St Austell, St Blazey and China Clay Area Regeneration Plan - Consultation Summary Table

Introduction

Consultee Summary of Comments Received CC Comment Action RSPB  General concern expressed about lack of focus on the Reference to environment should be Text Cornwall environment and that the plan would mean the loss of the made within any context provided. amended to Office opportunity to deliver the re-creation of a heathland However, the natural and historic highlight landscape in this post-mining environment environment receives significant environmen protection through existing national, tal euro- and supranational legislation and legilsation designation and policy. This plan will not and remove these considerations this position strengthen should be clarified in the final text. We key do consider that the plan has lost its focus principles in and strength with regards to the low terms of carbon agenda and local distinctiveness low carbon which should be amended. focus. Natural  Supports the Plan’s aspirations No comment No change England CPRE  Welcomes and supports the preparation of this plan for the The Regeneration Plan (RP) was Design of Cornwall area, although feels its presentation could be improved. presented plainly due to time constraints Plan  Objects to the sequencing of the plan in advance of, and its and to ensure consultees focused on the amended status as an interim document until the Core Strategy is content. The final version will be subject and weight adopted. It is felt that the plan’s status and democratic to in-house design. It is considered attributed validity would be questionable at best. appropriate to prepare an interim plan to the plan given the context to what is happening in to be the area however, the weight attributed clarified. to the plan will only increase if its policy is supported through the Core Strategy process. Carlyon  Concerned re the lack of public finance for the regeneration, There is some grant funding being spent Evidence Parish and the Plan’s relationship to Parish Plans. in the area and this information should be base to be Council highlighted in the supporting evidence amended to base. include Parish Plans are material considerations information to planning decisions. The aim is to help on public deliver their objectives however; we funding. accept there will be circumstances where there may be a clash or Parish Plans may be silent on a particular issues. The proposed policy requires developer to engage with communities and achieve broad community support. Cornwall  The enabling of regenerative development in the Plan area is No comment No change Develop- time-critical, and cannot wait until the Core Strategy is in ment place. Accordingly CDC fully supports this enabling document Company as a matter of principle. Robert  The plan requires enhanced publicity and consultation via a The RP has been consulted on widely and No change Rowett, range of media, due to its potentially major impact locally subject to press notices and coverage. local Any proposals that come forward would resident also be subject to statutory consultation. St Austell  “Generally there was a lot of support for the document,” and Minor changes acknowledged and Text Town the Town Council submitted a number of minor suggestions amended where relevant to final draft. amended Council for revised wording. where relevant. Barton  The weight to be attributed to the Plan should be clearly The adopted RP will be a material Text to be Willmore articulated; and its targets clearly linked back to national consideration and its weight will increase amended to planning planning guidance, the saved local plan and the emergent as its principles become part of the clarify plan agents, Core Strategy. emerging Core Strategy. status acting for Given the impending replacement of Mercian existing local plan policy and national Consider Develop- planning policy, circulars and guidance producing ments with the National Planning Policy guidance Framework it was not considered wise to note specifically reference existing policy and referencing guidance as we want the plan to have policy when sufficient longevity. In the RP RP adopted. preparation reference was made to Core Strategy Issues Papers and also RP Review papers were produced to examine existing policy. It may however be appropriate to produce a supporting statement which makes direct policy references when the RP is adopted. CPRE  The plan is not currently fit for purpose. Without alterations, Comments acknowledged and plan Plan Cornwall and if it were a DPD, it would be deemed unsound. redrafted to provide greater clarity. amended to provide greater clarity. Goonvean  Supports the overall objectives of the Plan and much of its No comment No change Ltd, China detail. Clay and Aggregates Producer St  The Plan is yet another document of words without No comment No change Stephen’s substance, that fails to instil the confidence that Cornwall Residents Council can ever get anything right. Assoc. CSJ  The Plan suffers in being too general and not offering any The plan was prepared to be a timely Plan planning certainty to prospective developers. Clear direction and a response to the opportunities represented amended to consultants proposal map would help. by Convergence and existing development provide on behalf of pressure. Taking into account the time greater Amy constraints and the wide range of issues clarity. Property over a large area an open criteria based Develop- policy was considered the best possible ments Ltd. approach. It is our intention to continue to work on the spatial implications of the plan and as the Core Strategy emerges greater certainly should also evolve. Savills on  The status of the plan and its relationship to the Development The adopted RP will be a material Text to be behalf of Plan should be clarified, in order to reduce the potential for consideration and its weight will increase amended to Devonshire legal challenge. as its principles become part of the clarify plan Homes emerging Core Strategy, this should be status clarified.

