Little Silver Lodge, Stevenstone, Torrington, Devon EX38 7HX Tel: 01805 622076
Local Plan Consultation Torridge District Council Riverbank House Bideford EX39 2QG 12 th March 2013
Dear Sirs
Northern Devon Draft Local Plan
I am writing to provide comments in respect of the Consultation Draft of the North Devon and Torridge Local Plan. As a resident of Great Torrington my comments are in respect of the development strategy for the town as a whole, and specific sites proposed.
It is appropriate to suggest the town of Great Torrington is near its realistic limit of growth due to landscape constraints – the hilltop position, river Torridge, and Great Torrington Commons etc. The town is in a linear formation and cannot grow any further in a linear direction whilst remaining a sustainable community. The town is already several miles long from end to end east to west, and people do not walk this distance between home and school/work/services but tend to drive. Lengthening the town further, as the plan proposes through allocation of employment land at GTT2, would only exacerbate this. More effort should be made to develop sites in the more central areas around the town. This view is reflected in the SHLAA site assessment reference SHA/GTT/15, which whilst considering residential use nevertheless states that this site ‘lies divorced from any built form’ in Great Torrington, as it is separated by the sports pitches. DCC Highways reference this site as being ‘remote from town’ and the site assessment also states that ‘development would form an inappropriate tongue of built form into the countryside’.
Employment
Whilst job creation needs to be given a priority focus in Great Torrington, this should be in a planned way and should focus on:
Town centre - retaining and improving the independent nature of the town centre and ensuring the usage of central properties encourages investment and vibrancy.
Regeneration of brownfield sites - the old employment sites must be regenerated as a matter of urgency – the creamery site and the former meat plant. The local plan has the ability to push regeneration of these sites by enabling some higher value use classes, particularly residential, within the sites or near the sites. This may mean allocating a wider area around each factory site, in order to increase values and ultimately to bring these sites back into use. There should not be a greenfield allocation of employment land while these two sites remain unused. The NPPF fully supports this approach to regeneration and job creation, prioritising brownfield sites above greenfield, and this should be given particular weight in the context of the SHLAA views that development at GTT2 on a greenfield site would form an ‘inappropriate tongue of built form into the countryside’. Hatchmoor Common Lane (GTT3) – this site is allocated for employment uses in the current Torridge District Local Plan. This site should remain and be protected for employment uses as it is a natural extension to the existing Hatchmoor Industrial Estate and is sited alongside the road link (known as Hatchmoor Common Lane) which is primarily used for industrial traffic, and which joins the main B3232 to Barnstaple. Within the SHLAA the site to the west of Hatchmoor Common Lane, site reference SHA/GTT/13, is not considered suitable for residential development as it lies adjacent to the principle employment area for the town.
Dartington Crystal site – thought needs to be given to this site. The appropriateness of employment use in this location, accessed through a residential suburb, should be questioned, as it may not be ideal for neighbouring residents or for the growth of Dartington Crystal themselves. Ideally the draft local plan should encourage the relocation of Dartington Crystal to a more suitable site that enables better access for visitors and deliveries, and that gives room to grow. This would then enable residential development on the Dartington site, perhaps accommodating c. 100 houses in a central location to the core of the town where residents could easily access schools, shops, pubs and jobs. It would be reasonable to suggest that this scenario could occur within the timescale of this plan and that this should be included as an ambition. The SHLAA supports this view, deeming SHA/GTT/5 (the Dartington Crystal site) as developable for 54 residential units, and as being promoted by the landowner and as being available for development from 2014.
Sports, Recreation, Open Space
I would make a considerable objection to the loss of the previously allocated sports pitches which are now covered by the proposed GTT02 employment land allocation. There is no evidence base to suggest the sports pitch allocations are no longer required by the community, and in fact if the community is to grow by 474 houses then surely there is an even greater requirement for sports pitches. The SHLAA identifies the same issue with regard to SHA/GTT/15 – that it is not developable as it is required for playing pitches, and there is no justification that these are not required.
The draft Local Plan leaves Great Torrington falling far short of other locations in terms of the amount and quality of recreation space it provides for the town. The central ‘park’ near the football ground is tiny and insufficient for the town’s needs. As the draft Local Plan points out, Great Torrington has a tourism niche, however the town needs to attract more visitors to come into the town centre rather than just visiting Rosemoor or Dartington Crystal. Victoria Park in Bideford and Rock Park in Barnstaple play a very strong role in attracting families and visitors into the towns, and Great Torrington should aspire to something on a similar scale.
