Joint Local Plan

MM9

JOINT LOCAL PLAN

SCHEDULE OF AND SUMMARY RESPONSE TO REPRESENTATIONS ON MAIN MODIFICATIONS

December 2018 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

As set out in our letter of 5th January 2017, the essential transport infrastructure elements of the plan had been established in advance of the transport hearing sessions. Two matters were then discussed at the hearings which related to whether the plan, which was submitted in advance of the essential transport infrastructure elements being identified, makes effective provision for the timely delivery of the infrastructure as identified. Two questions were going to be considered further by the inspector: Firstly, whether a minor modification was necessary in order to provide suitable sign posting to the essential transport infrastructure elements of the plan and, Secondly, whether it was necessary or helpful to reinforce the Lisa Highways 42 1002528 General guidance contained within NPPF by including a minor modification to Policy Dev 31 to include "Planning permission will be granted only where the impact of development is not McCaffrey England considered to be severe’. Following the hearing HE subsequently wrote to the Programme officer at Plymouth, for the attention of the Inspector setting out the proposed wording, to ensure that the impact of growth set out in the Plan could be safely accommodated and without a severe operational impact on the SRN. It is noted that the minor modification proposed by HE has not been incorporated in to the Main Mods, are you able to confirm that the inspector has considered this point and has concluded that the modification is not necessary, hence why the proposed modification isn’t included?

During the hearings I made representations on behalf of Stoke Gabriel Neighbourhood Plan in regard to housing policy for housing needs including enabling the use of exception sites for self-build, so I welcome the incorporation of TTV new on this issue. However, I have been unable to find any policy recognition of the ongoing water drainage and sewer overload General - issues in Stoke Gabriel, and note several other comments in regard to insufficiency of the sewer and storm drain network in several parts of South Hams. 243 1002903 Leaf Lovejoy Stoke Gabriel Please ensure that policy that prevents additional housing being constructed without addressing the capacity of local sewer networks to effectively both drain and treat combined sewer outflows, and to imporve local drainage structures.

Greenspace Allocation - Miss Bethan Request to amend the Riverford boundary area from Strategic Greenspace, to Neighbourhood Greenspace, due to inaccurate and flawed information within Plymouth City Councils 162 1190532 Plym Valley Roberts own site assessments, submitted to the Planning Inspector in April 2018. Please see attached report. (Riverford)

Jillings Heynes Diocese of MM1 – the change is noted but it still does not remove our objection made previously regarding this part of the Plan in respect of addressing the point whereby greenfield sites that 194 964187 MM01 Ed Heynes Planning Ltd Plymouth perform well in terms of meeting established sustainability criteria should not be discounted in terms of delivering development;

Once this consultation has closed, can the following concerns be clearly addressed going forward.... When will the 'Final' JLP be published? As time goes by how will any new Mr Graham changes/attempts to change be managed and will they go through consultation? How will they be communicated? As time goes by, will all proposed developments that could have 239 1191222 MM01 Palmer impacts on the final, agreed JLP be subjected to the rigorous checks adopted by the JLP process? Such that the JLP does not become a theoretical exercise, where the idealogy applied is simply overtaken by uncontrolled, unchecked developments.

MM1 Policy SPT1 (3i) MM1 in relation to Policy SPT1 (3i) proposes to re-cast the wording set out in the submission draft plan so as to provide that: “The effective use of land is made for development through optimising the reuse of previously developed sites, therefore reducing the need for green field development ...” (modifications underlined) Whilst this objective is laudable and is supported by Sutton Harbour Holdings, it risks being an empty expression of aspiration unless it is underpinned by concrete, practical provision to ensure its delivery. The nature of the problem is exemplified by the scale of under-utilised previously developed land within Plymouth City which is not promoted for re-development in this Plan, whilst extensive tracts of peripheral greenfield land, in the setting of a Grade 1 listed building and the Dartmoor National Park, with highly challenging topography, a poor relationship to existing services and facilities and inadequate (and potentially unfunded) road access at Woolwell are allocated for development. Mr Will Montagu Sutton Harbour 307 1095702 MM01 Edmonds Evans Holdings plc Accordingly, it is considered that the City Council’s proposed Main Modification 1 should be accompanied by the following companion/explanatory text: “Where previously developed land of significant scale (> 5 ha) is known to be available (or is likely to become available) for redevelopment and remains under-utilised in relation to its potential to deliver housing and other appropriate uses, the City Council will engage with the owners of such land and produce a Development Brief to ensure that redevelopment proposals come forward in accordance with the principles of sustainable development at the earliest possible opportunity during the Plan period.” Reason: To ensure that previously developed land is brought forward to meet the ongoing development needs of the City in a timely fashion; and to avoid the unnecessary release of increasingly remote and environmentally sensitive greenfield sites.

Rockspring Mr Alistair Boyer 327 1191547 MM01 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd

1 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) SUPPORT with strong reservations. No changes have been made to acknowledge that natural assets should be protected, conserved and enhanced for future generations in line with the concept of intern-generational equity as enunciated in UNGA's principles of sustainable development. Other suggested changes have not been resolved through the proposed modifications: To bring the policy in line with biodiversity policy through the use of the established term "net gains" in biodiversity not the ambiguous "overall gains". And to bring in Ms Victoria line with law and policy on the biodiversity through the use of "conservation" in addition to protection and enhancement To properly reflect the mitigation hierarchy of first to avoid, 364 1095125 MM01 Tanner- then mitigate, and as a last resort, compensate. "iii. Pollution and adverse environmental impacts of development are avoided, minimised and effectively mitigated where Tremaine unavoidable, and as a last resort compensated for;" To include landscape character as part of a sustainable environment. This is different from local distinctiveness "v . Local distinctiveness , landscape character and sense of place is respected, maintained and strengthened through high standards of design." These have not been addressed by the MM or the AM.

Reference paragraph 3.17 Figure 3.2 and the new paragraph to follow 3.17. This whole paragraph brings in a new variation to the meaning of sustainability, without any definition and thus in effect negates any conclusion made from the assessment of the criteria in Figure 3.2. This seems to change a measurable policy to one that can never be used to assess any level Mr Mike of sustainability. Adding this new paragraph would mean planners and developers could virtually ignore sustainability as an issue. 22 1010886 MM02 Wynne- Powell I believe the new paragraph should be removed completely, as bringing in new sentences that have no legal meaning is pointless and counterproductive to achieving the purpose of the JLP and effectively makes table 3.2 irrelevant.

Thurlestone Parish Council Policy SPT 2 Sustainable linked neighbourhoods and sustainable rural communities NEW PARA TO FOLLOW 3.17. We support the clarification that the LPAs will rely on neighbourhood 86 1002318 MM02 Sue Crowther and plans to support the delivery of sustainable development in the Sustainable Villages of the TTV Policy Area. One of the main legal requirements (Basic Conditions) of a neighbourhood Neighbourhood plan is to demonstrate that it contributes to the achievement of sustainable development. Plan Emery Wainhomes Mr John 208 893384 MM02 Planning (South West) M M 2 : Policy SPT2 narrative The proposed modifications reflect those agreed with the Council at the hearings, and are supported. Coxon Partnership Holdings Ltd. Ms Victoria 365 1095125 MM02 Tanner- SUPPORT. Tremaine

MM3 – It would seem counter intuitive for a Local Plan to have a lower expectation of housing supply from ‘sustainable’ villages, where development is expected and planned than for windfall sites, where development is unplanned. We cannot understand why the assumed rate of windfall development over the time period 2017-2034 is significantly greater than the previous assumption over a slightly longer period of 2016-2034; the only conclusion can be that it is increased to allow the maths to add up and justify reductions elsewhere within the figures. The way in which the figures are framed provides an artificial suppression of delivery from a sustainable source of housing, i.e. the NPPF (para.7) sates that “the purpose of the planning system is to contribute to the achievement of sustainable development”, the JLP has identified certain settlements as ‘sustainable villages’, ergo development in these 6 1074071 MM03 Neal Jillings Place Land LLP locations is ‘sustainable development’ subject to detailed technical consideration. Clearly, the scale of development that is deemed sustainable will relate, to a degree, to the scale of the sustainable village to which it is attached. However, an artificial and arbitrary ‘cap’ on the level of development that would be acceptable as imposed by a reduction in the 720 figure to 550. The reduction in this figure should not be reduced because there are less settlements defined as sustainable villages; it should mean that the target required (i.e. the 720 figure) is met by development in fewer sustainable villages. This obviously requires that amendments to policy TTV30 and accompanying figure 5.8, which I turn to below.

Change required – the sustainable villages target is maintained at 720

Mrs Sally Hello I would like to point out that the chart of site allocation totals by settlement type for the TTV area, figure 5.1 on page 190, has not been updated to reflect the figures as amended 8 1187856 MM03 Challiss by MM3 and is incorrect. For instance the sustainable villages allowance should be 550, not 720. Yours, Sally Challiss 9 1019942 MM03 Glen Wise (Hand written letter)

Dear Strategic Planners, I am writing to voice my opposition to the Joint Local Plan. I understand that planning inspectors have allocated 504 houses in Dartington and almost another 500 in Totnes. It is unfair and unsustainable, to grow our village by 63% in 20 years. It will damage our countryside, rural character and choke our roads. I object to the development of 96 1190458 MM03 Nisha Toppin the green fields of Broom Park and Sawmills West. In particular I object to the modifications that have been proposed to the Plan - I am concerned about policies which: 1. Allow developers to build 2077 SURPLUS houses in South Hams- 27% above even the Joint Local Plan’s assessment of housing needs.

I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of 101 1018487 MM03 Gill Gairdner housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. MM3

2 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 106 1018748 MM03 Hazel Fuller South Hams will exacerbate commuting, countryside loss and urbanisation. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of Anthea housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 110 1013363 MM03 Scholefield from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 114 1017978 MM03 D Elphick from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of Barbara housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 118 1017979 MM03 Henry from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 122 1190518 MM03 A Richards from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of Miss Rosa housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 126 1013608 MM03 Bloomberg from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of McConnell- housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 130 1190520 MM03 Bloomberg from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 134 1190522 MM03 Janet Wilce from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 138 1190523 MM03 W Ollis from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing allocations 142 1190525 MM03 Pam Gorman from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. MM3 para24 SPT3 It is unclear from this policy whether, where a Neighbourhood Plan is not in an advanced stage, an accepted planning application to build houses at sites which have been examined through the SHLAA, count towards the housing numbers for that Sustainable Village. Dorothy 159 1040549 MM03 Gennard Therefore it would be helpful if the policy were modified to confirm the position regarding SHLAA housing applications before a Neighbourhood Plan (NP) has been completed, or where no NP plan is being prepared.

3 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Read this note in combination with the Revised Housing Topic Paper (October 2018) produced as an Addendum to the MMs document. The surplus of housing supply provision in the South Hams compared with housing requirements is significant. See fig. 3.4 of MM3 showing the 5-year land supply provision is actually adequate for 9.1 years (being 3,416 houses compared with 1,874 of need and the latter already includes 5% buffer). Particularly see Revised Housing Topic paper which shows at ES23 that South Hams has a JLP need for 3,624 houses yet the supply proposed within the JLP (and within the MMs) is 5,701, ie a surplus of 2,077 houses. Further, the Revised Housing Topic includes planned intake of 900 houses from West Devon location needs. It is acknowledged that this assumes new commuting from South Hams both across to West Devon and into Plymouth, as well as encouraging new residents into the area rather than into West Devon. All of the above South Hams housing surplus in turn contravenes other MMs within this consultation, eg MM8 relating to SPT11 - Strategic Approach to the Natural Environment. The supposed protection to the wildlife and the community needs for greenspace is being subsumed by the proposed housing in excess Miss Annette 165 1094460 MM03 to the area needs and MM30 Strategy for TTV . Thus within TTV29 (Dartington) there is considerable local objection to the original and the revised number of houses proposed for Morley Dartington village and hamlets, on the basis of the community's greenspace preservation, its wildlife protection and its air pollution concerns. See also MM39 which endorses the minimising of pollution (see DEV2 and NEW PARA AQMAS). Yet the single action which would meet MM8, MM30 and MM39 would be to reduce the excessive surplus South Hams housing set out at MM3 in particular in the TTV29 locations

Reduce the surplus South Hams housing set out at MM3, especially targeting the reduction to meet the needs set out at MM8 (natural environment) and reducing air pollution in accordance with MM39, by focusing on MM30 (TTV29) and Dartington's particularly high over-supply of houses. It already has especially high levels of air pollution and unsuitably high levels of traffic, not in accordance with AQMAs

MM3 I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing 172 1191000 MM03 Joyce Higgins allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. MM3 I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses, which is 27% above even the Joint Local Plan’s Mrs F H assessment of housing needs. Accepting 900 houses from West Devon’s allocation to the South Hams will exacerbate commuting, countryside loss and urbanisation. Removing housing 177 1191008 MM03 Williams allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further concentrate new housing in ‘thriving’ villages, such as Dartington. MM3 I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to 184 1191016 MM03 Pippa Palmer the South Hams will exacerbate commuting, countryside loss and urbanisation. Simon Collier 191 989450 MM03 Linden Homes Please see attached. Collier Planning

Mr Simon Persimmon 206 1191045 MM03 See Attached File Wagemakers Homes

MM3: Policy SPT3 and related amendments to narrative and Annex 2 We refer to our letter of the 16th March 2018 which addressed the geographical basis of assessing 5 year housing land supply. The Main Modifications are out-of-step with the South Worcestershire Local Plan, which the Council incorrectly used to justify its position at the hearings. They also suggest a perverse scenario whereby the very same policies could be simultaneously considered ‘up-to-date’ and ‘out-of-date’ against paragraph 11(d) of the Framework without even considering whether a 5 year supply is being maintained against the overall housing requirement (which is based upon housing need across the entire plan area). Since the examination closed, the PPG has been revised. Paragraph 3-046 provides: “ H o w will areas with joint plans be monitored for the purposes of a 5 year land supply? Areas which have or are involved in the production of joint plans have the option to monitor their 5 year land supply and have the Housing Delivery Test applied over the whole of the joint planning area or on a single Emery Wainhomes authority basis. The approach to using individual or combined housing requirement figures will be established through the plan-making process and will need to be set out in the Mr John 209 893384 MM03 Planning (South West) strategic policies. Where the 5 year land supply is to be measured on a single authority basis, annual housing requirement figures for the joint planning area will need to be apportioned Coxon Partnership Holdings Ltd. to each area in the plan. If the area is monitored jointly, any policy consequences of under-delivery or lack of 5 year land supply will also apply jointly.” Therefore it is clear that there are two options open to local planning authorities for monitoring 5 year supply and the Housing Delivery Test: either over the whole joint plan area, or on a single authority basis. The proposed main modifications Joint Local Plan do neither, as the current distribution does not follow single authority areas. Monitoring the Housing Delivery Test would not be possible, as the areas set out do not align with CLG housing completion returns data, nor the household projections which will be used for at least the next 3 years as part of the transitional arrangements. The interpretation of policy is a matter of law. Having regard to how the housing requirement and distribution has been derived (with Plymouth effectively meeting needs derived in the rural areas), it would represent a fundamental misinterpretation of national planning policy to not monitor 5 year housing land supply across the plan area. The only logical solution is that 5 year supply is monitored across the housing market area in alignment with the evidence on housing need.