Big Picture

Consultee Summary of Comments Received CC Comment Action Clerk  Queried how the boundary was decided – Luxulyan Parish not The boundary used replicated that of the No change Luxulyan included although it has China Clay workings. Strategic Investment Framework for the Parish area. Council Cllr Bain  Querying why Luxulyan has been excluded. The boundary used replicated that of the No change Strategic Investment Framework for the area. Cllr Bull  Querying why Luxulyan has been excluded and requesting its The boundary used replicated that of the No change inclusion. Strategic Investment Framework for the area. Head-  Broad agreement with the big picture and suggestions of the No comment No change teacher of Plan Penrice Community College Natural  Specific reference should be made here to the following: the Area based review papers were produced Text England implications of climate change for development to be which examined environmental issues amended to delivered under the plan; the environmental values of the however reference to environment should highlight area; the role of green infrastructure in delivering be made within any context provided. The environmen development that is truly sustainable; and a study of the best natural and historic environment receives tal way of improving the existing network of trails and pathways significant protection through existing legislation in the Plan area. national, euro- and supranational and legislation and designation and policy. strengthen This plan will not remove these key considerations, and this position should principles in be clarified in the final text. We do terms of consider that the plan has lost its focus low carbon and strength with regard to the low focus. carbon agenda and local distinctiveness which will be amended Robert  Questioned the extent of genuine local need for more The driver for the RP is not housing rather No change Rowett, dwellings to facilitate economic growth, jobs and local infrastructure, however it is accepted that resident it is likely housing will be needed to make schemes viable. Overall growth is a decision for the Core Strategy, evidence within people and housing issues papers (Core Strategy and RP) indicate the need for new housing both affordable and open market in the future. RSPB  Disappointed that the ambitions of the plan for the natural Area based review papers were produced Text Cornwall environment are so slight. which examined environmental issues amended to Office  Maps should be included to highlight areas of environmental however reference to environment should highlight constraints be made within any context provided. environmen Constraint mapping was produced for the tal area and is part of the evidence base. legislation The natural and historic environment and receives significant protection through strengthen existing national, euro- and supranational key legislation and designation and policy. principles in This plan will not remove these terms of considerations this position should be low carbon clarified in the final text. We do consider focus that the plan has lost its focus and strength with regards to the low carbon agenda and local distinctiveness which should be amended David  The plan would inappropriately usher in an overprovision of The driver for the RP is not housing rather Text Bloxham, housing to facilitate economic growth, jobs and reviewed to private infrastructure, however it is accepted that strengthen individual it is likely housing will be needed to make position in schemes viable. The policy states that relation to schemes will only be acceptable if they housing. deliver positive change to the area and unlimited numbers of new housing would not meet this. The Core Strategy will establish growth levels up to 2030 and provide a growth target however, it is acknowledged there is a period of time between now and Core Strategy adoption end of 2012 where Cornwall is in a difficult position with respect to housing numbers. Large developments take a long time to plan before they even reach planning application stage and the risks of large-scale delivery in this intervening period is low. CPRE  Supports the statement that: “ the driver for this plan is No comment No change Cornwall regeneration not housing.” Goonvean  Contrary to the inference in this section, the Cornish clay Comment acknowledged paragraph Text Ltd, China industry is more than the fortunes of the largest company should be changed to accommodate this amended to Clay and involved. Significant reserves remain, many jobs have simply information if appropriate in final draft. reflect Aggregates been outsourced and the industry will continue to provide outsourcing Producer permanent, long-term, non-seasonal employment for many of China years. Clay jobs Terence  The Plan should make it clear that speculative and mediocre The plan aspires to deliver the highest No change O’Rourke proposals will not be allowed to prejudice longer-term quality developments which should be planning regeneration projects. delivered through a range of sources. agents, on Each case will be judged on its own behalf of merits. Eco-Bos ltd Head-  Mr Parker used his consultation response as an opportunity to The opportunities at Penrice School are No change teacher of outline his aspirations to relocate the school to the north of noted. Penrice St Austell - as part of a wider scheme whereby developers Community Wainhomes would then develop the existing school site for College housing. Robert  There is no mention of horse-riding, which is very popular Reference to horse riding is a detailed Ensure plan Rowett, locally. consideration it is considered that it is or evidence local part of a general aim of improving access. base resident Reference to horse riding and provision of includes bridleways should be made in the final reference to plan or evidence base. bridleways along with cycleways St Stephen  Wish to flag up that given that the Parish has been subject to Concern is noted. The driver for the RP is Review Parish extensive housing development over the last 20 years – both not housing, rather sustainable economic Plan to Council open market and affordable – there is concern that the growth, jobs and infrastructure, however clarify proposals of the plan could lead to a further intensive round it is accepted that it is likely housing will position of housing development and associated problems. be needed to make schemes viable. The with policy states that schemes will only be regards to acceptable if they deliver positive change housing and to the area and unlimited numbers of new land supply housing would not meet this. The area has a 5 year land supply against the Structure Plan. St Austell  Welcomes the document, especially the recognition of wider No comment No change Bay Parish transport infrastructure problems and the A390. Council Carlyon  The Plan is no more than a wish-list The plan does establish high level No change Parish aspirations. Council The China  Concern expressed that existing infrastructure provision The RP wants to deliver infrastructure but Further Clay under-run should not be continued by development the lack of public funding means we are spatial work Community encouraged by the Plan not in a position to meet all the needs will be Network  Suggested that the Plan be more specific in its statement of upfront. We will strengthen the undertaken infrastructure requirement projects, and be more detailed – infrastructure requirements where to feed into i.e. in the manner of the Town Framework Plans currently possible. The Town Framework the Core being developed for towns elsewhere in Cornwall. methodology seeks to identify locations Strategy. for urban extensions it is therefore not necessarily directly relevant to smaller scale villages. Alongside this document we are produced cell based appraisals of the areas and known opportunities this will continue to be developed after the RP is adopted to feed into the Core Strategy. Geoffrey  The Plan seems to be blind to the existence and needs of Best practice guidance requires No change White, local older people. developments to take into account a resident  Developed areas have lower life expectancies than rural ones range people. It is considered that life – therefore major development in this area (as encouraged expectancy takes in a range of factors, by the Plan) could reduce life expectancy. with no evidence that well designed new developments would have a negative impact on life expectancies. Barton  The Plan should acknowledge the disparity caused by the Comment acknowledged at this stage it is No Change Willmore focus of recent growth and expansion being on the east side not the intention to go to this level of planning of St Austell, and specifically seek to encourage development detail however, this may be an argument agents, on the west side. for supporting development to the west of acting for St Austell. Further spatial work will be Mercian undertaken to feed into the Core Develop- Strategy. ments Alan Coode,  The rationale for the Plan area boundary should be stated in The boundary used replicated that of the Text private the document Strategic Investment Framework for the amended to individual area. highlight reason for boundary Peter  The Plan’s efforts to encourage the creation of jobs must take Comment acknowledged the plan should Ensure Plan Wyper, into account that the area has a large pool of unskilled seek to enable a range of jobs. and private labour. evidence individual base acknowledg e full range of jobs Jo Hudson  The Plan should focus on business stimulation; housing Concern is noted the driver for the RP is Review private should follow. to facilitate economic growth, jobs and Plan to individual infrastructure and not housing. However, clarify housing is likely to be needed to make position schemes viable. with regards to housing and land supply

