. Whilst flood risk will remain an issue for existing development and Brownfield redevelopment in flood risk areas we consider that there is sufficient land available within both districts for all Greenfield development to be located outside of flood risk areas. Redevelopment of Brownfield land in flood risk areas should look to provide flood risk betterment by being designed to be safe and not increasing risk elsewhere as well by as seeking to reduce flood risks to the wider community (e.g. contribution to flood defence improvements and making space for water).

All development should also use sustainable drainage systems to manage surface flows so that Greenfield run-off rates are maintained. Within Critical Drainage Areas there are more stringent requirements (typically limiting flows to the present day 1 in 10 year event). Sustainable drainage should use natural processes wherever possible rather than underground infrastructure so that the multiple benefits of increased amenity and biodiversity are delivered.

As highlighted above, your councils have obligations under the WFD and should look to restore watercourses, including opening culverts, to more natural state.

Yours sincerely

MARCUS SALMON Sustainable Places Planning Specialist

End 2

Subject: Submitted via Web Site

Form namespace is www.southhams.gov.uk/FORM_V2EMAILCONTACT

The following information was received from the form southhams.gov.uk-article-3399 comments Regarding 'Our Plan SH' - Please note I would like to be kept up to date with the Local Plan as it develops. I appreciate the deadline was 20 June, but my main comment to the Forward Planning team is; - Adopt CIL and identify a new Totnes 'bypass' route and bridge to solve congestion (funded by CIL). Regards, Alex. oref name Alex Lessware email formorigin https://www.southhams.gov.uk/article/3399/community-team submittime 25/06/2014 10:37

Shaping the future to 2031 Response form

For office use only All comments should be received no later than Reference number …………………...... 5.00pm on Friday 20th June 2014. Date acknowledged ......

Your details

Name Peter Swallow on behalf of KEVICC Community College

Job Title (where relevant) Director

Organisation Hopwood Swallow LLP (where relevant)

Address and Please’s Passage Telephone number Postcode High Street Totnes, Devon, TQ9 5QN

Email address

Do you think that we have identified the right topics for Our Plan? (pages 6/7)

Yes X No

If you have answered “No”, please tell us what other topics you think we should consider.

Generally the regulation 18 Consultation document covers the appropriate topics, but more emphasis should be

given to individual wellbeing, through sport and recreation throughout the district.

Do you think that we have identified the right challenges for People? (page 12)

Yes No

If you have answered “No”, please tell us what other challenges for People you think we should

consider. Do you think that we have identified the right challenges for Place? (page 13)

Yes No If you have answered “No”, please tell us what other challenges for People you think we should consider.

Is there anything else you think Our Plan should contain?

Yes No If you have answered “No”, please tell us what else you think Our Plan should cover.

Keeping in touch: If you wish to be kept informed of progress with Our Plan in South Hams, please tick here X

Peter Swallow 11.07.2014 Signature Date

(A typed name is acceptable for electronic submission)

Please return this form by 5pm on Friday 20th June 2014 to:

Email: [email protected] Post: Strategic Planning Team, Follaton House, Plymouth Road, Totnes, TQ9 5NE

For any enquiries please call 01803 861234

To keep up to date with Our Plan progress, follow us on Twitter @OurPlanSH, find us on Facebook (www.facebook.com/ourplanSH) our visit our website www.southhams.gov.uk/ourplan

Shaping the future to 2031 Response form

For office use only All comments should be received no later than Reference number …………………...... 5.00pm on Friday 20th June 2014. Date acknowledged ......

Your details

Name Peter Swallow on behalf of Devon & Cornwall Farmers Ltd

Job Title (where relevant) Director

Organisation Hopwood Swallow LLP (where relevant)

Address and Please ’s Passage Telephone number Postcode High Street Totnes, Devon, TQ9 5QN

Email address

Do you think that we have identified the right topics for Our Plan? (pages 6/7)

Yes X No

If you have answered “No”, please tell us what other topics you think we should consider.

Generally the regulation 18 Consultation document covers the appropriate topics, but more emphasis should be

placed on employment provision and supporting the economy throughout the district.

Do you think that we have identified the right challenges for People? (page 12)

Yes No

If you have answered “No”, please tell us what other challenges for People you think we should

consider. Do you think that we have identified the right challenges for Place? (page 13)

Yes No If you have answered “No”, please tell us what other challenges for People you think we should consider.

Is there anything else you think Our Plan should contain?

Yes No If you have answered “No”, please tell us what else you think Our Plan should cover.

Keeping in touch: If you wish to be kept informed of progress with Our Plan in South Hams, please tick here X

Peter Swallow 11.07.2014 Signature Date

(A typed name is acceptable for electronic submission)

Please return this form by 5pm on Friday 20th June 2014 to:

Email: [email protected] Post: Strategic Planning Team, Follaton House, Plymouth Road, Totnes, TQ9 5NE

For any enquiries please call 01803 861234

To keep up to date with Our Plan progress, follow us on Twitter @OurPlanSH, find us on Facebook (www.facebook.com/ourplanSH) our visit our website www.southhams.gov.uk/ourplan