4 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Paignton Mr David 217 1094326 MM03 Neighbourhood The Forum supports the proposals as published and in particular those of MM3. Watts Plan Forum

Firstly, I would like to comment on the Revised Housing Topic Paper. The observations below underpin almost all of my further comments- namely that unnecessary damage, pollution, loss of character, countryside, wildlife and urbanisation is due to this JLP accommodating thousands of SURPLUS houses for sale, to in migrants, not local people. Revised Housing Topic paper ( Provision and Supply,) October 2018. I would like to object in the strongest terms to the over allocation of housing both over the area and in particular to the ‘thriving towns and villages’ of South Hams. Table 11a) shows that in the South Hams there is a total surplus of 2077 new houses but in West Devon a shortfall of 1254. On top of this, the paper states, in 3 b) that 900 of West Devon’s allocation of new housing will be built in the South Hams. With restrictions on development in the AONB and Plymouth already taking a huge proportion of the new houses, the burden has been placed upon the designated ‘thriving towns and villages’ of South Hams. It is clear, however that allocating these houses in South Hams is very likely to exacerbate commuting to employment in West Devon and Plymouth, placing more strain on local roads, exacerbating air pollution, unnecessarily increasing carbon output and not delivering self -sufficient, locally focussed communities. This decision will cause enormous damage environmentally, to the character of towns and villages and to the countryside and wildlife; a disproportionate and unnecessary burden on thriving towns and villages swamped by housing that is not needed. Even after all extrapolations are complete to allow for a five year housing supply, the final total housing figure allows for 2077 SURPLUS houses- a 27% ( recalculated at 21%) in the October Housing Topic paper- but Don't Bury still an enormous over supply with no justification. These houses are unnecessary and have skewed the allocation of housing particularly in the South Hams thriving towns and villages, 301 1014585 MM03 Trudy Turrell Dartington Under swelling the numbers allocated well over and above any justifiable housing need. That the figures are over inflated and not related to need has been comprehensively argued by CPRE Concrete in its paper ‘Devon’s Housing Needs Evidence, October 2018’. Looking at the county as a whole, CPRE states that far too many homes are being planned for Devon over the next 10 years - an average of 4,300 would be required per annum as opposed to 5,800 predicted by the various Local Plans. Around two thirds of the new housing provided is to meet the needs of people moving to Devon, whilst home ownership remains predominantly unaffordable to young local households. 41,000 extra dwellings were provided in Devon between 2006 and 2016, while almost two thirds of the increase in the number of households in that time came from people relocating to the area. The predictions are that the rise in dwellings will continue by another 43,000 by 2026, much of it to satisfy inward migration. That the houses are to attract in migration is clear in the paper. That the South Hams, with its reputation for beautiful coast and countryside and historic and famous towns, will attract buyers from elsewhere is stated. The JLP seems to be simply allocating housing for developers to sell- on the back of protected landscapes, natural beauty and established, ‘named’ places that migrants will know. West Devon, although beautiful with historic towns, is lesser known outside of Devon and so I believe that is why planners have decided to reallocate these surplus homes to South Hams. They may lie empty in West Devon but in South Hams will be more marketable. Explained in this way, the JLP becomes less of a rational, needs based, planning exercise and more an estate agents brochure. In short, there is no justified need for these surplus 2077 new houses and no reasoned explanation for accommodating them in the South Hams, except for economic reasons and to the advantage of developers.

Rockspring Mr Alistair Boyer 331 1191547 MM03 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd Nicole PCL Planning 338 1191551 MM03 Baker Estates Please see attached. Stacey Ltd

MM3 (Policy SPT3) We note the main modification to Policy SPT3 (Provision for new homes) including changes in text and changes to the housing supply figures set out in Figure 3.3 (Overall Housing supply). It is noted that this still includes an overall housing provision of at least 26,700 homes in the Plan Area during the plan period 2014-2034. In general the proposed modifications at MM3 are supported in so far as the Policy Area housing requirements are separate and non-transferable. The JLP now proposes that only housing proposals within each Policy Area will be considered to contribute to meeting the housing requirement for that Policy Area. Any shortfall in the supply of housing sites in a Policy Area must be made up within that Policy Area, and cannot be remedied in the other Policy Area. To some extent this is a logical approach although the real world practicalities of this are a little Jonathan Walsingham Land Value 346 1096270 MM03 unclear. The approach would mean that in the event there is a shortage of housing in the TTV Policy area this could be made up by proposals in either South Hams or West Devon. The Chick Planning Alliances (LVA) geographical size of the TTV Policy Area will mean that housing proposals will not necessarily be delivered in the area of need and could result in unsustainable growth in areas with limited access to public transport. At Paragraph 3.27 the MM’s state that Figure 3.4, supported by the evidence set out in the Revised Housing Topic Paper, January 2018 and Addendum October 2018, shows that a five year land supply of specific deliverable sites can be demonstrated across the Plan Area, and for the two policy areas at the point of adoption. Concern is still raised regarding the ability of the strategic sites to maintain a 5 year supply of housing. This is compounded by an increasing reliance on windfall sites to fill the gap at the expense of prioritising development on available planned sites which ensure that an appropriate level of sustainable growth is achieved.

White Young 353 1105974 MM03 Robin Upton Bloor Homes Please see attached. Green Lauryn 357 1191915 MM03 Please see attached (Dartington) Reeves

5 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

SUPPORT with reservations. The separation of the allocations amongst the policy areas can be positive in terms of managing the distribution of growth between Plymouth and the Ms Victoria TIVPA where demand for housing is high. However, if a housing shortfall occurs in the TIVPA owing to there being a lack of land for housing which does not harm the AONBs, then 366 1095125 MM03 Tanner- there is a sustainability argument for allowing the general housing requirement being transferred. Support the exclusion of AONB villages from the TIVPA total supply in line with the Tremaine Inspector's recommendations in the Post- Hearing Advice Note. Support the separate housing supply buffers for the TIVPA.

Amanda 387 1018467 MM03 Please see attached (Dartington) Chadwick

392 1191638 MM03 Adam Griffin Please see attached (Dartington)

397 1191642 MM03 Angla Hornby Please see attached (Dartington)

Agata 402 1191646 MM03 Please see attached (Dartington) Krajewska Ashley 407 1191654 MM03 Please see attached (Dartington) Parsons

412 1191660 MM03 Andrea Prew Please see attached (Dartington)

Mrs A 417 1191664 MM03 Please see attached (Dartington) Robinson Miss Ali 422 1094187 MM03 Please see attached (Dartington) Roscoe Mr Ashton 427 1114209 MM03 Please see attached (Dartington) Chadwick Cllr Andy 432 1191668 MM03 Please see attached (Dartington) Simms 437 1191677 MM03 A Smaldon Please see attached (Dartington) 442 1191679 MM03 Alan Whele Please see attached (Dartington) 447 1191680 MM03 Mrs Aydin Please see attached (Dartington)

452 1191681 MM03 Barbara Keen Please see attached (Dartington)

457 1191683 MM03 Bree Long Please see attached (Dartington)

462 1191687 MM03 Brian Mascall Please see attached (Dartington)

Carol 467 1191688 MM03 Please see attached (Dartington) Ballenger Christina 472 1097444 MM03 Please see attached (Dartington) Bennett

477 1191707 MM03 Chris Harding Please see attached (Dartington)

482 1017437 MM03 Clare Hornsey Please see attached (Dartington)

487 1191709 MM03 Mr C Mapsen Please see attached (Dartington)

492 1018458 MM03 Carole Powell Please see attached (Dartington)

497 1191712 MM03 Miss C Watt Please see attached (Dartington) Denis 502 1191715 MM03 Please see attached (Dartington) Anderson

507 1097433 MM03 David Barnett Please see attached (Dartington)

6 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) David 512 1097428 MM03 Please see attached (Dartington) Duncombe David 517 1191719 MM03 Please see attached (Dartington) Ferguson

522 1191720 MM03 Donald James Please see attached (Dartington)

Dick 527 1191723 MM03 Please see attached (Dartington) Kassabian 532 1191726 MM03 D Smaldon Please see attached (Dartington) 537 1191729 MM03 David Vitler Please see attached (Dartington) Doirrey 542 1191730 MM03 Please see attached (Dartington) Watterson 547 1191732 MM03 D Young Please see attached (Dartington) Elizabeth 552 1014700 MM03 Please see attached (Dartington) Callaway 557 1191743 MM03 E Ferguson Please see attached (Dartington) Elizabeth 562 1191745 MM03 Please see attached (Dartington) Turner Esther 567 1097402 MM03 Please see attached (Dartington) Watson

572 1017430 MM03 Fiona Bicknell Please see attached (Dartington)

Frances 577 1191752 MM03 Please see attached (Dartington) Brodrick Anne 578 1191751 MM03 Please see attached PDF (Dartington) Woodend 587 1191756 MM03 Colin Bastin Please see attached PDF (Dartington) 589 1191757 MM03 Fiona Tilley Please see attached (Dartington) 597 1191759 MM03 Claire Stoyle Please see attached PDF (Dartington) 602 1191766 MM03 Don Tucker Please see attached (Dartington)

603 1191762 MM03 Graham Black Please see attached (Dartington)

612 1191771 MM03 Ella Baillie Please see attached (Dartington)

613 1191772 MM03 Geoff Caplan Please see attached (Dartington)

622 1018737 MM03 EA Potter Please see attached (Dartington) Geoffrey 623 1018138 MM03 Please see attached (Dartington) Nickolls 632 1191777 MM03 Gail Johnson Please see attached (Dartington)

633 1191776 MM03 Graham Prew Please see attached (Dartington)

Gordon 642 1002916 MM03 Please see attached (Dartington) Riddel Gordon 644 1191780 MM03 Please see attached PDF (Dartington) Woodend Isaac 652 1097358 MM03 Please see attached (Dartington) Bloomberg 657 1018485 MM03 D Hannaford Please see attached (Dartington)

660 1191782 MM03 I Underdown Please see attached (Dartington)

7 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

667 1191784 MM03 H Hannaford Please see attached (Dartington)

669 1018187 MM03 J Rich Please see attached (Dartington) 677 1191786 MM03 Lisa Daix Please see attached (Dartington) 682 1191788 MM03 Hon Ashton Please see attached (Dartington) 687 1191790 MM03 L Keel Please see attached (Dartington) 688 1016052 MM03 Heidi Orrell Please see attached (Dartington) 697 1191793 MM03 M Cole Please see attached (Dartington) Richard and 698 1018437 MM03 Jeanne Please see attached (Dartington) Hughes 707 1191795 MM03 Helen Welsh Please see attached (Dartington)

712 1016272 MM03 Isabelle Orrell Please see attached (Dartington)

717 1191800 MM03 Ian Smail Please see attached (Dartington)

722 1191801 MM03 John Callaway Please see attached (Dartington)

Ref: Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. I object to the proposal to transfer 900 houses from West Devon’s allocation to the South Hams as this will exacerbate issues arising from commuting, countryside loss and urbanisation of a rural area especially as the modifications also propose to 728 1015453 MM03 Karin Jordan withdraw the allocation in villages in the AONB and instead move these allocations to already burgeoning villages such as Dartington which are at risk of becoming towns and losing their rural character. In addition, the total allocation for the South Hams is 27% above the JLPs local assessment of housing needs which is excessive and unecessary. Revised Housing Topic Paper Addendum, October 2018 (pageVII) is not positively prepared as it does not achieve unmet need or sustainability; neither is it justified.

I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 731 1191806 MM03 Ros Durston South Hams will exacerbate commuting, countryside loss and urbanisation. We object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 735 1095210 MM03 Barry Reeves South Hams will exacerbate commuting, countryside loss and urbanisation. We object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 739 1191810 MM03 Anita Cole South Hams will exacerbate commuting, countryside loss and urbanisation. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 743 1017703 MM03 Helen Tune South Hams will exacerbate commuting, countryside loss and urbanisation. Miss Selena I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 749 1094766 MM03 Mara South Hams will exacerbate commuting, countryside loss and urbanisation. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 755 1014631 MM03 Josh Zatz South Hams will exacerbate commuting, countryside loss and urbanisation. I object to the Revised Housing Topic Paper Addendum, October 2018 (pageVII) that allocates a surplus of 2077 houses. Accepting 900 houses from West Devon’s allocation to the 759 1095118 MM03 Sharon Ellis South Hams will exacerbate commuting, countryside loss and urbanisation. 764 1191814 MM03 T Lang Please see attached (Dartington)

769 1191815 MM03 Joel Chadwick Please see attached (Dartington)

Janice 774 1018151 MM03 Please see attached (Dartington) Duncombe James 779 1097475 MM03 Please see attached (Dartington) Fordham John 784 1191817 MM03 Please see attached (Dartington) Greenhalgh 789 1097375 MM03 Joy Hanson Please see attached (Dartington)

794 1191818 MM03 Jenny Heaton Please see attached (Dartington)

799 1191819 MM03 Jane Hext Please see attached (Dartington)

8 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 804 1191820 MM03 June Hext Please see attached (Dartington) 809 1191821 MM03 J Hodgson Please see attached (Dartington) 814 1191822 MM03 John Lee Please see attached (Dartington) 819 1014649 MM03 J Marshall Please see attached (Dartington) Lesley 824 1191823 MM03 Please see attached (Dartington) Marshall 829 1191824 MM03 Josh Orrell Please see attached (Dartington) Jonathan 834 1191828 MM03 Please see attached (Dartington) Reeves Josephine 839 1013778 MM03 Please see attached (Dartington) Unwin 845 1073274 MM03 Joanna Watt Please see attached (Dartington)

850 1018385 MM03 Jacqui Wilkins Please see attached (Dartington)

Arthur 851 1191829 MM03 Please see attached (Dartington) Durrant 854 1191830 MM03 Kevin Childs Please see attached (Dartington) 864 1018193 MM03 Alex Sharp Please see attached (Dartington) Katherine 865 1191832 MM03 Please see attached (Dartington) Smaldon 874 1191833 MM03 Kevin Weale Please see attached (Dartington)

879 1014279 MM03 Lucia Fausset Please see attached (Dartington)

880 1191834 MM03 Cass Wynne Please see attached (Dartington) 885 1191835 MM03 Lorna James Please see attached (Dartington) 894 1191836 MM03 L Korda Please see attached (Dartington) Mr and Mrs T 899 1191837 MM03 Please see attached (Dartington) Locker 904 1191860 MM03 Michael Cox Please see attached (Dartington)

909 1191861 MM03 Mary Hobden Please see attached (Dartington)

915 1018405 MM03 Mavis Jones Please see attached (Dartington) Dr Malcolm 920 1017707 MM03 Please see attached (Dartington) Purcell 925 1191882 MM03 Mick Wicks Please see attached (Dartington) Mr Nigel 930 1094768 MM03 Please see attached (Dartington) Backhouse Elizabeth 939 1018413 MM03 Please see attached (Dartington) Williams Matthew 944 1191933 MM03 Please see attached (Dartington) Heming 949 1191934 MM03 Nigel Hinks Please see attached (Dartington) Michael 951 1191935 MM03 Please see attached (Dartington) Brown Mr Martin 960 1073037 MM03 Please see attached (Dartington) Crawford 961 1017617 MM03 P Douglas Please see attached (Dartington)

970 1191936 MM03 Philip R Jones Please see attached (Dartington)

971 1191937 MM03 Matt Harvey Please see attached (Dartington)

9 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 980 1191938 MM03 Pete Reeves Please see attached (Dartington) Rosamund 985 1018175 MM03 Please see attached (Dartington) Bastin Martina 989 1191939 MM03 Please see attached (Dartington) Heming 995 1191943 MM03 Minni Jain Please see attached (Dartington) Ms Mary 1000 1095121 MM03 Please see attached (Dartington) Light Michelle 1005 1191948 MM03 Please see attached (Dartington) McHale

1010 1191949 MM03 Richard Hard Please see attached (Dartington)

Main 1015 1191951 MM03 Please see attached (Dartington) Patterson 1018 1191952 MM03 Rooh Star Please see attached (Dartington) 1025 1191953 MM03 Monika Pike Please see attached (Dartington)