Vision and Key Principles

Consultee Summary of Comments Received CC Comment Action RSPB  The list of Key Principles should be extended so that The purpose of the plan is primarily to Text Cornwall proposals should also show that they: deliver green deliver economic growth, jobs and amended to Office infrastructure; respect environmental capacity; conserve infrastructure and the principles were highlight natural resources; and protect and enhance biodiversity. drafted to reflect this. The natural and environmen  The unique opportunity should be taken here to develop a historic environment receives significant tal regional eco-park on a landscape scale. protection through existing national, legislation euro- and supranational legislation and and designation and policy. This plan will not strengthen remove these considerations this position key should be clarified in the final text. We principles in do consider that the plan has lost its focus terms of and strength with regards to the low low carbon carbon agenda and local distinctiveness focus which should be amended. Natural  Although dealing with the social and economic sides of The purpose of the plan is primarily to Text England proposed regeneration, this section fails to address the deliver economic growth, jobs and amended to critically important environmental aspect. infrastructure and the principles were highlight  The list of Key Principles should be extended so that drafted to reflect this. The natural and environmen proposals should also show that they: deliver adaptation and historic environment receives significant tal resilience to climate change; maintain and enhance natural protection through existing national, legislation ecosystems; pro-actively seek opportunities for landscape euro- and supranational legislation and and and biodiversity enhancement; and include specific proposals designation and policy. This plan will not strengthen for green infrastructure. remove these considerations this position key should be clarified in the final text. We principles in do consider that the plan has lost its focus terms of and strength with regards to the low low carbon carbon agenda and local distinctiveness focus which should be amended. South West The society makes the following comments: The existing clay trails are well used and Text Office,  Despite the rural nature of the Plan area, the document is should be acknowledged where possible. amended to British very urban in its approach; It is considered that the key principles include Horse  The document fails to acknowledge that as existing, the clay should be redrafted to include the greenspace Society area has become a very successful outdoor recreational area provision of greenspace. The need for provision with an extensive network of trails; interconnected spaces is current best within the  The plan lacks a cohesive approach, particularly with respect practice and it is not considered key to the provision of green infrastructure; and necessary for the plan to repeat this. All principles.  Consideration is not given to the impacts that developments applications would need to consider their that may arise under the Plan would have upon the wider impacts under existing environmental plan area. legislation.

Crime  The list of Key Principles should be extended so that It is considered that this criterion is a key No change Prevention proposals should also show that they have been designed to part of good urban design and is therefore Design integral to achieving the highest quality Advisor, ensure that all communities are safe, and feel safe for all. design and environmental standards. Devon & Cornwall Police Goonvean  One of the Key Principles should be that proposals should It was the intention to support existing Text Ltd, China show that they would support existing businesses and businesses however, this could be made amended to Clay and encourage their growth. more explicit within the key criteria. reflect Aggregates support to Producer existing businesses

Emerys This representation raises a number of concerns as to the validity In redrafting the plan it was considered Text Planning, and status of the plan. It then continues to comment on the Key that some of the accompanying criteria amended on behalf of Principles A-I (as set out in para 24) as follows: was repetitive and unnecessary. The key Wainhomes A. This principle lacks substance and does not give clear principles are the main policy statement Ltd guidance; and only further explanation is necessary B. The supporting text contradicts this principle, and so creates if they are not self explanatory. The key confusion as to what standard is actually being sought; principles will be reviewed and redrafted C. Clarity is required as to what actually counts as a job – are where necessary. retail, tourism and construction to be included? It is accepted a range of jobs could be D. St Austell is already served by a railway station, therefore no counted which is wider than traditional new infrastructure is required. Secondly, national guidance employment space. makes it clear that any requested financial contributions must Proposals would need to meet 106 tests if be restricted to infrastructure that is directly related to that mechanism is being used to secure specific proposals. Lastly, the policy should specify a benefit. Rail infrastructure is not just minimum of 40% affordable housing. stations, it could be improving disabled E. The policy should seek to encourage development which access or increasing train frequency, this maximises non-motorised transport by virtue of its location is relevant. It is not considered F. This principle is likely to direct development to unsuitable appropriate for this policy to override locations removed from urban areas. other affordable housing policies, G. This principle is misleading, as the clay workings are already particularly as a DPD is being produced. bound by conditions to ensure re-instatement, and are not It is accepted that most clay workings classified as previously developed land. have restoration conditions, only sites on H. This objective is mutually exclusive with proposals for former China Clay workings will have to housing address whether it needs safeguarding or I. This criterion is also vague, (as A above). not. The representation concludes by suggesting a revised set of 6 new The suggested key principles are principles. acknowledged.