Residential
As per my second paragraph in this response, I have strong objections to the proposals for residential sites which are seemingly plonked on the map of Great Torrington with scant regard for the overall shape of the settlement, the clustering of nearby land uses, and/or transport access. Accepting that the community can and should take a small amount of residential growth, far more effort should be taken to ensure this is provided in locations where people may actually want to live. The delivery of residential development may also have an important role to play in ensuring the delivery of brownfield sites in order to provide centrally located jobs for the community. The SHLAA process identifies a wide range of sites considered developable for residential use, and that in general terms provide for a far more sustainable community in built form through the proximity of housing. Employment, town centre, transport links and services. Sites that should be allocated for residential include:
GTT4 – Dartington Fields – 60 houses - just about acceptable, as alongside existing houses, although far from town centre GTT5 – Burwood Lane – 60 houses - acceptable, alongside existing houses Burwood Lane+ - 166 houses – a wider site identified in the SHLAA, ref SHA/GTT/7 GTT7 – School Lane – 50 houses - acceptable, alongside existing houses Dartington Crystal site – 54 houses, in a housing area and close to town centre, schools etc Adjacent to Meat Factory - 9.69 acres – 115 houses, could provide connectivity and enable site to be regenerated, good footpath links, central to town shape and easily walkable to town centre, schools etc GTT1 – Creamery site – 106 houses, SHLAA considers this site developable as a mixed use scheme ref SHA/GTT/11
Total – 611 (vs the 330 proposed in the draft Local Plan – total of sites GTT4, GTT5, GTT7 and GTT3)
GTT2
I have specific concerns about the proposed allocation at GTT2, and as previously stated most of these concerns are in fact raised in the SHLAA assessments evidence base reference SHA/GTT/15:
• Settlement shape and layout – GTT2 increases the linear nature of the settlement shape, and does not help create a cohesive and sustainable community. The majority of people would not walk here but would drive. The care home development and the sports pitches/rugby club here have already capped the eastern spread of the Hatchmoor Industrial Estate and have provided a natural ‘end point’ for the town at its eastern extremity. It would be very poor spatial planning to then revert to further employment land beyond this point, and this would destroy any logical sense of place in this area of the town . • Landscape - the site is very open and is an important setting for the town. This open setting is even referenced at 10.201 in the draft Local Plan as ‘somewhat visible’! This site is a rural gateway to Great Torrington, and with its particularly open and attractive landscape setting supports Great Torrington’s tourism role. • Agricultural need - the Defra Agricultural Land Classification (England and Wales) identifies this site as one of the higher quality areas of agricultural land in northern Devon, rated as a Level 3 site. (There being no Level 1 land in northern Devon and minimal Level 2). This is borne out by the fact that this large level field with good access is used regularly for cropping. Based on the growing requirements for food, alongside the backdrop of an encouragement of sustainable communities producing food for local needs, there again needs to be an exceptionally strong justification for an employment use on this site when there are viable and preferable alternative options. Retention of the site for future playing field use enables the site to be used for food production in the interim. • Recreation and sports - Torridge District Council have not undertaken an assessment of the needs of their communities for future recreation space, so there is no case to suggest this site is no longer required for playing pitches. It is suggested that as there is expected to be future housing growth in the town then this site will indeed be required in the future. There are few other options for such playing pitches/recreation space to be delivered in and around Great Torrington due to the topography and other constraints around the town. This site is level, very accessible, and well located to both the existing rugby pitches and to the schools, so it is suggested there is no justification to support the loss of this playing pitches allocation from the previous local plan. • Heritage - this site has been identified as being archaeologically significant due to the 1646 civil war ‘Battle of Hatchmoor’, as this area is the exact site where the Parliamentarians based at Stevenstone attempted to ambush the Royalist forces defending Great Torrington. This is well documented in letters and texts from Fairfax, Hopton and Wogan, amongst other accounts. Based on this historical significance the employment allocation would need to prove the sequential test to justify the development of this site. With 2 brownfield regeneration sites failing to be allocated as a priority to GTT02 the sequential test has failed already. • Highways - used for employment uses this site would generate an increase in traffic movements of heavy goods vehicles in particular. This proposed site is located to the east of the town, and is generally not well located to the wider transport network. There are significant steep hills at Langridge Ford meaning access to the site via the B3227/Umberleigh/South Molton route is not appropriate. Trucks arriving via Bideford or Barnstaple would be required to travel all the way through the town to reach this site.
Overall, there needs to be much greater thought as to the optimal locations within and around Great Torrington for the key land uses of housing and employment. If Great Torrington is not properly planned it will not be a place where people want to live and spend time, and nor will it be a place that attracts jobs and investment.
I have specific concerns over the proposed allocation of GTT2 for employment uses, when other sites have not been considered. This concern in exacerbated as this decision making has not been made on a robust or up-to-date evidence base – as I understand it the joint North Devon and Torridge Employment Land Review, commissioned in autumn 2012, was not provided to the council at the time the draft plan went out for consultation. In addition the SHLAA evidence base, which is up to date and reflects the current economic climate (mid 2011) seems to have been blatantly and entirely disregarded.
I have concerns that the residential allocations are not central enough to the core of the town, and that opportunities are being missed to regenerate the former creamery and meat factory sites. Both sites could be delivered, with both employment space and housing, with more considered allocations that include residential uses to increase values and therefore viability. Landownerships appear to support this strategy.
Finally, with particular comment on the proposed allocation GTT2, I would suggest that any benefits of employment use here are far outweighed by the negative impacts of development here to the community as a whole, particularly when there are preferable and deliverable alternative solutions.
Please find an alternative plan attached below to support the suggested alternative strategy for the town – I think you will agree it enables a far more sustainable approach where development is much more closely related to the town centre and key services, and which also enables economic growth and is deliverable.
Yours sincerely
Andrew Vernon