1030 1191954 MM03 Rachel Tucker Please see attached (Dartington)

Marti 1031 1191955 MM03 Please see attached (Dartington) Valentine 1040 1191957 MM03 Sarah Curtis Please see attached (Dartington) 1041 1191958 MM03 Mike Welsh Please see attached (Dartington) 1050 1191961 MM03 Nell Admiral Please see attached (Dartington)

1055 1191963 MM03 Nicholas Keen Please see attached (Dartington)

1060 1191966 MM03 Mr O Clarke Please see attached (Dartington) Oliver 1065 1095333 MM03 Please see attached (Dartington) Tringham 1070 1191968 MM03 T Palm Please see attached (Dartington) 1075 1018745 MM03 Pollie Ash Please see attached (Dartington) Mr Phillip 1080 1094867 MM03 Please see attached (Dartington) Bridge

Philip and 1085 1097512 MM03 Minni Franses Please see attached (Dartington) and Jain

1090 1095641 MM03 Paul Hornby Please see attached (Dartington)

1091 1191972 MM03 Sara Ferguson Please see attached (Dartington)

1100 1191973 MM03 Sandra Hard Please see attached (Dartington) Pamela 1101 1191974 MM03 Please see attached (Dartington) Kassabian SC 1106 1191975 MM03 Please see attached (Dartington) Underdown 1115 1191977 MM03 Sue Wicks Please see attached (Dartington) 1120 1191978 MM03 T Backhouse Please see attached (Dartington) 1125 1191980 MM03 Tanya Bell Please see attached (Dartington) 1130 1191981 MM03 Tim Grevatt Please see attached (Dartington) 1133 1191979 MM03 Peter Mingo Please see attached (Dartington)

10 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

1140 1191982 MM03 Vicky Hadland Please see attached (Dartington)

Patricia 1145 1191983 MM03 Please see attached (Dartington) O'Carroll 1146 1191985 MM03 Vivien Hinks Please see attached (Dartington) 1155 1018364 MM03 R & VM Keel Please see attached (Dartington) Phil 1156 1191986 MM03 Please see attached (Dartington) Sheardown Miss MR 1165 1018574 MM03 Please see attached (Dartington) Brand 1168 1191987 MM03 V J May Please see attached (Dartington) 1175 1191993 MM03 R Orrell Please see attached (Dartington) 1180 1191995 MM03 Richard Pike Please see attached (Dartington)

1185 1191997 MM03 Rosie Roberts Please see attached (Dartington)

1190 1191998 MM03 Roger Shelley Please see attached (Dartington)

Mr & Mrs RH 1195 1018009 MM03 Please see attached (Dartington) Tripp 1200 1191989 MM03 Debbie Feld Please see attached (Dartington) Mr R 1201 1018359 MM03 Please see attached (Dartington) Valentine 1210 1018420 MM03 Janice Bragg Please see attached (Dartington) 1215 1192003 MM03 Susan Boal Please see attached (Dartington)

1216 1192004 MM03 John Chapple Please see attached (Dartington)

1225 1192007 MM03 Jane Parker Please see attached (Dartington) 1230 1017953 MM03 John Platt Please see attached (Dartington) 1235 1192006 MM03 S Carrol Please see attached (Dartington) 1236 1192010 MM03 Lise Platt Please see attached (Dartington) Sandra 1245 1018749 MM03 Please see attached (Dartington) Crawford

1246 1018584 MM03 Marion Baker Please see attached (Dartington)

1255 1192013 MM03 Mike Bridger Please see attached (Dartington)

Susan 1259 1018841 MM03 Please see attached (Dartington) Goldsworthy

1261 1018583 MM03 M Green Please see attached (Dartington) 1270 1018446 MM03 M Lang Please see attached (Dartington) Mrs Susan 1271 1018172 MM03 Please see attached (Dartington) Greenhalgh Margaret 1280 1192017 MM03 Please see attached (Dartington) Lewis Philomena 1285 1192019 MM03 Please see attached (Dartington) Wynne 1290 1018169 MM03 Sandra Lee Please see attached (Dartington) Mr Roger 1291 1093100 MM03 Please see attached (Dartington) Nicholson

11 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Susan 1300 1192021 MM03 Please see attached (Dartington) Nancholas Stephen 1301 1192022 MM03 Please see attached (Dartington) Harper 1310 1192023 MM03 S Niemeyer Please see attached (Dartington) Mrs Sue 1315 1017725 MM03 Please see attached (Dartington) Norris Simon 1320 1192025 MM03 Please see attached (Dartington) Patterson Shimako 1325 1018357 MM03 Please see attached (Dartington) Sharpe

1330 1192027 MM03 Susan Weare Please see attached (Dartington)

Timothy 1335 1192030 MM03 Please see attached (Dartington) Hornsey 1340 1192034 MM03 Wendy Cook Please see attached (Dartington) 1345 1192035 MM03 Wendy Fisk Please see attached (Dartington) Simon Collier 192 989450 MM04 Linden Homes Please see attached. Collier Planning Rockspring Mr Alistair Boyer 332 1191547 MM04 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd Nicole PCL Planning 340 1191551 MM04 Baker Estates Please see attached. Stacey Ltd

MM4 – additional para 5.122 Para 5.122 states future redevelopment of the Dartington Estate must be informed by detail contained within the Heritage Impact Assessment. It is our understanding that this relates to the Heritage Impact Assessment produced as part of the evidence base to accompany the JLP. However, this point is unclear and without additional clarification there will be uncertainty surrounding the delivery of development at the Dartington Estate. We propose that the wording of this paragraph should be amended to: ‘It is Andrew Dartington Hall 342 1002035 MM04 Lichfields Jo Talling important that the form, scope, scale and design of development in Dartington is informed by a Heritage Impact Assessment submitted with any major planning applications.” For ‘on Cockett Trust campus’ development the Estate Framework will provide the final agreed detail on the scale, scope and form of future development. This should not be explicitly tied to the overarching Heritage Impact Assessment used to inform the wider JLP and all its sites. It is considered that the revised wording above provides sufficient comfort that any development proposals at the Estate are fully informed by future HIA’s which will cover greater detail than the JLP evidence base document (HE4).

We note that SPT4 has been modified to include an additional 62,580 sqm in addition to the OAN of 312,700. This increases the employment floorspace provided for in the plan by 20% to 375,208m2. It is noted from the updated Employment Topic Paper (October 2018) that the 20% increase is to allow for “churn and healthy choice in employment land”. It is also noted that the additional employment land has not been identified within allocated sites. I would be grateful if you could confirm how the over provision of employment land would be handled through the planning application process. From the updated Employment Topic Paper, it is concluded that the plan does not seek to grant planning permission for Employment Lisa Highways Land in excess of the AON and on this basis Highways England do not consider it necessary that the transport evidence base is revisited. It must be noted however that the over 43 1002528 MM05 McCaffrey England allocation of floorspace could result in employment concentrations being higher in some areas (Derriford for example) than has been considered in the transport evidence to date. This could potentially lead to deliverability difficulties if, for example, a higher concentration of employment leads to a severe transport impact even with the identified transport infrastructure being in place. In respect of SPT8 it is also understood that a detailed Infrastructure Delivery Plan is still yet to be prepared, to set out the infrastructure needs of the plan. On this basis I would be grateful if you could confirm if/how the scale of infrastructure necessary to support the development set out in the JLP, is sufficiently clear from the plan to potential developers.

MM5 TTV29.3 TTV29.10 Consequential amendments: Para 5.152 Employment land floorspace for Beacon Park Dartington (TTV29.3) is shown as 11,300 m 2 . This relates to the larger site previously shown in the JLP and the figure should be reduced pro rata. Employment floorspace calculations re TTV29.10 Woodlands Yard have been overstated in the JLP 5500 m 2 (as opposed to 5500 ft 2 which is 510m 2 ). Woodlands Yard is now subsumed into TTV (NEW) but the original figure still seem to stand as the JLP is still showing the total Dartington Dartington Parish 188 1191022 MM05 Kate Wilson employment space as 17,300 m 2 which implies that the incorrect figure of 5,500 m 2 for Woodlands is still included in that total. The figures in the consequential amendments para Council 5.152 are therefore overstated by possibly 9000m 2

Check/correct the calculation of employment floorspace in relation to TTV3 and TTV (NEW) above.

12 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Paignton Mr David 218 1094326 MM05 Neighbourhood The Forum supports the proposals as published and in particular those of MM5. Watts Plan Forum MM7 – Policies Map: Thriving Towns and Villages Policy Area (South Hams) The Trust supports the removal of the previous three individual site allocations throughout the Estate and Andrew Dartington Hall the inclusion of the Dartington Hall Estate boundary on the proposals map. The modified proposals map also includes a new boundary indicating the Primary Shopping Area/ Centre 343 1002035 MM07 Lichfields Jo Talling Cockett Trust Boundary for Dartington. The Trust is supportive of the inclusion of a Centre Boundary, however, would request that this boundary is adjusted slightly to include The Shops car parks which are functionally connected to the centre. Cllr. Nicky MM8 – Spatial Strategy Policy SPT11 This has significant changes to it to include the Woolwell Community Park amongst others being deleted. This change is acceptable as I believe that 23 684616 MM08 Hopwood PLY44 point 4 clearly sets out definitive needs that have too be met in order to deliver the Park.

30 1006285 MM08 Ms Liz Hore MM8 why has the proposal for the community park been deleted? With the additional houses we will need this additional leisure space to stop the existing areas being oversubscribed.

Regarding MM8 – Spatial Strategy Policy SPT11 This will implement significant changes to the Woolwell Community Park amongst others being withdrawn. The change will be 35 1096357 MM08 N Parr acceptable as I believe that PLY44 point 4 gives needs that have too be met in order to deliver the Park. The Park is an area that is a necessity for all and the environment for the area.

MM8: Spatial Strategy Policy SPT11 This has major changes to it including the WOOLWELL COMMUNITY PARK amongst others being deleted. This change is acceptable as I think PLY44 46 1096356 MM08 Anni Parr point 4 sets out clear definitive needs that have to be met in order to deliver the Park.

54 1190053 MM08 Simon Nobbs I agree with the proposed changes which include Woolwell Community Park.

MM8: What has happened to the Woolwell Community Park? How very sad that lines have literally been drawn through and crossed out all sections referring to nature and wildlife, 75 1190081 MM08 Nicki Wheeler this is an area abundant in both so it’s not surprising that their significance is being ignored. Thurlestone Parish Council 87 1002318 MM08 Sue Crowther and Policy SPT11. Strategic approach to the natural environment. We welcome these modifications which make this policy more robust and much clearer to follow. Neighbourhood Plan Miss SPT11 - Point 4 talks about “… Conserving and Enhancing the landscape…and the adjacent Dartmoor National Park..” Point 8 refers to Strategic Landscape Areas and Strategic 146 1013602 MM08 Elizabeth Greenspaces yet these terms were taken out of the Bickleigh Parish Neighbourhood Plan because of the feedback from the Inspectors of the JLP. This leaves the parish fields with low Gilmour levels of protection. See also MM52 (DEV29) Note that TTV1 and TTV31 are not strong enough to protect any “countryside” Paignton Mr David 219 1094326 MM08 Neighbourhood The Forum supports the proposals as published and in particular those of MM8. Watts Plan Forum

MM8 Re SPT11 Spacial Strategy Looking at this modification the removal of the list of sites diminishes their importance to communities. Woolwell Community Park is an extremely Cllr Michael significant item that has to be delivered in accordance with the statement found in PLY44 The modification fails to link with items 1. to V11 found with item 4 of PLY44 It is difficult to 236 1004109 MM08 Blake establish what point is made and in what context without trying to cross reference as indicated in Para 3.91 and Policies Dev 4 - 5 and Dev 24 - 30 whilst diluting 4. V11. This makes the consultation flawed in that it leads to confusion and doubt and in my view should be re - written in a way that it can be clearly and easily understood.

Mrs Linda MM8 Re SPT11 Removing the list of sites lessons their importance to the communities. The importance of the Woolwell Comminity Park is a very important item that has to be 248 1096832 MM08 Crowe delivered as per the statement in PLY44 MM8 Re SPT11 Removing the list of sites lessons their importance to the communities. The importance of the Woolwell Comminity Park is a very important item that has to be 254 1096834 MM08 Mr M Crowe delivered as per the statement in PLY44 Rebecca MM8: there are significant changes which impact on the Community Park in PLY44. Although this is covered within point 4 of Ply44 and therefore as a resident of Bickleigh I would be 260 1096845 MM08 Clayton demanding that developers allocated the protection of Green Space of a Community Park within their plans. MM8: there are significant changes to this which additionally has impact on the Community Park in PLY44 as this has been deleted. Although this is covered within point 4 of Ply44 and therefore as a resident of Bickleigh I would be expecting developers to continue within their plan to allocated the protect Green Space of a Community Park within their plans. 264 1096858 MM08 Ben Gavan Additionally within the changes there is less emphasis on specific protected sites this makes the wording open to interpretation unlike the specific lists that were in the previous document e.g. the deletion of weight consideration for example. MM8: there are significant changes to this which additionally has impact on the Community Park in PLY44 as this has been deleted. Although this is covered within point 4 of Ply44 and therefore as a resident of Bickleigh I would be expecting developers to continue within their plan to allocated the protect Green Space of a Community Park within their plans. 268 1096861 MM08 Tara Gavan Additionally within the changes there is less emphasis on specific protected sites this makes the wording open to interpretation unlike the specific lists that were in the previous document e.g. the deletion of weight consideration for example.

13 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) MM8: there are significant changes to this which additionally has impact on the Community Park in PLY44 as this has been deleted. Although this is covered within point 4 of Ply44 and therefore as a resident of Bickleigh I would be expecting developers to continue within their plan to allocate the protected Green Space of a Community Park within their plans. These 272 1191389 MM08 Larry Taylor changes present less emphasis on specific protected sites this makes the wording open to interpretation unlike the specific lists that were concise and clearly defined in the previous document. MM8: there are significant changes to this which additionally has impact on the Community Park in PLY44 as this has been deleted. Although this is covered within point 4 of Ply44 and therefore as a resident of Bickleigh I would be expecting developers to continue within their plan to allocated the protect Green Space of a Community Park within their plans. 297 1191484 MM08 R Pengelly Additionally within the changes there is less emphasis on specific protected sites this makes the wording open to interpretation unlike the specific lists that were in the previous document e.g. the deletion of weight consideration for example. There are significant changes to this which additionally has impact on the Community Park in PLY44 as this has been deleted. Although this is covered within point 4 of Ply44 and Steve Bickleigh Parish therefore as a resident of Bickleigh I would be expecting developers to continue within their plan to allocated the protect Green Space of a Community Park within their plans. 314 1007783 MM08 Clement- Council Additionally within the changes there is less emphasis on specific protected sites this makes the wording open to interpretation unlike the specific lists that were in the previous Large document e.g. the deletion of weight consideration for example.