Terence  Principle E for sustainable travel is too specific, and should be It is considered that establishing a target Text O’Rourke more flexible. gives a starting point for negotiation amended planning  It should be clarified that off-site provision of affordable however, we accept that every applicant agents, on housing will be acceptable in certain circumstances. will not achieve all criteria. It is up to behalf of applicant to demonstrate the accumulated Eco-Bos ltd benefits of each proposal. Existing policy allows for off-site provision in certain circumstances this policy will not change. Cornwall  So called ‘enabling development’ should be explicitly The requirement of enabling development No change Develop- accepted as an integral delivery tool. is accepted in the context of this plan. ment Company Mevagissey  This plan would provide for development that would It is acknowledged that in the detail of No change Parish exacerbate the problems associated with the already many responses there was a call for Council overloaded infrastructure of the wider area, e.g. congestion infrastructure and jobs first. The plan on the A390; flooding and sewerage issues, schools at seeks to deliver these needs but given capacity etc. Infrastructure improvements should precede public and private sector financial house-building. constraints it would be unreasonable to expect all of this to be delivered up front. Each proposal will bring with it specific educational requirements. Pentewan  Pleased to note inclusion in the Plan of requirements to be No comment No change Valley put on developers to include flood alleviation schemes. Parish Council Luxulyan Express a number of doubts as to how the Plan - and The area has a 5 year land supply against No change Parish development that it will bring forward - will address the need for: the structure plan, the plan policy seeks Council  highway and social infrastructure to be improved and high quality development. Proposals will maintained; need to show they comply with the key  jobs to be genuinely secured; principles and do deliver benefits.  ‘affordable’ houses to be actually affordable by local people; and  Developers to be held to promises to deliver the infrastructure phases of development in addition to more lucrative swathes of housing. Treverbyn  The Parish has experienced an intensive growth in dwelling The concern is acknowledged. We cannot No change Parish numbers recently, without a sufficient accompanying require new development to resolve all Council provision of infrastructure. The Parish is concerned that the existing problems, our requests have development encouraged by the Plan should not exacerbate to be reasonable. However we do not this situation, but instead that it must address these shortage consider that not advocating any issues. development in the area would achieve the best outcomes as in this situation it is highly unlikely that funding will be prioritised to the area. We accept that new development can not solve all the existing problems but it can assist if directed to meet existing needs. Barton  The key principles of para24 should be applied flexibly, so as It is accepted that not all proposals can Following Willmore not to negate the individual merits of any proposal. achieve everything. Agreed financial review planning  Financial viability and the submission of open book appraisals viability will only be relevant where we reference to agents, should not have to be a pre-requisite for the determination of are not achieving something we want or open book acting for planning applications (as para 25 suggests) to quantify amount of enabling financial Mercian development acceptable. appraisals Develop- has been ments removed Gary  The Plan should include means to explicitly encourage mid- Concern acknowledged but this is not the No change Lemin, scale development - and not be so focussed upon large-scale role of the regeneration plan in this private projects. interim period, this will need to be individual considered through the Core Strategy. David Orr,  Without a spatial element to the Plan, the delivery of Concern acknowledged it is intended to No change private ‘regeneration benefits’ may have little sustainable impact. consider this through the Core Strategy individual process Mr/Ms  The statistics presented in the plan highlight the need for the Funding that the Council has is being No change Sweet, council to concentrate its efforts on regenerating existing directed to existing communities for private communities - rather than backing large-scale, eco-town example through ‘U Choose to Retrofit’. individual developments. However public funding is limited and we do not consider that not advocating any development in the area would achieve the best outcomes as in this situation it is highly unlikely that funding will be prioritised to the area. We accept that new development can not solve all the existing problems but it can assist if directed to meet existing needs. Peter  The plan should include the criterion to be applied to all It is acknowledge the requirement for Text Wyper, applications: “Will this development further the aim of sustainable development needs to be amended private making St Austell and its hinterland the green capital of strengthened individual Cornwall?” Barbara  The key principles should include, “ Prime agricultural land There is no grade 1 and only small areas No change Wyper, must be preserved…” of grade 2 agricultural lands in the plan private area, there are larger areas of Grade 3 individual agricultural land. We do not currently have a breakdown of Grade 3 to it’s ‘a’ and ‘b’ subsets. The Grade 3 land lies largely to the further edges of the plan and around the urban area of St Austell, the China Clay working area is generally of lower quality. One of the key principles highlights the productive use of former China Clay working as a positive attribute the analysis of agricultural land would also direct you to these areas. Gary  The Plan fails to make reference to, take account of, or In this interim status this plan wants to Text Lemin, acknowledge the important sustainable contribution that can deal with the current development reviewed in private be made by self-build residential development. The Plan pressures for large-scale developments relation to individual should instead explicitly support this movement. although it does allow for small-scale supporting exemplars. It does not remove the ability small scale to provide smaller schemes under existing exemplar policy and in this concern will need to be schemes. addressed by the Core Strategy Savills on  The criterion that new proposals should deliver one One of the primary reasons for facilitating No change behalf of employment opportunity per home is both unworkable and development ahead of the Core Strategy Devonshire unenforceable. It is not the role of the developer to be is to deliver sustained economic growth Homes burdened with the need to attract inward investment. and jobs, without this proposals would not be acceptable given the area has a 5 year land supply