MM8 Re SPT11 Spatial Strategy Looking at this modification the removal of the list of sites diminishes their importance to communities. Woolwell Community Park is an extremely Steve Bickleigh Parish significant item that has to be delivered in accordance with the statement found in PLY44 The modification fails to link with items 1. to V11 found with item 4 of PLY44 It is difficult to 315 1007783 MM08 Clement- Council establish what point is made and in what context without trying to cross reference as indicated in Para 3.91 and Policies Dev 4 - 5 and Dev 24 - 30 whilst diluting 4. V11. This makes Large the consultation flawed in that it leads to confusion and doubt and in our view should be re - written in a way that it can be clearly and easily understood

Rockspring Mr Alistair Boyer 333 1191547 MM08 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd

Dear Sir/Madam The RSPB has the following comments to make on the Plymouth and South West Devon Joint Local Plan: Main Modifications consultation. Policy SPT11 Strategic approach to the natural environment, modifications are problamtic in various respects. Its first principle is to avoid harmful impacts on existing features, but, where harmful impacts are unavoidable, they are mitigated or as a last resort compensated. There is no test articulated in the principle that a land use change that would cause unavoidable harmful impacts on the natural environment must be justifiable in terms of its public benefits, ie. that in order to justify harm in the first place, a land use change must have public benefits that override the principle of conserving the natural environment features in situ. This is a fundamental tenet of sustainable development, and its ommission from the modified policy wording is a serious concern. As such, the RSPB objects to it as proposed. We also consider that the qualifications adequately and proportionately should be removed . The extent of mitigation should be defined by what is needed to avoid the impact occurring. The test of proportionality could be interpreted as relating to the scale of development, ie. a small development RSPB (Royal would only need to provide low levels of mitigation even it its natural environment impact was large. That cannot in our view be right. The level of mitigation must relate to the scale of Gavin Society for the 350 1135071 MM08 environmental impact, not the scale of the development. If mitigation for a large environmental impact caused by a small scale development renders that development non-viable, the Bloomfield Protection of development should not proceed. The word adequately does not in our view add anything, other than suggesting a lower test compared with fully, which rightly qualifies Birds) compensation. The RSPB therefore recommends revising the text of principle 1 so that it reads: Avoiding harmful impacts on existing features as a first principle, and where harmful impacts are unavoidable but the public benefits of the proposed land use change are such that they override natural environment objectives, ensure that such impacts are mitigated or as a last resort fully compensated. Principle 8 now states Conserving and enhancing a functional network across the Plan area of greenspace and geodiversity sites that meets the needs of communities and wildlife. Under paragraph 171 of the National Planning Policy Framework (July 2018), Local Plans should take a strategic apporoach to maintaining and enhancing networks of habitats and green infrastructure and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries. It is not clear how the document plans for the enhancement of habitat networks and natural capital at catchment/landscape scale. Policy SPT11 should also in our view reflect Government’s ambitions for biodiversity net gain for developments, as set out in its recent consultation document. Yours sincerely, Gavin Bloomfield

MM8: there are significant changes to this which additionally has impact on the Community Park in PLY44 as this has been deleted. Although this is covered within point 4 of Ply44 and Glenn 360 1191554 MM08 therefore as a resident of Bickleigh I would be expecting developers to continue within their plan to protect Green Space of a Community Park. In addition there is now less emphasis Pengelly on specific protected sites making those removed subject to interpretation and potentially no protection.

14 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

SUPPORT with reservations. Some suggested changes have been resolved by the proposed modifications. Support the inclusion of the mitigation hierarchy as a first principle. With regards point 4. It should be conserving and enhancing the natural beauty, as this is the legal duty imposed on local planning authorities when plan-making and decision-taking. It is only with regards to the weight to be given that the NPPF limits this to landscape and scenic beauty factors of natural beauty. Therefore the key principle ought to reflect the law. It is Ms Victoria arguable that the requirement to give great weight to the conservation and enhancement of the landscape and scenic beauty of the AONBs and Dartmoor National Park is a key 367 1095125 MM08 Tanner- principles. Also,that major development in these protected landscapes should only be under exceptional circumstances and when demonstrably in the public interest is a key principle Tremaine of the plan's strategic approach to the distribution of development and therefore should be explicit in this policy. It is therefore disappointing to see this deleted from the policy text. This is important in the light of the changes in the NPPF which now requires strategic policies and non-strategic policies. The principles of 'no net loss' and a 'net gain' of biodiversity are also arguably key principles which ought to be set out in this strategic policy.

SUPPORT with reservations. Some suggested changes have been resolved by the proposed modifications. Support the inclusion of the mitigation hierarchy as a first principle. With regards point 4. It should be conserving and enhancing the natural beauty, as this is the legal duty imposed on local planning authorities when plan-making and decision-taking. It is only with regards to the weight to be given that the NPPF limits this to landscape and scenic beauty factors of natural beauty. Therefore the key principle ought to reflect the law. It is Ms Victoria arguable that the requirement to give great weight to the conservation and enhancement of the landscape and scenic beauty of the AONBs and Dartmoor National Park is a key 368 1095125 MM08 Tanner- principles. Also,that major development in these protected landscapes should only be under exceptional circumstances and when demonstrably in the public interest is a key principle Tremaine of the plan's strategic approach to the distribution of development and therefore should be explicit in this policy. It is therefore disappointing to see this deleted from the policy text. This is important in the light of the changes in the NPPF which now requires strategic policies and non-strategic policies. The principles of 'no net loss' and a 'net gain' of biodiversity are also arguably key principles which ought to be set out in this strategic policy.

PLY27: Main Modification 11, page 107. This site is within the boundaries of the Neighbourhood Forum. The HNF welcomes the modification and the strengthening of protection for the Hoe Conservation Area, in Main Modification 11 ( should conserve and where appropriate enhance the character or appearance of the Hoe Conservation Area and Registered Park and Garden). However it points out that if the MM is to be effective the current site planning guidance will need to change. We have taken detailed advice (summary attached) which shows Hoe that the current allocation for mixed use development, including a quality hotel and housing (52 homes) is unrealistic for the site, and the designation should change to either a quality 226 1095700 MM11 Penny Tarrant Neighbourhood hotel or housing (circa 45 units and a maximum height of 6 storeys). The current planned density and mixed use will not allow for the character and appearance of the Hoe Forum Conservation Area to be conserved or enhanced. Hence the outline of PLY27 needs to change as follows: PolicyPLY27 Register Office, Lockyer Street, The Hoe. Land at Lockyer Street, The Hoe , is allocated for mixed use development, including a quality hotel and housing. Provision is made for in the order of 52 homes: is allocated for either a quality hotel or housing (circa 45 units and a maximum height of six storeys).

MM14Land at Woolwell …. Provision is made for in the order of 2,000 new homes (about 1,880 1,560 of which are anticipated to come forward within the plan period), with none occupied until the A386 Woolwell to the George Junction Transport Scheme has been implemented. … 2. The main access arrangements to the development must are to be agreed and delivered prior to the commencement of development the main construction works and delivered commensurately with the associated phase of the development. Additionally, there should be no occupation of new homes until the A386 Woolwell to the George Junction Transport Scheme has been implemented, with the exception of where this can be Mrs Susan accommodated without resulting in a severe impact on the operation of the local road network. Any commencement of work with regard to proposed housing will impact on existing 1 1014661 MM14 Ramsay road infrastructure. it is unsound to agree to any housing building work prior to adequate infrastructure being in place. Existing traffic problems will be severely exacerbated if development takes place without road improvements. Emergency vehicle access at present is restricted and can affect response times. Further works traffic on existing roads would be unwise

Separate access to new development should be put in place to accommodate new housing scheme.

MM14 – Strategy for Plymouth Policy Area Policy PLY44 The changes to point 2 are unacceptable. These changes have been made without any reference to a traffic management report being made readily available to ascertain the implications of extra traffic on the A386 before road upgrades are completed. It is vital that the main access to the development is delivered prior to any development taking place. Additionally, it is unacceptable for any houses to be built before the A386 Woolwell to the George transport Scheme has been Cllr. Nicky completed without exception. This road is at breaking point for the residents of Woolwell, Bickleigh and Roborough at the moment. There is proposed development in Tavistock and 24 684616 MM14 Hopwood Yelverton which will make the situation worse. If any houses are built before this is completed residents will have the added burden of construction traffic using an unsustainable road network adding to their already miserable daily commute. I commended South Hams for taking such a hard stance on this policy and am disappointed that the Inspector has chosen to ignore the views of people who have first hand knowledge of this road. The wording of the document ‘with the exception of where this can be accommodated without resulting in a severe impact on the operation of the local road network’, who will determine what a severe impact is?, again with no traffic management plan this cannot be done.

15 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

To whom it may concern. Firstly I would like to say how I have found it difficult to navigate my way through the modifications and so I am having to email my concerns. My concerns are with the removal of Local Green Space within the plan. In particular to that at the end of Pinewood Drive, Woolwell. This piece of land is already with the Local Authority to build around 90 house on this plot of land. The land itself was scheduled for Local green space and so the original planning permission was declined. The owner put in new planning permission months ago when Inspector were called to question the designation of local green space. Its awaiting a decision. But in the meantime the inspector has chosen just to remove this policy of local green space protection entirely. This will have a huge impact of residence within the area. the removal of such protection from the designation of Local green Lucina Space leads me to believe the JLP is in the interest of building further properties. Also read that amongst other things the JLP will now allow people to reside in properties buildt in the 27 1014124 MM14 George Woolwell extension once built even if this is before the completion of making the infrastructure to the Woolwell site is completed. This is obsurd. There needs to be a better infrastruction on the A386 around the George and Tavistock Road by Woolwell and on road to tavistock. The roads within Woolwell are all ready overwhelmed by the amount of vehicles it cannot cope with more. This modification needs further consideration and changed back to previous policy of road first then the building of extension. I truly believe that if the JLP was to be completely rewritten so that all the council involves can just build houses without a care to residence within these areas or the infrastructure within then why ask the residence their opinions. The inspectors have literally just changed these policies and all we can do is comment but I am very unreassured that these comments will hold no weight at all.... I am very disappointed in how the JLP jas changed for the worst. Regards Lucina George

MM14 I must insist to you how stressful it can be trying to enter/exit woolwell at certain times of the day. We were originally assured that access would be improved before any building works started to alleviate the extra traffic caused by the additional houses plus construction traffic. It was proposed to add a second exit onto Tavistock road but this would not 31 1006285 MM14 Ms Liz Hore be adequate. You would still be adding to the already overloaded tavistock road. The amendment now seems to retract the assurance that building would not commence until after the appropriate road improvements were implemented. This is not acceptable.

MM14 – Strategy for Plymouth Policy Area Policy PLY44 The amendments to point 2 are not unacceptable as there is no consideration to the traffic impact or any reference to a traffic management assessment of the implications of extra traffic on the A386 and surrounding roads with what road upgrades are completed. It is my view and a necessity that the main access to developments is assessed fully and delivered prior to any development taking place. It is unacceptable for any houses to be built before the A386 corridors and surrounding roads are assessed in Woolwell, to provide a good flowing George transport Scheme has been completed. These roads are already at breaking point for all residents of Woolwell, Roborough and Bickliegh at present. Having a proposed development in Tavistock and Yelverton, will make the traffic situation worse which already bottlenecks at varying locations serving the A386. Houses being built before this is assessed and completed properly will cause current residents added traffic delay burdens, inclusive of construction vehicles who will use all roads which are currently unable to cope. This will add to most persons already miserable daily commute. South Hams should be complemented for having a hard stance on this policy but I am disappointed with the Inspector who has ignored the views of people in and around the area who have first hand knowledge and experience of the problems in the 36 1096357 MM14 N Parr road networks for the areas. The wording in this document ‘with the exception of where this can be accommodated without resulting in a severe impact on the operation of the local road network’, shows there has been no consideration of what severe impact is in this matter. Having no traffic management plan shows a lack of consideration to the current community and future communities intended to prevent further road congestion. At present the roads are overloaded, more houses will no doubt add at least two cars per property built and workers of extra and current services for the area. Therefore full consideration needs undertaking before gridlock occurs. At present delay is extensive to those travelling and with increased traffic further delays will occur to deliveries, service facilities, inclusive of delaying emergency services. A full traffic management plan is a necessity and a need before the commencement of the JLP. The recent Derriford Road improvements are evidence of increased traffic through Bickleigh where traffic avoiding congestion, use lanes and roads not designed for such use coming from The East side of the the area and visa versa. This will incur surrounding lanes, small roads further disrepair and increase dangers to cyclists, horses, runners and vehicles who use these routes to commute in an attempt to avoid increased traffic. Dangers of congestion through increased traffic for and after development will impact on wildlife, communities through more pollution to the area.

MM14 – Strategy for Plymouth Policy Area Policy (PLY44) We believe that the proposed changes to point 2 are totally unacceptable. One of the key objections raised, by local residents, during the Bickleigh Parish Neighbourhood Plan development process, was the unacceptable impact on the already heavily congested road system in the Parish. A recent Traffic Management Survey has yet to be made widely available, thereby providing a picture of the ongoing poor traffic situation, with the additional load resulting from this development prior to the A386 upgrade completion. Additionally, it is imperative that the main access roads to the new development are put in place prior to any building work commencing, thereby avoiding major impacts on the currently heavily used road systems around Woolwell and Roborough. Construction traffic being forced to use the existing road 39 1016378 MM14 Ian Kempsell network will add considerably to the already difficult daily commute, to and from work, faced by many local residents. It is totally unacceptable that any future development be started before the A386(Woolwell to the George Junction) transport Scheme has been completed. The proposed developments in Tavistock and Yelverton are going to increase the already heavy traffic usage, resulting in even greater congestion in areas such as the Woolwell Roundabout (with a knock-on effect on the Roborough bypass), to name but one! South Hams DC should be commended for taking such a strong position on this critical policy and I find it very difficult to understand why the Inspector has chosen to ignore the prime views of local residents who, with their first hand knowledge of the regular road chaos, should be key evidenced providers.

MM14 – Strategy for Plymouth Policy Area Policy (PLY44) A386: I think we are all in agreement that the wording that has been changed is to suit Barwood to allow them to build and 45 1189988 MM14 Mr Neil Prout let people occupy housing before road is completed. This is unacceptable and the road should be the priority as the traffic is affecting far too many people and to allow the houses to be built with no improvement to infrastructure first is a abomination.

16 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM14: Strategy for Plymouth Policy Area Pollicy PL44 Changes made to point 2 are unacceptable. The changes have been made without any mention to a TRAFFIC MANAGEMENT SURVEY being made available to ascertain the implications of the inevitable extra traffic on the A386 before road upgrades are completed. It is necessary that the main access to the development is delivered before any development is delivered prior to any development being initiated. Also, it in wholly unacceptable for any dwellings to be built before the A386 WOOLWELL to THE GEORGE transport scheme has been completed without exception. This road is already totally unequipped to handle the residents of WOOLWELL, BICKLEIGH and ROBOROUGH as it is. There is a proposed development in TAVISTOCK and YELVERTON which will make the situation untenable. If any houses are built before this is completed, 47 1096356 MM14 Anni Parr residents will have the added burden of construction traffic using an already underequipped road system. This will add to the daily stress of an already stressful and time consuming journey towards and away from PLYMOUTH CITY CENTRE. I applaud SOUTH HAMS for taking such a strong stance on this policy and am extremely disappointed that the INSPECTOR has chosen to ignor the view of people who have first had knowledge of this road in its present state. The wording of the document “WITH THE EXCEPTION OF WHERE THIS CAN BE ACCOMMODATED WITHOUT RESULTING IN A SEVERE IMPACT ON THE OPERATION OF THE LOCAL ROAD NETWORK”. Which body or person will decide or determine what a SEVERE IMPACT is – surely any reasonable person can determine that this cannot be done without a comprehensive traffic management survey?