Nature and Scale

Consultee Summary of Comments Received CC Comment Action RSPB  The inclusion of greenspace as a key determinant should be Key principles should include the Text Cornwall significantly strengthened. provision and importance of greenspace. amended. Office David  Housing development should be small-scale and in villages, The plan does not seek to drive all No change Bloxham, thus making them sustainable - rather than forcing more development to town-scale developments. private people into live in the towns. This type of discussion is a decision for individual the Core Strategy which this plan will feed into. Tom  Large scale development should be restricted to brownfield Planning policy steers you towards No change Hudson, sites – such as Par Docks; greenfield sites should be so brownfield sites first (many China Clay private maintained. sites are Greenfield because they are individual subject to restoration conditions) however, they are very few brownfield opportunities in the area (see evidence base urban capacity paper) and therefore other opportunities need to be examined. Barton  The high proportion of green space demanded of proposals The greenspace requirements should be a Text Willmore should not be required at the expense of other benefits, eg key principle. amended planning housing and jobs. agents, acting for Mercian Develop- ments CSJ  The requirements for greenspace for all proposals would It is accepted that some schemes such as Text planning undermine the viability of employment schemes, for which it those that are purely employment would amended to consultants is inappropriate. not necessarily need to provide specified with regard on behalf of levels of greenspace, proposal-specific to Amy judgements will need to be made. greenspace Property However, greenspace requirements are Develop- an integral part of the Plan, and it is ments Ltd. appropriate to assert this. Geoffrey  Development on the heathland sections of the Plan area and Any proposals would need to consider the No change White, local resultant loss of habitat would have a seriously adverse impact on biodiversity and protected resident impact on biodiversity – and in particular the cuckoo. species under existing planning legislation. Planning  The requirement for 40% greenspace may act to hinder the It is accepted that some schemes such as Text &Estates delivery of otherwise appropriate development. those that are purely employment would amended to Manager, not necessarily need to provide specified with regard Imerys levels of greenspace, proposals specific to Minerals judgements will need to be made. The greenspace Ltd 40% requirement form part of the accompanying guidance. St Mewan  Concerned that the document does not give due The purpose of the plan is primarily to No change Parish consideration to environmental issues deliver economic growth and highly Council-  The environment of Cornwall would be ruined by high levels sustainable development and informal of development infrastructure provision. Existing planning views policy strongly seeks to protect the environment and any proposals would need to address this. The overall amount of development is a decision for the Core Strategy which will impact on the implementation of this plan. Savills, on  The Plan inappropriately seeks to specify that development The Plan will be a material consideration Text behalf of should exceed the criteria of the statutory test, i.e. that it but it will not replace existing policy, the amended to developers should accord with the Development Plan and any material weight attributed to it will have to be clarify Devonshire considerations. Furthermore the Plan does not reflect the determined on a case by case basis. It status of Homes impending requirement that there will be a new presumption will also feed into the Core Strategy policy plan in favour of sustainable development. for the area.

Design and Environmental Quality

Consultee Summary of Comments Received CC Comment Action Robert  Shouldn’t the dwellings, as exemplars, be required to meet a Very few schemes (other than RSL Text Rowett, higher level than Level 4 of the Code for Sustainable Homes? schemes) in the area achieve level 4, it is amended local acknowledged that the low carbon with resident standards need strengthening. There is regards low also uncertainty over the timeframe for carbon which the government will require code 4 standards as a minimum, which was set at 2016, but may now be moved back, meaning that the levels achieved within the pilot scheme will outperform standards for longer than anticipated.