As a Woolwell resident, I am writing to express my concern over the proposal to build 2,000 extra houses at the back of Woolwell/near Bickleigh. I was concerned about the impact on the area, even with the proposed road dualling upgrade between Woolwell Roundabout and the George Park & Ride with the proviso that this had to be done before the first of the new houses was occupied. I understand now, however, that following a recent amendment, not only is the Joint Local Plan likely to go ahead, but this will be allowed to proceed without the road being dualled. I also feel that the proposal to make the Woolwell Roundabout controlled by traffic lights as a backward step and I object to both of these plans. As a regular user of the road in the rush hour period both in the morning and afternoon, I always find the area between the Woolwell Roundabout and the Park and Ride to be a bottleneck. I had cause to travel today from the station to Yelverton at around 2pm and even at that time the traffic was heavy on that stretch beyond the Park and Ride until just beyond Woolwell Roundabout. What will it be like when there are more people trying to reach their homes at Woolwell? We also need to consider that the CSA traffic already contributes greatly to traffic issues in the area and my opinion is that we simply need the road improvements themselves without any additional building just to accommodate current traffic levels. Peter 50 1190043 MM14 Furthermore, I understand that developments are planned at both Tavistock and Yelverton and I have grave concerns that the Woolwell development when combined with these two Goodman other developments will have severe implications for the already congested road on the northern corridor. I would like to query what traffic management assessments have been carried out to determine the impact of all this extra traffic. I appreciate there is a need for housing but it is pointless building houses if there is nowhere to go for the extra traffic that will be generated. Who will buy properties in an area where there are notorious bottlenecks? I can only see this being a lose/lose situation all around; the current residents will be forced to deal with extra traffic and longer journey times if the houses are built and sold, or the houses may be built and then become difficult to sell resulting in the project becoming a white elephant. Prices will then need to be reduced, the developers will not make the profits they expect and house prices in the area in general will be affected. I am not the kind of person that enjoys seeing house prices spiralling upwards and I appreciate that this is something that needs to stop, but if there is too much of a house price depression, this could put people into negative equity and lead to hardship for some families. At present I can see no good coming out of this plan and I would be grateful for your comments on how this will be of any benefit for the area.

17 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

To whom it may concern, Your website is very unwieldy to use and to be able to submit a comment, hence the email. These changes are completely UNACCEPTABLE! To build 1800 - 2000 houses before relevant transport and road infrastructure is in place around the A386 Woolwell to the George transport Scheme has been completed is utterly ridiculous. This road is at breaking point for the residents of Woolwell, Bickleigh and Roborough at the moment and the implications of extra traffic on the A386 in its current state cannot be tolerated. In addition to this it is imperative that the main access to the development is delivered prior to any development taking place. There is proposed development in Tavistock and Yelverton which will make the daily commute much worse. If any houses are built before this is completed residents will have the added burden of construction traffic using an unsustainable road network adding to their already miserable daily commute (I only work at the hospital but this is 30mins most days!) . The wording of the document ‘with the exception of where this can be accommodated without resulting in a severe impact on the operation of the local road network’, is also unacceptable who will determine what a severe impact is? The roads are clogged constantly at the moment, not just on weekdays. I am happy that the Plymouth Urban Fringe is recognised as having special characteristics. However Policy PLY (NEW) 1.iii ‘ The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements’ , surely by 1880 homes proposed on the Plymouth Urban Fringe with direct access and view to the Dartmoor National park gives a justifiable and valid reason for this whole development being in completely the wrong place. I believe that this site was considered back in 2000 along with the Sherford urban extension, but was rejected at that time because of proximity to the Dartmoor National Park and the adverse effect it would have on it by way of views out of the Park. Nothing has changed in this respect. I am NOT in favour of the proposal of the Woolwell/Bickleigh/Roborough development, but if it is forced upon us then we the residents must insist on the following: Infrastructure : The A386 will need a major upgrade if there are to be any additional houses at all in this area or in Yelverton and Tavistock. These improvements MUST be carried out before any new development begins, because the disturbance which would be caused by access through the present housing would be absolutely unacceptable. Public transport: This is poor at the moment and a guaranteed public transport system is essential due to 52 1190044 MM14 Jo Smith the proximity of development to towns. There are no early or late buses on a Sunday which makes it difficult for us to get into Plymouth City without a car. Also the buses are stuck in the traffic from the Roborough roundabout all the way to Runway Drive. Education : The existing primary school is full, so a new one would need to be provided on the new site. Provision for transport to secondary schools must be considerably improved. Health : The present doctors’ surgery is already over capacity. A new health centre would be required, along with provision for a dental surgery as there is none in the north of the city. Connectivity: There needs to be good cycle and pedestrian connectivity between any new development and the existing to ensure good integration of both old and new communities with each other. Natural environment: There are a number of wooded areas and walkways, some of them ancient woodland, several are bluebell woods. Roborough Green and Pinewell whilst not ancient woodland should also be preserved. Any proposals should not harm any of these areas, which should be preserved at all costs for public recreation and enjoyment. Sports provision: The football and rugby pitches need to be maintained in situ and a new fit for purpose club house provided which could act as a social hub for the many other clubs which exist. This is so important for all ages in the community. Social connectivity is key with loneliness and isolation being concerns on the NHS Future 20 year plan. Social prescribing, nature activities, sport and social connectivity will all improve the health and wealth of the nation. 2000 new houses will NOT! Play space: As well as adequate provision on any new development, improvements and additional facilities are needed in Woolwell. These should be provided as part of the play provision for the new development. Local retail provision: A new hub of local shops will be needed as the existing cluster will not be sufficient for the needs of the new development. The local Post Office is to be closed in early 2019 which needs to be addressed as a matter of urgency. Administration of the area: Better communication is required between the City council and South Hams so that residents’ needs are cared for in a more coherent way. Apart from Councillor Nicky Hopwood who is outstanding, our other councillors are average at best in getting the voice of the residents heard at the South Hams council. There are too many conflict of interests and communication at parish level is poor.

I disagree with the changes to point 2. I have lived in Woolwell for 28 years and have seen the ever worsening traffic congestion that has significantly increased travel time to and from woolwell especially at peak times. This is primarily due to the A386 road between the George junction and woolwell roundabout. This part of the A386 road desperately needs 56 1190053 MM14 Simon Nobbs upgrading before ANY work is commenced on access or housebuilding. The extra construction traffic that is required will only make a bad situation worse even before the additional traffic caused by the increased number of residents.

18 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

To whom it may concern, Your website is very unwieldy to use and to be able to submit a comment, hence the email. These changes are completely UNACCEPTABLE! To build 1800 - 2000 houses before relevant transport and road infrastructure is in place around the A386 Woolwell to the George transport Scheme has been completed is utterly ridiculous. This road is at breaking point for the residents of Woolwell, Bickleigh and Roborough at the moment and the implications of extra traffic on the A386 in its current state cannot be tolerated. In addition to this it is imperative that the main access to the development is delivered prior to any development taking place. There is proposed development in Tavistock and Yelverton which will make the daily commute much worse. If any houses are built before this is completed residents will have the added burden of construction traffic using an unsustainable road network adding to their already miserable daily commute (I only work at the hospital but this is 30mins most days!) . The wording of the document ‘with the exception of where this can be accommodated without resulting in a severe impact on the operation of the local road network’, is also unacceptable who will determine what a severe impact is? The roads are clogged constantly at the moment, not just on weekdays. I am happy that the Plymouth Urban Fringe is recognised as having special characteristics. However Policy PLY (NEW) 1.iii ‘ The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements’ , surely by 1880 homes proposed on the Plymouth Urban Fringe with direct access and view to the Dartmoor National park gives a justifiable and valid reason for this whole development being in completely the wrong place. I believe that this site was considered back in 2000 along with the Sherford urban extension, but was rejected at that time because of proximity to the Dartmoor National Park and the adverse effect it would have on it by way of views out of the Park. Nothing has changed in this respect. I am NOT in favour of the proposal of the Woolwell/Bickleigh/Roborough development, but if it is forced upon us then we the residents must insist on the following: Infrastructure : The A386 will need a major upgrade if there are to be any additional houses at all in this area or in Yelverton and Tavistock. These improvements MUST be carried out before any new development begins, because the disturbance which would be caused by access through the present housing would be absolutely unacceptable. Public transport: This is poor at the moment and a guaranteed public transport system is essential due to 58 1190062 MM14 Daniel Smith the proximity of development to towns. There are no early or late buses on a Sunday which makes it difficult for us to get into Plymouth City without a car. Also the buses are stuck in the traffic from the Roborough roundabout all the way to Runway Drive. Education : The existing primary school is full, so a new one would need to be provided on the new site. Provision for transport to secondary schools must be considerably improved. Health : The present doctors’ surgery is already over capacity. A new health centre would be required, along with provision for a dental surgery as there is none in the north of the city. Connectivity: There needs to be good cycle and pedestrian connectivity between any new development and the existing to ensure good integration of both old and new communities with each other. Natural environment: There are a number of wooded areas and walkways, some of them ancient woodland, several are bluebell woods. Roborough Green and Pinewell whilst not ancient woodland should also be preserved. Any proposals should not harm any of these areas, which should be preserved at all costs for public recreation and enjoyment. Sports provision: The football and rugby pitches need to be maintained in situ and a new fit for purpose club house provided which could act as a social hub for the many other clubs which exist. This is so important for all ages in the community. Social connectivity is key with loneliness and isolation being concerns on the NHS Future 20 year plan. Social prescribing, nature activities, sport and social connectivity will all improve the health and wealth of the nation. 2000 new houses will NOT! Play space: As well as adequate provision on any new development, improvements and additional facilities are needed in Woolwell. These should be provided as part of the play provision for the new development. Local retail provision: A new hub of local shops will be needed as the existing cluster will not be sufficient for the needs of the new development. The local Post Office is to be closed in early 2019 which needs to be addressed as a matter of urgency. Administration of the area: Better communication is required between the City council and South Hams so that residents’ needs are cared for in a more coherent way. Apart from Councillor Nicky Hopwood who is outstanding, our other councillors are average at best in getting the voice of the residents heard at the South Hams council. There are too many conflict of interests and communication at parish level is poor.

MM14: Yet again how appalling that lines have been drawn through the agreement that no houses are to be occupied until the A386 Woolwell to George junction has been implemented and that access must be agreed and delivered prior to commencement. Of course it is without doubt going to have a severe impact on the operation of local road 76 1190081 MM14 Nicki Wheeler networks. At peak times you cannot get in or out of Woolwell without severe delays, in addition it can take 20 minutes to get from Belliver roundabout to Woolwell roundabout when driving from Tavistock or Yelverton. Ref to :"Additional, there should be no occupation of new homes until the A386 Woolwell to the George Junction Transport Scheme has been implemented, with the exception of where this can be accommodated without resulting in severe impact on the operation of the local road network" Mr Edward 81 714836 MM14 On no account should any further development be allowed at Woolwell until the A386 Woolwell to the George Junction Transport Scheme has been completed and an additional Lawrence access to Woolwell created off the A386 for all contractors vehicles involved in any future development at Woolwell. The Woolwell Road must not be used for access for any future development at Woolwell by contractors vehicles. The fact there is only one road (Woolwell Road) into Woolwell already causes problems at CSA Unit and school start and finish times. Woolwell has been dubbed the largest cul-de-sac in Devon. The traffic issues within Woolwell and the existing Tavistock Road are currently a major problem. Tavistock Road is a bottleneck around Woolwell and it would be insanity to build new 82 1190410 MM14 Sarah Jackson houses ( increase traffic flow) without a solution to the current problem. It doesn’t show that the inspector looked at or had traffic management survey information to make accurate decisions! It was promised at various stages that traffic would be dealt with PRIOR TO BUILDING COMMENCEMENT.

19 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Really am extremely concerned that this development is being steamrollered through for all the wrong reasons and the views of the residents in Bickleigh and Roborough have not been communicated effectively or accurately since this process began. Over the years we have registered our views and were advised to let these be known at local parish council meetings. We attended a couple of meetings to express our objections but have left prior to being able to do so because the meetings were long and drawn out (a cynic might suggest this be a deliberate tactic !) leaving the really important issue at the very end when it is fair to say both time and interest ran out ! So much so that the last meeting we attended two of the members appeared to be asleep at times ! We believe, as do others we have spoken to, that the whole process is tainted because one of the key players had a vested interest. To us it is astonishing that someone who will benefit financially should continually be in the hot seat either as Chair or as an "impartial observer” during the key period. When the Chairman stood down the damage had been done. Within Roborough, communication has been poor, virtually non-existent - thankfully we have been allowed to monitor the Woolwell information pages on the understanding that we are not allowed to comment. It is frustrating to see how much the Woolwell community is putting into the whole process and how little is being done to reflect our views by the representatives for Bickleigh and Roborough. We are sure Councillor Hitchens has done sterling work for the community over the years Chris & Helen 93 1013595 MM14 and as he suggested some 8 years ago he feels he has done so much for Roborough it is time he got something back. If this was the case he should have resigned and campaigned as a Allen land owner and not as the representative of a community that is against it. For him to be allowed to continue in this role raises many questions. We understand we are not allowed to know how Bickleigh Council have responded on our behalf. We can but hope that their submissions were a true and accurate reflection of how this community feels about the plans that are being made. Notwithstanding these extremely distasteful points the proposed transport infrastructure is ten years too late and would not meet the demands of entry and egress into Plymouth from the north today let alone in the future.

Interestingly representation of local views is still not being communicated effectively. I tried to attend a local parish council last Thursday but gave up after an hour as I just could not believe what I was witnessing. It made the council meetings in the Vicar of Dibley looks polished. I would suggest you appoint an independent body to represent the views of the local communities at least we would then know our views have been communicated. If a new road system is to be put in place than insist on a monitoring period of at least a year be put in place before any further decisions are made.

MM14 – Strategy for Plymouth Policy Area Policy PLY44 Being a local resident and experiencing the already overloaded A386 daily, the prospect of commencement of this development without prior improvements to the A386/Woolwell/George is short sighted and foolhardy to say the least. The proposed modifications to the JLP (point 2) appear to have made with no reference to a traffic management survey being made readily available to ascertain the implications of extra traffic on the A386 prior to road upgrades are completed. Local residents (Woolwell, Bickleigh and Roborough) are at a loss as to why such a logical and sensible preparatory element would not be instigated. The effect of increased traffic has yet to be Mr Mark experienced following the implementation and ultimate habitation of the "Eco Village", and further development in Tavistock and Yelverton will only make the situation worse. One has 99 1004102 MM14 Parlett also to consider the added burden of construction traffic using an already unsustainable road network.

It is, without doubt, essential that road infrastructure projects are COMPLETED prior to any development taking place. One only has to experience the daily gridlock of this area to appreciate the current dire situation, without contemplating increasing to it unnecessarily. The Inspector has apparently chosen to ignore the views of people who have first hand knowledge of this bottleneck.

PLY44 Referring to the A386 problems and work and implying that development at Woolwell can go ahead before the infrastructure can cope with the addition of the EcoVillage and Miss the developments at Woolwell, Tavistock etc. This is adding to the load of the existing community and has much in the way of protest already. Why is it being ignored? Referring to 147 1013602 MM14 Elizabeth “Community Park” – I appreciate this has been in the Plan for some time but what is the point of a “Park” on the edge of a conurbation, replacing and next to green fields? Parks are Gilmour usually to be found within towns and cities. This implies more development to come. It is an added expense on the Parish and its only value is if it gives another level of protection against further development. Dear Team, I am writing to express my strong objections to a modification to the above plan. My concern relates to item MM14 which might permit development on the land at Woolwell before upgrade work has been completed on the A386. I currently work part time and on the days I need to take the car due to work and child care hours it can take me up to 30 minutes to travel from my house in Roborough to Bickleigh Down School. The road is blocked solid at peak times. Traffic pollution is created and the volume of traffic where the road 154 1190529 MM14 Karen Tucker becomes single lane is dangerous. Due to a lack of secondary education in the area my son (age just 11) waits in the traffic jam at the roundabout to catch his bus across town to school. The whole road needs to be addressed as it stands and definitely before further houses are built. The council might have a requirement to build more houses but it also has a responsibility to look after the health and we’ll bring of current tax paying residents. The scale of the proposed build is unacceptable and current facilities do not support it. Yours sincerely, Karen Tucker (Local resident)

20 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Do "the experts" that you employed to carry out any surveys actually live in Woolwell. If they do then they will surely know that we do not want any further development here. Any increases in house numbers will on average mean a further 3/4 cars per house house increase. The road between Woolwell Roundabout and the George Junction cannot cope with current levels let alone any increase. I understand that a road widening scheme is being reviewed for this section but fail to see how a proposed set of traffic lights on Woolwell roundabout will aid the flow of traffic. Over the past 30 years I have NEVER had to queue or have been prevented from getting into Woolwell NO MATTER WHAT TIME OF DAY. My 155 1190530 MM14 Robert Tolley daughter lives in Milehouse and all I see getting from there to Woolwell are 14 sets of traffic lights and I can count on one hand the number of times I have actually had a clear run up to Woolwell, you inevitably end up stopping at every set, how does this improve flow of traffic, and you now want to add another set. Not only that you also intend to put a set further up by Tesco's where you want to change the exit junction from Tesco's from a slip road to a right turn to allow traffic to flow to Tavistock. Again, how will this improve the flow of traffic on the main A386 once these lights go red or some one wants to cross at the pedestrian crossing at Woolwell Roundabout, do you not understand the concept that RED LIGHTS STOP TRAFFIC NOT IMPROVE IT. Sorry to rant on but i'm only a Simpleton who has lived here for 30 years, and in the words of that famous Spanish waiter :- "I KNOW NOTHING"

I write to formerly object to two points in the main modification on the JLP. In relation to MM14 – Strategy for Plymouth Policy Area Policy PLY44 The changes that have been made are unacceptable. These changes have been made without any reference what so ever to the implications of extra traffic on the current A386. It is clear that despite an over whelming amount of residents objections that this development will go ahead anyway however it is VITAL that the main access to the development is completed prior to any development taking place. It is totally unacceptable for any houses to be built before the A386 Woolwell to the George transport Scheme has been completed. This road is already at breaking point. Anyone attempting to leave or enter the area at peak time already has a lengthy wait. Wen have one way into Woolwell and this proposed develpoment together with the proposed developments in Tavistock and Yelverton will make the situation worse. If any houses are built before the access is completed then families like myself will have the added burden of construction traffic using an unsustainable road network, adding further to our already difficult daily commute. I am HUGELY disappointed that the Inspector has chosen to totally Mrs Sarah 160 1190871 MM14 ignore the views of the residents who have first hand knowledge of this road. I’d love to see the inspector attempt the daily commute. It’s an accident waiting to happen so to blindly Daniels start building additional housing with no regard to access and safety of residents is unacceptable.

Well in the ideal work there would be no further development of an already large community however as that’s not likely to happen then I strongly urge that firstly the main access into Woolwell be sorted before ANY housing developments are started. We are at total breaking point with only one way in. How on earth do you expect residents to be able to come or go with the added pressure of construction traffic. Traffic that will run right past our primary school. It’s an accident waiting to happen!!! I also urge you to look into the sudden change to pinewood no longer being deemed a protected green space. If the plan is to turn Woolwell into a concreate jungle and dig up all our beautiful green space and drive the wildlife out, then you’re going about it the right way. Please leave us some green space!!!

MM14 The proposed changes made here are unacceptable. The A386 needs to be upgraded before the development is started and houses built for occupation. It is grossly unfair to 182 1012890 MM14 Mr Jon Todd consider penalizing the existing users of this road with more commuter/construction traffic, before upgrading the main road and site access. As a side issue, Just imagine the vastly increased traffic pollution you will be creating, from traffic congestion, without first upgrading the road structure.

The removal of the requirement to complete the George Junction Transport Scheme prior to the occupation of any houses on the proposed Woolwell extension will place an Mr Keith unsustainable additional load on the already overloaded access roads into and out of Woolwell and the Tavistock Road. It will also mean that there is no incentive on Plymouth City 193 1191025 MM14 Rutter Council to undertake or complete the scheme. The main access arrangements must be agreed and completed prior to the commencent of the development. If not there will be unacceptable traffic load and disruption to existing residents due to use of the single access/egress to Woolwell by the construction traffic.

21 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM14 Re PLY44 It is imperative that this modification is not implemented It has clearly been written without considering the various traffic surveys carried out between 2001 and the present day which prove in access of 30000 traffic movements per day. The surveys clearly indicate that the traffic density on The A386 is now critical It has been written in a manner which relies heavily upon interpretation by the use of words such as commensurately, severe, and where this can be accommodated. Who and when will this be determined It will be stable Door impact I.E. after the horse has bolted. There is no clear definition of what is meant by the wording Road Network nor does it recognise that the road network consists of the roads already ready within Woolwell Roborough and Bickleigh as well as the A386 If implemented this modification would make the lives of those living in Woolwell a living Hell owing to the limited access and egress. The modification only mentions one specific part of the transport scheme namely the George to the Woolwell roundabout. It fails to recognise the additional problems that will emerge as a result of the Local road network which will become saturated This modification also fails to recognise that the access arrangements greatly affect the local road network where the roads are b and C class single carriageway with virtually no passing facilities for heavy traffic it will have a SEVERE IMPACT, These areas need to Cllr Michael 237 1004109 MM14 be dealt with before any any properties are built. Item 6 PLY44 also emphasises the importance of solving these problems. The problem is unlikely to see an improvement as the A386 Blake will not only take the traffic from the Development area but will also take the traffic from and from The New ECO Village, Tavistock, Yelverton and Tamerton all of which are subject to significant housing builds themselves. The so called improvements will only move the problem further along the A386 towards the Dartmoor National Park it will not see the improvements needed being made. These points have already been made but ignored in the Devon Structure report 2001. At some stage Common sense must prevail The proposal is Flawed in many respects. Lastly the proposal fails to take account of Policy Dev 2 in relation to Air and Noise pollution which will result from the greatly increased amount of traffic. It is being perceived as simply a means to assist the developers and no thought are being given to the need to overcome the difficulties that will WORSEN for the people who live in Woolwell, Roborough, Bickley and the towns and villages to the north. The situation is UNIQUE not as some would suggest normal. Point 5 claims to support the new and existing residents and enhance the sustainability of the area but in effect will achieve the opposite as students of secondary age will have to travel further afield to get an education. It is debatable if any contribution will mitigate the impact on Plymouth secondary schools.

The proposals that the plan be amended such that the A386 be not dualled before occupancy of the development is unsound. The developers could take many months after the first occupants take residence before undertaking the road development; meanwhile the road will have to carry the additional construction traffic and the road works simultaneously, Mr Norman 242 1191233 MM14 causing even more delays. The yet to be constructed Sherford A38 link road is indicative of the chaos that might ensue. Behenna Additionally, there should be no construction of new homes until the A386 Woolwell to the George Transport scheme has been implemented ...

MM14 Re PLY44 Reducing the amount of anticipated homes from 2000 to 1560 is not going to satisfy any form of delay in improving the current road network. We have been promised improvements every time a Planning Application is presented. Eco Homes with 91 houses, Tamerton Foliot 60+, Tavistock, Yelverton, Southway it goes on and on without any Mrs Linda 249 1096832 MM14 thought to the pressures this puts on the public who need to get to work, children to school, business etc. To also cross out "with non occupied until the George Junction has been Crowe implemented" and then in the next breath "with the exception of where this can be accommodated" HOW and WHERE, the only roads remaining have not been" identified" and still means that Construction traffic has to use the A386 to get to them to construct the houses that Eventually will be occupied !!.

MM14 Re PLY44 Reducing the amount of anticipated homes from 2000 to 1560 is not going to satisfy any form of delay in improving the current road network. We have been promised improvements every time a Planning Application is presented. Eco Homes with 91 houses, Tamerton Foliot 60+, Tavistock, Yelverton, Southway it goes on and on without any 255 1096834 MM14 Mr M Crowe thought to the pressures this puts on the public who need to get to work, children to school, business etc. To also cross out "with non occupied until the George Junction has been implemented" and then in the next breath "with the exception of where this can be accommodated" HOW and WHERE, the only roads remaining have not been" identified" and still means that Construction traffic has to use the A386 to get to them to construct the houses that Eventually will be occupied !!.

MM14: there is not a chance in hell that we residents we allow building work to be started before the road infrastructure is improved. We already struggle with bottlenecks and traffiv Rebecca chaos without the added impact of building traffic or the traffic from all the new residents. There is no evidence that the recent transport survey has been taken into consideration and 261 1096845 MM14 Clayton this still has not been made available to the public.The needs of the developer should never be put above the needs of the existing residents whose community is being threatened. Therefore changes need to reflect that no housing is occupied at all until the road works and George Junction is completed!

MM14: The changes to point 2 are completely unacceptable. There is no evidence that the recent transport survey has been taken into consideration and this still has not been made available to the public. The wording is reflective of a meeting residents had with the developer prior to the publication of the modifications of the JLP. Why is this the case? I am disappointed that it seems that the examiner has taken the needs of the developer above the needs of the existing residents. Additionally the wording within point 2 is ambiguous at 265 1096858 MM14 Ben Gavan best, words such as implemented. This needs clarity to ensure that implemented means completed and that no additional traffic is added to the high congestion rates at the junction. Prior to the completion of the junction would be catastrophic as the area already has high congestion, adding to it building construction including workers, road work congestion and then new occupants cars etc this would have a very high impact in this area. Therefore changes need to reflect that no housing is occupied at all until the road works and George Junction is completed!

22 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) MM14: The changes to point 2 are completely unacceptable. There is no evidence that the recent transport survey has been taken into consideration and this still has not been made available to the public. The wording is reflective of a meeting residents had with the developer prior to the publication of the modifications of the JLP. Why is this the case? I am disappointed that it seems that the examiner has taken the needs of the developer above the needs of the existing residents. Additionally the wording within point 2 is ambiguous at 269 1096861 MM14 Tara Gavan best, words such as implemented. This needs clarity to ensure that implemented means completed and that no additional traffic is added to the high congestion rates at the junction. Prior to the completion of the junction would be catastrophic as the area already has high congestion, adding to it building construction including workers, road work congestion and then new occupants cars etc this would have a very high impact in this area. Therefore changes need to reflect that no housing is occupied at all until the road works and George Junction is completed! MM14: The changes to point 2 are almost a complete “U” turn and therefore completely unacceptable. There is no evidence that the recent transport survey has been taken into consideration and this still has not been made available to members of the general public. Furthermore the statement: “with the exception of where this can be accommodated without resulting in a severe impact on the operation of the local road network” – please define “sever impact” as this statement is both woolly at best but certainly without defined 273 1191389 MM14 Larry Taylor values and as such cannot be enforced. It appears that the examiner has taken the needs of the developer above the needs of the existing residents and grossly underestimated the impact on an already over-burdened infrastructure. Therefore changes need to reflect that no housing is occupied at all until the road works and George Junction improvements are completed in their entirety!

I strongly object to the modification to the above policy even though there has been a subsequent reduction to the proposed development area since the JLP as the existing A386 highway infrastructure is totally inadequate. Having attended a consultation meeting with members of the highway regarding proposals for the scheme at the Woolwell/A386 junction I Mrs T M clearly stated that the road between the recent Derriford alterations and the George junction should first be addressed before any further works to the A386 should be considered. At 276 1191403 MM14 Paddon no time have there been any traffic flow results provided that proves that the existing infrastructure is currently adequate, let alone after an additional 2000 homes are built. I also understand that further residential development will take place to the north in the West Devon area, which will only serve to put more pressure onto the A386. Furthermore there should be NO occupation of new homes until the A386 Woolwell to the George Junction Transport Scheme has been completed and certainly no exception, to be given by whom?

I strongly object to the modification to the above policy even though there has been a subsequent reduction to the proposed development area since the JLP as the existing A386 highway infrastructure is totally inadequate. Having attended a consultation meeting with members of the highway regarding proposals for the scheme at the Woolwell/A386 junction I Mr Brian clearly stated that the road between the recent Derriford alterations and the George junction should first be addressed before any further works to the A386 should be considered. At 278 1191406 MM14 Paddon no time have there been any traffic flow results provided that proves that the existing infrastructure is currently adequate, let alone after an additional 2000 homes are built. I also understand that further residential development will take place to the north in the West Devon area, which will only serve to put more pressure onto the A386. Furthermore there should be NO occupation of new homes until the A386 Woolwell to the George Junction Transport Scheme has been completed and certainly no exception, to be given by whom?

Sir, Please allow me to comment upon the modifications to the JLP affecting Woolwell. Although I realise that I probably have to accept this expansion, it saddens me that these dwellings have to be built on this part of Plymouth in the first place. We seem to be expanding Plymouth out onto green fields and Dartmoor itself. I foresee a time in the not too Andrew 280 1191418 MM14 distant future when we may lose even more of this very valuable space. What concerns me the most with this development is that it would seem that it may start before any attempt is Clarke made to deal with the traffic problems that we already have on the A386. It is not just the problem of the additional traffic that residency of these properties would bring but also, of equal or greater concern, the construction traffic that such a project would need. Regards Andrew J Clarke

Point 2 amendments and additions are unacceptable, as they stand Wording in point 2 ‘with exception of where this can be accommodated without resulting in a severe impact on the local of the local road network’ should be removed How will ‘severe impact’ be determined and by whom – proposed wording leaves room for considerable doubt Pre-existing traffic surveys used to support previous development (Eco Village, for example) all indicate over capacity on A386 or use dated information not taking into account the increases in traffic over more recent years I understand that updated traffic survey(s) have been undertaken but access has been denied to the wider public The A386 has been proved to be working at over Mr Barrie capacity for many years; no additional traffic should be accommodated until A386 upgrade is implemented. Even then it is debatable about whether additional traffic can be catered 286 673928 MM14 Spencer for since all the proposed development of the A386 will do is push the traffic bottlenecks to a different place on the same road Existing traffic issues will be further compounded by proposed developments in Tavistock and Yelverton as well as from the proposed development of Woolwell The full impact of the habitation of the Eco village has yet to be felt; this can only add to the congestion ‘Local road network’ is undefined. It is proven that the existing traffic congestion on the A386 has forced traffic into the wider road network. This is evidenced by increased ‘tidal’ traffic on New Road (using access to Plympton via Bickleigh) for example. There are many other examples. These roads are already ill equipped to deal with the increased usage required of them

MM14 (PLY44) – OBJECTION – The changes for access arrangements are unacceptable. The A386 is already at breaking point and no account has been taken of extra housing at the Carole Roborough Eco Village, Tavistock and Yelverton. Local residents have already been ignored regarding their preference to changes of access to the A386. The Woolwell to George 294 1096742 MM14 Spencer Junction Transport Scheme needs to be completed BEFORE work starts on the development at Woolwell as this will cause a severe impact on the operation of the local road network starting at construction stage. Who decides what “severe impact is”? Would anyone listen to local residents? Where is the up-to-date traffic management plan?

23 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) MM14: The changes to point 2 are completely unacceptable. There is no evidence that the recent transport survey has been taken into consideration and this still has not been made available to the public. The wording is reflective of a meeting residents had with the developer prior to the publication of the modifications of the JLP. Why is this the case? I am disappointed that it seems that the examiner has taken the needs of the developer above the needs of the existing residents. Additionally the wording within point 2 is ambiguous at 298 1191484 MM14 R Pengelly best, words such as implemented. This needs clarity to ensure that implemented means completed and that no additional traffic is added to the high congestion rates at the junction. Prior to the completion of the junction would be catastrophic as the area already has high congestion, adding to it building construction including workers, road work congestion and then new occupants cars etc this would have a very high impact in this area. Therefore changes need to reflect that no housing is occupied at all until the road works and George Junction is completed!