RSPB  Welcome given to the inclusion of the points of this section – Comments noted changes to be made to Evidence Cornwall subject to suggested modifications. accompanying guidance base Office amended Crime  Pleased to note the comments re the need for proposals to No comment No change Prevention take into account the need to design out crime, and the fear Design of crime. Advisor, Devon & Cornwall Police St Stephen  Welcome the reference to the need to enhance existing Accepted that flooding and drainage a No change Parish drainage systems which should indeed be given high priority high priority for new infrastructure. Council as it has been an ongoing problem in the Plan area. Goonvean  The demand for buildings to be zero-carbon status could lead It is considered that a blanket Text Ltd, China to unaffordable housing and discourage the expansion of requirement for zero carbon would be amended in Clay and existing businesses. extremely challenging, however, the relation to Aggregates ability to achieve zero carbon should be zero carbon Producer given significant weight, this will be standard clarified. Cornwall  Suggest that the following criterion be included in order to Comment acknowledged and should be Detailed Develop- encapsulate urban design principles and assess if proposals: included within any detailed guidance. design ment “Create a balanced mixed-use development based in a well guidance to Company connected network of streets, with buildings creating active include this frontages onto all areas of public realm” information  Similarly proposals involving highway infrastructure should: “aspire to achieving the design principles set out in Manuals For Streets 1 and 2, where they do not conflict with the Council’s highway design standards”. Planning  The requirements of para39 for a range of housing types and There will be flexibility in applying the No change &Estates tenure should be applied flexibly in response to the varied plan but should housing be provided Manager, specific circumstances of each site. proposals should be of a high quality as it Imerys is economic growth and infrastructure Minerals that are the plan driver. Ltd St Dennis  Housing developments within the villages should be small- This comment is acknowledged, the plan No change Parish scale so as not to destroy their existing characters. requires engagement with the local Council community in bringing forward any proposals. This concern needs to be taken forward the policy for the area within the Core Strategy. Gary  Stronger encouragement should be given for house design to Key principles to be amended to Text Lemin, be low-energy usage by making use of passive solar gain etc strengthen low carbon requirements amended private individual David Orr,  The encouragement in the Plan for proposals to be Plan referred to BfL silver standard No change private exceptional should be made more specific, e.g. the BfL score individual of 14 or more (ie Silver)

Jobs and Skills

Consultee Summary of Comments Received CC Comment Action RSPB  A further point should be added to insist that buildings should Local supply chain is an important way of Text Cornwall be constructed from sustainably sourced and locally achieving the plans criteria. It is amended to Office distinctive building materials considered that a stronger emphasis on reflect local local distinctiveness and the importance distinctiven of the environment in this should be set ess out Carlyon  One job per household is too low a target in this low-wage Achieving 1 job per household may sound No change Parish area. low but is an increase to ‘usual’ planning Council requirements. It is not considered possible to increase these standard further at this time particularly in light of the financial climate Terence  The Plan should explicitly accept that some flexibility of There will be flexibility in applying the No change O’Rourke phasing in the delivery of jobs and homes will be acceptable plan, which is stated, however proposals planning  Similarly some flexibility should be sanctioned re the must demonstrate they are of a high agents, on acceptability of non-local of materials and products, quality and delivering the economic and behalf of particularly in the early stages of development. infrastructure needs, without which Eco-Bos ltd support will not be given. Cornwall  The space criterion at para 50 ( i.e. that 1 job ≈ 30 sq.m. This comment is acknowledged, it would Text Develop- employment space) is too simplistic, and should be expanded be for the economic strategy amended ment to specify different areas per use class. accompanying any plan to evidence the Company number of jobs created. Affordable  Should the reference to employment opportunities be more The requirement for jobs and economic Guidance to Housing specific as to whether retail jobs are being included as sought growth does not preclude retail jobs confirm Officer, under the plan? This would clarify the position with regard to providing the locations for such retail jobs Cornwall supermarket-led proposals. development are acceptable. are included Council Tom  St Austell town centre must continue to be supported as the Existing planning policy protects existing Guidance to Hudson, main area of retail activity. Any proposed large [out of town] town centres and recognises the existing confirm private retail developments – such as the one at St Mewan – should retail hierarchy. Each proposal would retail jobs individual be resisted. need to be judged on its own merits. are included Barton  Retail jobs should not be down-valued; they provide The requirement for jobs and economic Guidance to Willmore important and accessible opportunities for the local growth does not preclude retail jobs confirm planning community at all levels and are therefore drivers for providing the locations for such retail jobs agents, economic development. development are acceptable. There will be are included acting for  It is often not possible to deliver jobs hand in hand with flexibility in applying the plan, which is Mercian housing: the Plan should allow for this possibility. stated however proposals must Develop- demonstrate they are of a high quality ments and delivering the economic and infrastructure needs, without which we would not wish to support them. CSJ  This section contains no reference to retail jobs; this is a The requirement for jobs and economic Guidance to planning serious flaw as these could help to deliver transformational growth does not preclude retail jobs confirm consultants benefits, particularly in St Blazey. providing the locations for such retail jobs on behalf of  This omission reflects tired, outdated planning thinking, out development are acceptable and respect are included Amy of line with PPS4 the existing retail hierarchy. Property Develop- ments Ltd. Planning  The principle of one job per dwelling may be difficult to The plan does not seek to deliver solely No change &Estates provide on smaller developments, and should therefore be housing development. Whilst there will Manager, applied flexibly. be flexibility in applying the plan, Imerys proposals must demonstrate they are of a Minerals high quality and delivering the economic Ltd and infrastructure needs else we would not wish to support them.

Infrastructure

Consultee Summary of Comments Received CC Comment Action Carlyon  A comprehensive review of flood risks in the area should be The Council together with Environment Evidence Parish carried out in advance of any large-scale development Agency are currently undertaking flood base to Council modelling across large parts of the area, include this will help us assess flood and surface reference to water impacts and begin to identify flood risk solutions. This work will need to continue modelling to be progressed, it will be relevant to and be assessing and designing individual updated proposals and the need for strategic with results contributions. Terence  The Plan should be more explicit in its explanation as to why Background specifies the existing and No change O’Rourke the need for a new A391 link to the A30 is essential to efforts projected issues with the A391. planning to unlock the regenerative potential of the Plan area. agents, on behalf of Eco-Bos ltd Barton  With regard to para 57, developers should not be expected to Existing legislation dictates what can and No change Willmore contribute to infrastructure aspirations over and above those can’t be requested within s106 and planning directly related to the proposal planning conditions. The provision of agents, infrastructure however may be the reason acting for for accepting a scheme. Mercian Develop- ments Environ-  The Plan should provide a framework for ensuring that The Council and the Environment Agency Evidence ment regeneration delivers positive outcomes for communities that are currently working in partnership to base Agency are currently affected by flooding, and sewerage network and deliver flood modelling of the area. It is amended treatment plants that are at capacity. also considered that there remains further  In line with the above, the ‘effective management of flood work to do which will include working with risk’ should be a Key Principle of the Plan. SWW particularly looking at the sewerage  Due to its vulnerability to all types of flooding, the relocation network and treatments plants – this of all or part of the town centre of St Blazey should become should be progressed. the subject of consultation. It may be that the development It is acknowledged that St Blazey has opportunity marked 5 on the map (near St Blazey Gate) particular flooding problems and that a might help to facilitate this move. further dedicated piece of work on St  A Water Cycle Study (WCS) should be undertaken for that Blazey may be useful and this should be part of the Plan area that drains to the 2 Water Treatment explored in addition to the plan and Works at Par and Menagwins. Regeneration should be able to through the Core Strategy. help deliver the necessary capacity improvements for these It is not considered that managing flood plants. risk needs to be a key principle because it is covered by existing legislation and guidance. Gary  The list of specific infrastructure needs at para57 should This request will be clarified with Include Lemin, include a bypass for Trewoon. highways reference to private road individual improveme nts including the A390 Barbara  As existing infrastructure is already overstretched, this should We cannot require new development to No change Wyper, be addressed before any [large scale] development is resolve all the existing problems, our private started. requests have to be reasonable. However individual we do not consider that not advocating any development in the area would achieve the best outcomes as in this situation it is highly unlikely that funding will be prioritised to the area. We accept that new development can not solve all the existing problems but it can assist if directed to meet existing needs. Jo Hudson  Infrastructure should be scheduled to match in time and scale Infrastructure would normally be secured No change private the development which it is to serve. via section 106 and its phasing would be individual part of this discussion Savills, on  There is a risk that the combined effect of the Key Principles, Plan needs to be amended to be clearer Text behalf of (particularly with regard to contribution to infrastructure) on what is required, if proposals can not reviewed developers would be to render otherwise acceptable schemes unviable provide the identified needs particularly in Devonshire terms of economic growth there would Homes not be a reason to accept it. The Plan aims to set standards that recognise what a community requires for a development to be viable, not just look at economic viability.

Transport

Consultee Summary of Comments Received CC Comment Action Robert  Consideration should be made for the possible rise in the use Accepted that bridleways not mentioned Text Rowett, of horses as a sustainable mode of functional transport. in the plan this should be reviewed amended to local include resident bridleways Roger  The Plan overlooks the important contribution that the use of Referred to Highways they advise that No change Nunn, motorcycles can make to the interests of sustainability. They their main focus in relation to motorcycles private ease congestion, are more fuel-efficient, require less land for is safety related as the number of m/c individual parking and are more affordable than cars. Accordingly casualties remains high and we continue transport principles of the Plan and development proposals in with co-ordinated road safety agencies to the Plan area should demonstrate how the use of motorcycles tackle this problem in LTP3. We do as a transport option has been taken in account, promoted acknowledge the environmental benefits and provided for. being promoted through the use of m/c and we are currently investigating the possibilities of allowing m/c to use our bus lanes across Cornwall. That said the sustainable argument for modal shift and the use of the motor bike is still undecided. For example it could be said that getting 4 people in a car, particularly if the vehicle is an energy/fuel efficient vehicle is more sustainable than getting 1 or 2 people onto a 1000cc motor bike.

Carlyon  Although the intentions expressed in the Plan may be It is accepted that the plan has high No change Parish laudable, the Parish doubts the chances of successful aspirations but it is considered that we Council implementation and uptake. need to take proactive action rather than do nothing Cornwall  At para 57 reference should be made to existing limits to The plan does not negate the 106 tests in Text Develop- demands that local authorities can make of developers with current guidance. Accepted that reviewed. ment regard to infrastructure contributions – in order not to unduly Newquay airport is influential. Company raise community expectations.  Although just outside the Plan area, reference should be made to Newquay Cornwall Airport (NCA) as it: acts as a gateway to Cornwall (and the Plan area); has a significant transformational potential for the area; is an important employment location and could provide a proportion of the jobs needed for the area to thrive; and can provide skills training. Barton  There needs to be a degree of realism with regard to the Sustainable travel is considered to be Text Willmore achievability of the 50% sustainable travel target - as it will important particularly given the amended planning be dependent upon external factors. congestion in the area however, it is with regard agents, accepted that this has to be treated to acting for realistically in a rural areas. It is sustainable Mercian considered that the wording of the 50% travel Develop- target should be reviewed. targets ments St Dennis  The problem of heavy trucks passing through the Plan area’s Issues related to heavy trucks are No change Parish villages should be addressed. understood but it is accepted it is difficult Council  Public transport provision should be improved, not only for this plan to address this other than to between the villages and the main towns – but between the advocate infrastructure improvements. villages themselves. Improvements to public transport are needed and separate strategies are being implemented to progress this and new proposals would need to contribute towards public transport provision.