MM14: The main A386 road between Tavistock and Plymouth is already extremely congested, particularly at peak times. This bottle necks around the Woolwell roundabout area and can cause ridiculous queues for residents and commuters alike. What will be done to establish the implications of extra traffic on the main A386 road that would come with the development access road. It is essential that the main access road to the development must be completed before any development takes places or any houses or built. This also covers the Wollwell to The George Transport Scheme needing to be completed before any houses are built. Not doing this would result in a complete standstill for any traffic passing along this 308 1191513 MM14 Emma Hogg stretch of the A386, which will have further repurcussions towards Yelverton and Tavistock with an ever increasing amount of traffic coming into Plymouth from these areas as they continue to expand. Furthermore, the existing road network into Woolwell is already at capacity. In addition, with a primary school, two nurseries and a Doctor's surgery (amongst others) located within Woolwell, the use of the main road into Woolwell for developers lorries, most likely HGVs would create a huge safety risk on what is already a very busy road, particularly at peak school drop off and pick up times.

I have re-read the plans in light of the above I concur with comments by Councillor Nicky Hopwood of SHDC I attended the viewing in Tavistock on 31 10 2018 and spoke with Thomas Jones Thomas Jones kindly sent me a copy of his email to Gina Small Mr. Jones’ email relayed my request for an update on queries I have raised previously These queries can be summarised as: A] A386 Road traffic capacity increase provisions as required What measures have been prepared? What are the latest data results? How far ahead of the rise in Edward 313 711199 MM14 demand will the A386 improvements be ready? What provision for emergency service alternative routes, and when? B] Drainage and sewerage What increase in capacity will be Gordon made to meet: The rising population? The increased transition from natural to hard surface area? Weather emergencies? C] Security and civil emergencies / infrastructure Are there any updates since 31 10 2018, and if so may we have details? I send this at the eleventh hour” because: Despite my efforts, I have not had any response since 31 10 2018 From J.E.Gordon

MM14 Re PLY44 It is imperative that this modification is not implemented It has clearly been written without considering the various traffic surveys carried out between 2001 and the present day which prove in access of 30000 traffic movements per day. The surveys clearly indicate that the traffic density on The A386 is now critical. It has been written in a manner which relies heavily upon interpretation by the use of words such as commensurately, severe, and where this can be accommodated. Who and when will this be determined It will be stable Door impact I.E. after the horse has bolted. There is no clear definition of what is meant by the wording Road Network nor does it recognise that the road network consists of the roads already ready within Woolwell Roborough and Bickleigh as well as the A386 If implemented this modification would make the lives of those living in Woolwell incredibly difficult, owing to the limited access and egress. The modification only mentions one specific part of the transport scheme namely the George to the Woolwell roundabout. It fails to recognise the additional problems that will emerge as a result of the Local road network which will become saturated. This modification also fails to recognise that the access arrangements Steve greatly affect the local road network where the roads are b and C class single carriageway with virtually no passing facilities for heavy traffic it will have a SEVERE IMPACT, These areas Bickleigh Parish 316 1007783 MM14 Clement- need to be dealt with before any any properties are built. Item 6 PLY44 also emphasises the importance of solving these problems. The problem is unlikely to see an improvement as Council Large the A386 will not only take the traffic from the Development area but will also take the traffic from and from The New ECO Village, Tavistock, Yelverton and Tamerton all of which are subject to significant housing builds themselves. The so called improvements will only move the problem further along the A386 towards the Dartmoor National Park it will not see the improvements needed being made. These points have already been made but ignored in the Devon Structure report 2001. At some stage Common sense must prevail. The proposal is flawed in many respects. Lastly the proposal fails to take account of Policy Dev 2 in relation to Air and Noise pollution which will result from the greatly increased amount of traffic. It is being perceived as simply a means to assist the developers and no thought are being given to the need to overcome the difficulties that will WORSEN for the people who live in Woolwell, Roborough, Bickleigh and the towns and villages to the north. The situation is UNIQUE not as some would suggest normal. Point 5 claims to support the new and existing residents and enhance the sustainability of the area but in effect will achieve the opposite as students of secondary age will have to travel further afield to get an education. It is debatable if any contribution will mitigate the impact on Plymouth secondary schools.

Rockspring Mr Alistair Boyer 334 1191547 MM14 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd

24 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM14: The changes to point 2 are concerning. There is no evidence that recent transport survey rates have been taken into consideration as this still has not been made available to the public. Therefore specific baseline rates of traffic flow and future impact are ambiguous at best. Therefore I fail to see how the proposed junction modification and dualing of the Glenn carriageway between Woolwell & the George Junction will enable the extra traffic to be managed. Similarly I fail to see how the relocation of New Road and the resulting traffic exiting 361 1191554 MM14 Pengelly onto the A386 have been adequately quantified. Additionally the wording within point 2 is ambiguous, the word implemented needs to be clarified proving the impact of road layout changes ahead of the development starting thus proving traffic is seen to flow better than it currently does and therefore at best the extra volumes will return congestion to the current levels and no worse. Therefore changes need to reflect that no housing is occupied at all until the road improvements are finished.

Please may I raise my official objection to the proposal that the original plan to defer any commencement of building a housing development in and to the north of Woolwell be delayed till improvement works to the A386 are completed to an alternative that envisages that building can commence whilst an improvement is planned but occupation of these houses is delayed till the road improvement works have been completed. I think this is a nonsense. This alternative is likely to lead to an impasse - we could see houses built and left unoccupied if the road improvement does not occur, causing a blight on the area, or we are eventually coerced into accepting this development without the road improvement leading to an impasse, or complete gridlock of the road system. I normally walk to work to Derriford and witness the daily logjam of traffic trying to exit Woolwell joining the static traffic on Mr Eric 85 1004334 MM14 the dual carriageway from Tavistock direction, and walk along stop start traffic up to The George junction, joining more static traffic down to the Derriford roundabout. On Tuesday I Drabble had the opportunity to see that this static traffic extends northward along the A386 onto the moor with stop start traffic as far back as Yelverton - 4 miles of relatively static traffic. That is the current situation. Your original plan to defer any commencement of the development till the road improvements have been completed, if it is to be built, must stand and not be amended. Will the associated improvement in infrastructure, provision of sewage, water, electricity and gas supplies, be instituted before any development commences, or will we await problems with these during development and occupation before they are addressed. Could you tell me if my previous objections are still on record? I understand that after a previous consultation exercise, we were invited to resubmit our objections, but this invitation was not well publicised. Were previous objections kept on record? Eric Drabble

Miss PLY46.13 -Approval It is a good point to retain the current playing pitches in the heart of the existing community – on level ground with good drainage. Unlike other parts of the 148 1013602 MM15 Elizabeth proposed development which are on slopes and with less effective drainage. (Bags me the goal on the upslope!) Gilmour Mrs T M 277 1191403 MM15 I am concerned with this modification as a developers re-provision may not suit the community, as it exists at present. Paddon Mr Brian 279 1191406 MM15 I am concerned with this modification as a developers re-provision may not suit the community, as it exists at present. Paddon Mr Barrie The proposed new wording should stress that any re-provision should be within the immediate vicinity of any existing site so removed As worded this could be seen to encourage traffic 287 673928 MM15 Spencer movement to more distant sites robbing local communities of valuable easily assessible local facilities Carole 295 1096742 MM15 MM15 (PLY46.13) – APPROVAL. We need to retain or improve current play pitches Spencer

MM19 – we note changes to draft Policy PLY59, Site 12. As the Councils (and Inspectors) will recall the proposed allocation of the site was discussed at the Hearing Sessions. The site is owned by our Clients. The most significant change as far as the Proposed Modifications are concerned is the proposed alteration to the number of residential units to be accommodated on the site which has been reduced from 120 to 94 no. As we understand it, the main reason for the proposed change relates to the need to take into account existing site constraints, most notably the presence of heritage assets, which may lead to less land being available for built development. These constraints need to be taken into account with Mr/Mrs Jillings Heynes respect to any proposed layout for the development of the site. Any key natural and/or historic designations will, potentially, have to be afforded some degree of protection as and 198 964051 MM19 Ed Heynes Richard/Barb Planning Ltd when a design and layout for the site is prepared. Clearly the level of analysis undertaken by both our Clients and the Councils at this stage has not been so extensive as to identify the ara Bennett precise number of units that could be delivered. We therefore regard the 94 total number of units as being as being a minimum as stated in our previous correspondence to the Council in relation to the Pre-Submission Consultation version of the Plan (see letter dated 26th April 2017). We note that the table column heading for the capacity of the site is an estimation of housing provision. We raise no objection regarding the criteria at 1. i), ii) and iii) as they will have to be addressed through the preparation and completion of technical documentation at the time a planning application is submitted for the site.

25 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM19 – we note changes to draft Policy PLY59, Site 12. As the Councils (and Inspectors) will recall the proposed allocation of the site was discussed at the Hearing Sessions. The site is owned by our Clients. The most significant change as far as the Proposed Modifications are concerned is the proposed alteration to the number of residential units to be accommodated on the site which has been reduced from 120 to 94 no. As we understand it, the main reason for the proposed change relates to the need to take into account existing site constraints, most notably the presence of heritage assets, which may lead to less land being available for built development. These constraints need to be taken into account with Mr/Mrs Jillings Heynes respect to any proposed layout for the development of the site. Any key natural and/or historic designations will, potentially, have to be afforded some degree of protection as and 199 1095768 MM19 Ed Heynes David/Jane Planning Ltd when a design and layout for the site is prepared. Clearly the level of analysis undertaken by both our Clients and the Councils at this stage has not been so extensive as to identify the Stratton precise number of units that could be delivered. We therefore regard the 94 total number of units as being as being a minimum as stated in our previous correspondence to the Council in relation to the Pre-Submission Consultation version of the Plan (see letter dated 26th April 2017). We note that the table column heading for the capacity of the site is an estimation of housing provision. We raise no objection regarding the criteria at 1. i), ii) and iii) as they will have to be addressed through the preparation and completion of technical documentation at the time a planning application is submitted for the site.

Thurlestone Policy TTV1. Prioritising growth through a hierarchy of sustainable settlements. Para 5.5 . We support this clarification that in the absence of defined settlement boundaries, Parish Council development outside built-up areas will be considered in the context of Policy TTV31 (Development in the Countryside) and that neighbourhood plans may identify settlement 88 1002318 MM21 Sue Crowther and boundaries for their towns and villages, based on the principles published in the JLP Settlement Boundaries Topic Paper (in draft) which will be incorporated in the Thriving Towns and Neighbourhood Villages SPD. Plan

The JLP documents refer to a Settlement Boundaries SPD but my understanding is that this document would be a DPD which obviously carried more weight and is preferred. Dartington Parish 189 1191022 MM21 Kate Wilson Council Clarify whether the proposed settlement boundaries document is to be an SPD or a DPD

MM21: TTV1 and consequential amendments We support the modification which confirms that settlement boundaries will be defined through a separate DPD, rather than SPDs, and Emery Wainhomes this aligns with our submissions on this matter to the examination. However, we do not agree with the proposed wording of paragraph 5.5, which states that “development outside Mr John 210 893384 MM21 Planning (South West) built up areas will be considered in the context of Policy TTV31” . The wording is extremely ambiguous, as it is not clear how ‘built up areas’ are to be defined in the absence of Coxon Partnership Holdings Ltd. settlement boundaries. Furthermore a strict application of Policy TTV31 fails to have regard to the fact that the settlement boundaries are up-to-date and need to be amended through a subsequent DPD. We therefore consider that the second sentence of paragraph 5.5 (as amended) should be deleted.

Paignton Mr David 220 1094326 MM21 Neighbourhood The Forum supports the proposals as published and in particular those of MM21. Watts Plan Forum

MM21 (Policy TTV1) Figure 5.1 identifies how site allocations have been distributed across the settlement hierarchy set out in Policy TTV1. It is noted that the site allocation totals identified in Figure 5.1 are still not expressed as ‘minimum’ requirements. To allow flexibility in delivery and to ensure local needs are met this should be clarified. This approach will also accord with Policy SPT3 (Provision for new homes) which sets out the overall housing requirement as a ‘minimum’. We acknowledge that the housing requirements in Policy SPT3 are expressed as ‘at least’ however it will be important to ensure a consistent approach across all policies relating to the delivery of housing in the plan period. Therefore, Policy TTV1 and Figure 5.1 should be updated accordingly. As set out in our previous representations while it is important that the housing requirements are expressed as a ‘minimum’ it is also Jonathan Walsingham Land Value 347 1096270 MM21 considered that there is still potential to achieve more than the 970 units proposed in the ‘towns and key villages’ identified in Figure 5.1 in the plan period. This is particularly the case Chick Planning Alliances (LVA) for Hatherleigh which is a market town with a good level of services and facilities as well as areas for employment provision. As set out further below land north of the A3072 in Hatherleigh as edged red on the attached site location plan (Appendix 1) was a proposed allocation for mixed use development in the consultation on the TTV (July 2016) and the Extra Sites and Topic Paper (November 2016). It is still considered to be the most suitable location to provide a mixed-use extension to the settlement. Thus, to deliver the final agreed levels of housing in the TTV of the JLP, there should be a greater focus for development at the ‘Towns and Key Villages’ through, specific, deliverable site allocations, in appropriate locations (such as land north of the A3072, Hatherleigh) in order for the provision of housing to be planned for positively as required by the NPPF (paragraph 157).

Ms Victoria 369 1095125 MM21 Tanner- SUPPORT. In paragraph 5.5 the overarching principles should include no full and proper consideration of the AONBs and this should be addressed in the TTV SPD. Tremaine Reference MM22 – Strategy for TTV Policy Area/Policies – Spatial Priority SP3 – Spatial priorities for development to Kingsbridge. NEW POINT Recognising the important role of key road links, the A381 to Totnes and the need to maintain and improve public transport provision. The above New Point needs to be expanded to ensure the proposed Modification is Mr Martin Kingsbridge Town 10 1094862 MM22 Sound. Johnson Council Recommend additional wording: …the A381 to Totnes, the A379 to Dartmouth and the B3196 to the A38 corridor and the need to maintain…

26 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) SP4 - The Council strongly supports all elements within SP4, point 9. Traffic problems in Okehampton town center and Station Road will be greatly exacerbated once the rail service to Mrs Emma Okehampton 80 1187545 MM22 the town is reintroduced, likely to be in early 2020. We feel that priority should be given to joint communication between Devon Highways and the Regional Development Manager James Town Council West for GWR on the delivery of these points. White Young 354 1105974 MM22 Robin Upton Bloor Homes Please see attached. Green

Jonathan Premier Marinas 4 1096244 MM23 CBRE Ltd Please see attached. Stoddart (Dart) Limited

TTV6 – Noss on Dart. We welcome the modification made under po int 9 but recommend that you change the words bat consultation zone to Landscape Connectivity Zone as identified 64 1014005 MM23 Carol Reeder Natural England in the emerging Supplementary Planning Document (SPD) for the South Hams Special Area of Conservation (SAC). Please liaise with Rob Sekula on this point.

We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM23 Amended text in TTV6.10 requiring a 229 658611 MM23 Salmon Agency sequential approach to avoid unnecessary development in a flood zone. Also, new points requiring pollution prevention measures to protect the estuary, and to avoid inter-tidal habitat loss and to compensate/mitigate if avoidance is not possible.

Ms Victoria SUPPORT with reservations . It is not clear what the rationale is for the increase (within the AONB) from 100 to 126 dwellings at Noss on Dart. Also the addition of 88 use class (storage 370 1095125 MM23 Tanner- and distribution) and whether this is appropriate in the AONB and what impacts this could have on the AONB. What assessment of the implications for the AONB and the environment Tremaine generally has been done of this change in use classes for this allocation? Welcome and SUPPORT the two new points to Policy TTV6 Noss on Dart.