Community

Consultee Summary of Comments Received CC Comment Action St Stephen  Reference to the need to encourage inward investment and It is accepted that this is a difficult area Text Parish relocation of business could be open to misinterpretation and the text will be reviewed amended Council should be deleted. Barton  Re para 74, it is outside the scope of any developer to ensure The reference to entrepreneurs was Text Willmore that entrepreneurs relocate into an area. aimed at ensuring a range of amended planning  Clarification on the weight to be attributed to public support accommodation was provided so that agents, is needed within the Plan. people could relocate their businesses and acting for that the area’s profile was raised, Mercian however this text will be reviewed. Develop- The increased emphasis on local views is ments being promoted through the governments Localism Bill and it is considered proper that new polices take this into account. Savills, on  The criterion that proposals must show broad community The increased emphasis on local views is No change behalf of support is misguided; many schemes acceptable in planning being promoted through the governments developers terms meet objection due to less than robust reasons or as a Localism Bill and it is considered proper Devonshire result of misunderstanding. that new policies take this into account. Homes

Previously Developed Land or Former China Clay Workings

Consultee Summary of Comments Received CC Comment Action Robert  The Plan should not aspire to re-use former china clay Current legislation and guidance would No change Rowett, workings that have become naturalised. require applications to consider the local  Such places support a wider biodiversity range than farmland existing biodiversity and impact on resident mono-cultures protected species on any site that comes forward. RSPB  Concerned that the inclusion of this requirement in its current Impacts on biodiversity would need to be No change Cornwall wording would have an adverse impact on biodiversity. assessed in line with existing legislation. Office Goonvean  Currently dormant pits still contain many workable mineral Proposals that come forward on former No change Ltd, China reserves, and so they should be safeguarded – not sterilised china clay working will have to evidence Clay and by development. that they are not sterilising important Aggregates mineral reserves. Producer Cornwall  There should be an undertaking in the Plan to retain and Geo-diversity would need to be assessed No change RIGS Group enhance the geodiversity which was the foundation of the in line with existing legislation. industrial heritage and local distinctiveness of the area – in a manner similar to the commitment made to biodiversity made in para 43. Geoffrey  The recent floods show how difficult putting housing in Current planning regulations require No change White, local quarries will be – parts of the Eden project were still closed 3 assessment of flood risks and Flood Risk resident months after the rains. Assessments to be submitted this will not change

Minerals

Consultee Summary of Comments Received CC Comment Action Carlyon  There exists no definitive map of reserves – so how will The existing Minerals Local Plan contains No change Parish regeneration avoid sterilising mineral reserves? a map and this remains the most up-to- Council date reference until it is replaced Gary  International future demand for Cornish china clay will The plan seeks to protect critical reserves No change Lemin, remain strong; the plan should acknowledge this, and the private reserves should be protected. individual

Coast and Countryside

Consultee Summary of Comments Received CC Comment Action Robert  Existing open space should be preserved for recreational use Some private land has been opened up No change Rowett, for public use and permissive trails local created such as the Clay Trails which is resident welcomed, however it is not considered that this should thereafter prevent further development providing access is still provided. Such an approach could make landowners more reticent to provide permitted access. RSPB  Concern expressed that development encouraged by the Plan Environmental considerations are covered Text Cornwall would have an adverse impact on a number of ecologically by existing legislation and policy, this amended Office important sites and threatened bird species. policy will not override this, and should be clarified. Parish Cllr  Very concerned re the lack of any explicit reference to the The World Heritage Site (WHS) was Text Stocker, St World Heritage Site (WHS) at Charlestown. Unsympathetic included in supporting review papers but amended to Austell development locally could undermine the quality of the site – it is acknowledged it is not referred to in include Town and in turn prejudice its international status the plan and this should be amended. reference to Council WHS Historic  The plan does not address itself sufficiently to aspirations for The World Heritage Site (WHS) was Text Environ- the protection of heritage assets in the area – most notably included in supporting review papers but amended to ment Charlestown Harbour as part of the WHS. In this regard it it is acknowledged it is not referred to in include Advice currently fails to meet the requirements of PPS5. the plan and this should be amended. reference to Team, However, it is not considered necessary to WHS. Cornwall replicate policy and legislation covered by Council other guidance. The plan does not remove the requirement to adhere to this.

Barbara  The skyline of this attractive area must be respected. Existing legislation would require the No change Wyper, visual impact of proposals to be assessed private this will not change. individual Jo Hudson  Green areas to be preserved should be clearly designated as Existing legislation and guidance protects No change private part of the Plan designated open areas and the plan individual requires new greenspace to be provided

Monitoring

Consultee Summary of Comments Received CC Comment Action Terence  BREEAM assessments of employment buildings should only Accepted the concern about the size for Evidence O’Rourke be required for major developments, due to their high cost. BREEAM, it will be for proposals to show base planning their environmental credentials. amended agents, on Accompanying guidance should behalf of acknowledge this concern. Eco-Bos ltd