SUPPORT. Proposed modifications to The Quayside. SUPPORT inclusion of reference to the AONB requiring high quality design. SUPPORT the new point regarding tree canopy cover,and Ms Victoria support the maintaining of mature trees. SUPPORT in particular the restriction of the height of any new buildings which will help to mitigate some harm to the AONB from over 371 1095125 MM23 Tanner- domination of buildings. This was a particular concern for the South Devon AONB Unit and therefore this should be included in the policy rather than paragraph 5.55. SUPPORT the Tremaine requirement for the provision of parking within the development site, so as not to displace parking to elsewhere on greenfield sites in the future.

Measures are needed to improve access from Ivybridge on to the A38. It is therefore important that the original provisions are reinstated. The existing congestion in Ivybridge and Sarah Ugborough traffic flows through the communities of Bittaford and Wrangaton will only increase without these strategies. 16 1002392 MM24 Woodman Parish Council Reinstate para. 5.46 'combined with the creation of a road linking Exeter Road to the A38 via land south of the A38 are necessary to reduce the...' Reinstate TTV8 para 9.

MM5 – para 5.51 refers to the loss of employment floorspace, which is dealt with in more detail below, which results in villages having a bigger allocation of employment land than a so called “sustainable location” as one of the six main towns. MM24 The reduction in employment land from 10,400 to 4,600 sq m is drastic and completely undermines any efforts towards enhancing the towns’ self sufficiency. By requiring existing residents and those in all the new homes to continue to commute to Plymouth along the congested A38 without any provision of park and ride or improvement to the A38 junction at Ivybridge is completely wrong. Seemingly Ivybridge, it would appear, is not part of the wider Plymouth area traffic enhancement initiative which seeks to improve commuting from the surrounding area (including Ivybridge). This section also includes the appropriate strategy to mitigate any impact Ivybridge Town on the Western Road Air quality AQMA yet we know from discussions with Devon County Council and South Hams DC that no policy has yet been agreed (the report to South Hams DC 41 1014031 MM24 Lesley Hughes Council has been deferred yet again) and it is wholly dependent on those who park on Western Road now agreeing to move into an as yet unknown area. There is no agreement how this will be achieved yet the housebuilding continues apace and the air quality will worsen with no “relevant” plan in place, to the detriment of existing residents. The deletion of any reference to improved road and junction connections to the south of the A38 is worrying as the capacity is being explored currently with Devon County Council. This omission a retrograde step and will not assist endeavours to deal with the A38 roundabout junction where some of the arms are anticipated to have queues of some 24 vehicles stacked at peak times, putting pressure on drivers to rush onto the roundabout potentially causing more accidents. Promises made to the Examiner, and hence reflected in this document, cannot currently be demonstrated to be deliverable and MM24 is not acceptable in terms of employment, road capacity or air quality.

White Young 355 1105974 MM24 Robin Upton Bloor Homes Please see attached. Green White Young 356 1105974 MM25 Robin Upton Bloor Homes Please see attached. Green

27 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Reference MM26 – Strategy for TTV Policy Area – Policy TTV13 – The Quayside. Retention of public car parking to a level sufficient to support the town’s shopping and tourism roles, and which is appropriately located to those roles and incorporated into the design of new development, ensuring that car parking does not dominate the street scene. The above needs Mr Martin Kingsbridge Town to be expanded to ensure the proposed Modification is Sound. 11 1094862 MM26 Johnson Council Recommend additional sentence: Critically, the current 256 public parking spaces in Quay Car Park should not be reduced indeed, car parking capacity in the site should be increased to support the town’s own growth and as a visitor destination.

TTV13 – the Quayside. In clause 2 we suggest that a comma is inserted after “gateway site” to ensure that the clause is clear that a high quality design is required for the gateway site. 62 1014005 MM26 Carol Reeder Natural England The current wording suggest that the gateway site itself conserves and enhances the natural beauty….AONB. The new clause added refers to retention of “a tree canopy”. This wording seems unclear as it could be referring to the canopy of one tree or small isolated number. Replacing “tree canopy” with “a canopy of trees” is suggested as an alternative wording.

I refer to the following two policies: 'MM33 Strategy for TTV Policy Area – Policy TTV29.20 No exacerbating of water quality issues within the Salcombe to Kingsbridge SSSI'. 'MM26 Strategy for TTV Policy Area – Policy TTV13 and associated narrative TTV13 – The Quayside A site wide Sustainable Drainage Strategy to ensure that drainage requirements can be met on site without exacerbating water quality issues within the Salcombe to Kingsbridge SSSI and are designed to deliver landscape, biodiversity and amenity benefits'. Both these site are waterside or urbanised sites close to sea water level. It is not feasible to have these sustainable drainage policy statements for these locations. Much of the area is in flood zone 3 Mr Leslie 168 1190945 MM26 because it the sites are threatened by sea tidal levels within the estuary which is exasperated when southerly gales drive the tidal levels higher inside the estuary. The remaining area Pengelly of TTV13 is close to the estuary and does not have the space to include SUDs into there surface water sewer schemes. Therefore surface water sewers for these two locations will have to drain directly into the estuary and further exasperation of water quality will have to be accepted if these two sites are include.

Natural England's decision. They have a duty to protect the SSSI site.

We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM26 Inclusion of the new point in TTV13 230 658611 MM26 Salmon Agency requiring the investigation and remediation of contaminated land as agreed I our SoCG. Also the clarification in TTV13.5 that development should not exacerbate water quality issues in the Salcombe to Kingsbridge SSSI. This was not one of our recommendations but we are strongly supportive of the addition.

Policy TTV22 and para 5.91 Baker Estates has an interest in the land north of the lane bisecting the site. We support the increase to the housing allocation. However we object to the new accompanying paragraph 5.91. This fails to recognise the challenges of delivering the land north of the lane bisecting the allocation for lower value uses. A site allocated mainly for employment particularly limited to B1 will just not get delivered because of the infrastructure and servicing burden relating to this land. The land has challenging topography and will need a new road junction as well as other requirements which, whilst not making the site unsuitable for development overall, need to be recognised in the land uses and viability. The site is suitable for residential and other uses and will be delivered if the mix is correct. Just being near to other commercial and retail uses does not make this necessarily the most suitable land for a limited range of new employment uses. That statement in 5.91 is not evidenced or substantiated. A better criteria would be to recognise that most businesses of all types (commercial, retail, leisure etc) will prefer or demand road frontage along Plymouth Road. Hence if anything the accompanying paragraph should look to steer the employment parts more towards the eastern part of the allocation generally (including the part south of the lane) towards Plymouth Road rather than looking for a more north / south differentiation. In reality though, it will be commercial forces that decide where the job generating uses go best so this explanatory paragraph is not necessary or helpful in delivering all Mr Richard of the allocated area. This is a potential case of restrictive planning getting in the way of positively generating homes and prosperity. In summary then, this paragraph is unsound and 19 1188721 MM27 Baker Estates Ayre unnecessary because it threatens the delivery of the complete allocation unnecessarily. It also seeks to direct limited employment uses to a particular area unnecessarily and inappropriately. Finally 5.91 opens up the possibility of other job generating uses which is welcomed. To create prosperity for the town and deliver a range of jobs, some flexibility in allowable uses would be helpful. The accompaniment to the policy could therefore be more clear that a range of job generating uses or uses that enhance the facilities available will be welcomed where they benefit the town. As 5.90 recognises, this is a gateway to the town which presents good opportunities if not limited by planning policy.

Paragraph 5.91 should be deleted and replaced with something like: Landowners and developers will be expected to work together and with the councils to deliver the complete allocation including ensuring the whole allocation is viable. Employment generating uses outside the B1 use class order will be considered positively where they can be demonstrated to generate new employment opportunities and enhance the local economy. Whilst not a matter the inspector can direct on, the councils can be reminded, if these points and changes are accepted, that the proposals maps should reflect the policies so in this instance the whole TTV22 allocation should be for mixed use on the proposals map rather than the land north of the lane being employment only.

28 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

TTV22 – Land at Plymouth Road. The 1st sentence in clause 1, with the inserted text “to be informed by a landscape and visual assessment”, is now quite difficult to follow. It appears to be saying that a landscape buffer is require d to address site scale and prominence/impact of the AONB etc. and that design of the landscape buffer should be informed by a 65 1014005 MM27 Carol Reeder Natural England landscape and visual assessment. We seek clarification whether that is the intended meaning of the policy. If it is we suggest deletion of “in order” as a way of making the sentence slightly shorter. We also suggest that clause (6) could be made more concise by shortening to “a lighting strategy to minimise light spill”.

281 1003030 MM27 Annette Carr Please see attached document.

282 1003444 MM27 Robin Carr Please see attached document. Andrew 311 1002991 MM27 Please see letter attached. Overy Nicolette 312 1003364 MM27 Please see letter attached. Overy

MM30. New policy TTV and text for Dartington Hall Estate . We advise that clause (7) needs to be informed by the conclusions of the Habitats Regulations Assessment for this site (see comments below) and should make specific reference to the need for a plan to mitigate any adverse impact on the South Hams Special Area of Conservation (SAC) and associated 66 1014005 MM30 Carol Reeder Natural England population of Greater Horseshoe Bats. Similar wording to that set out in TTV6 (9) could be used. New text associated with allocation at Dartington Hall Estate . The allocated area shown on the proposals map contains a number of priority habitats (including deciduous woodland and semi- improved grassland). We advise that the presence of these habitats , and the need for their protection and enhancement to be considered within an Estate Framework, be referred to within the plan text accompanying this allocation.

Dear Strategic Planners, I am writing to voice my opposition to the Joint Local Plan. I understand that planning inspectors have allocated 504 houses in Dartington and almost another 500 in Totnes. It is unfair and unsustainable, to grow our village by 63% in 20 years. It will damage our countryside, rural character and choke our roads. I object to the development of 97 1190458 MM30 Nisha Toppin the green fields of Broom Park and Sawmills West. In particular I object to the modifications that have been proposed to the Plan - I am concerned about policies which: 2. Allow Dartington Hall Trust to sidestep planning law and build almost 400 houses on its land to generate income rather than to supply local need (no-one else can legally do this).

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 102 1018487 MM30 Gill Gairdner but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning

Dear South West Devon planning department, I wish to object to certain modifications made to the South and West Devon Joint local plan. I am particularly concerned about the proposal to allow the building of 420 houses on Dartington Hall Trust land within the Dartington parish. This will lead to unacceptable pollution levels on the A384 and A385 roads as a result of the extra traffic generated. I understand that WHO safety levels are already being broken along the A385 corridor from Dartington to Totnes and vehicles owned by people from this proposed development and deliveries to the properties will only make this problem worse and must therefore be illegal. I believe this policy will result in the unwanted Dr Edward 105 1055107 MM30 urbanisation of the village of Dartington. The process does not appear to be in response to local housing needs but to help the funding of the Dartington Hall Estate and should not Southall therefore be considered as a legitimate planning need. I am also concerned about the threat to the habitat of endangered species in the area , in particular Greater Horseshoe bats and their likely loss of habitat. These are protected by law and such housing development could be breaking this law by disturbing their habitat. The proposed new housing developments in Dartington are disproportionate to the size of the village and it is clear that the villagers oppose this development. Please acknowledge this complaint. Yours sincerely Dr Edward Southall MB BS FRCP

Policy MM30 (TTV NEW). Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 107 1018748 MM30 Hazel Fuller but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

Anthea Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 111 1013363 MM30 Scholefield but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 115 1017978 MM30 D Elphick but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Barbara Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 119 1017979 MM30 Henry but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 123 1190518 MM30 A Richards but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

29 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Miss Rosa Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 127 1013608 MM30 Bloomberg but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

McConnell- Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 131 1190520 MM30 Bloomberg but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 135 1190522 MM30 Janet Wilce but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 139 1190523 MM30 W Ollis but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 143 1190525 MM30 Pam Gorman but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

PLYMOUTH & SOUTH WEST DEVON JOINT LOCAL PLAN 2014-2034 Housing on Dartington Estate does not meet any local need. Air pollution is already a problem along the A385. No regard is being paid to maintaining the character of Dartington village. No regard is being paid to the implications for traffic of putting hundreds of cars on the already snarled up A385 Dr Tony 171 1190986 MM30 either on local people or on the tourist trade who take the same route from Dartington to Totnes in order to access the South Hams. Lopez Local houses should be built for local people as they need them. Not for retired folk to move into from London and the SE. We need fewer and more affordable homes.

Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 174 1191000 MM30 Joyce Higgins but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Mrs F H Policy MM30 (TTV NEW). Allocating at least 120 houses on the Dartington Hall Estate (plus over 300 on DHT-owned land in Dartington parish) is a response not to local housing needs 178 1191008 MM30 Williams but to the ‘need for housing and commercial development to generate long-term funding streams …’. This is not a material consideration for planning.

Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 185 1191016 MM30 Pippa Palmer but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

The inclusion of a new policy for Dartington Hall Estate is supported, but the modification to the wording as outlined below are requested. The status of the Estate Framework is not clear. Should it be prepared and formally adopted as a Supplementary Planning Document ensuring full consultation in accordance with regulations? The development and intensification of activities on the Estate will impact directly upon the Parish and its residents and so Dartington Parish Council should be identified as a party who would need to endorse the Estate Framework, together with Historic England and SHDC, taking into account of course the relative status of the input of each of each of the endorsing bodies. (4th New paragraph)

Add the underlined text to Consequential Amendment paragraph 5.122…future sustainability of the settlement: Given the special qualities of the Dartington Estate, future Dartington Parish 204 1191022 MM30 Kate Wilson redevelopment and new development must be sensitive to its character and importance both locally and nationally. It is therefore important that the form scope, scale and design of Council redevelopment and new development on, or in close proximity to, the Dartington Estate must be informed by the detail contained by a publicly available Heritage Impact Assessment and Wildlife and Habitats Impact Assessments. Add to Point a) After it reads fragmentation of the historic entity ‘ and protected wildlife habitats’ . Add to Point 7 the text underlined ‘ that a full assessment of the potential ecological impacts of the proposed developments, individually or in combination , has been undertaken (including greater horseshoe bats), and where appropriate a mitigation plan has been prepared. Add the underlined text to New Para 3 …. historic buildings and landscape, wildlife and habitats. New Para 4: The development and intensification of activities on the Estate will impact directly upon the Parish and its residents and so Dartington Parish Council should be identified as a party who would need to endorse the Estate Framework, together with Historic England and SHDC, taking into account of course the relative status of the input of each of each of the endorsing bodies. Insert appropriate wording to achieve this. Add the underlined text to New Para 5 line 4....learning, arts and culture and tourism/leisure opportunities

30 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Having read through as much as I can...i can clearly see the plan is being shifted in favour of more housing.....and more of the countryside disappearing. I live in Bickleigh. ...Our whole outlook will change...including the drive down from the main road....light pollution will increase...as will noise...as will the whole outlook onto the countryside. Not content with that...you know are looking at starting development before the road infrastructure is improved ? None of this can be allowed...The commute into the city is dreadful at best. ..and 247 1096846 MM30 Neil Clayton wholly ridiculous during rush hour.... We will not roll over on this so please be aware that you may think you can change the rules as you see fit. ...its not happening. I take it with the leviathan that will be Woolwell housing that there will be no need for further development on the Airport ?? So please tender this email that we do not agree with the latest changes to the Local area build what you want plan Neil Clayton

Historic England comments on the Main Modifications Policy Area – Policy TTV29.4, TTV29.5, TTV29.10 and associated narrative As a consequence of the inclusion of a housing figure, at the insistence of the Council at the last minute and without any evidence to support its insertion, we consider that additional safeguards are now required to ensure Dartington’s historic assets are not harmed. This would help ensure that a positive strategy is put in place to ensure the assets are properly managed. To enable a positive resolution on this issue we propose the attached changes to the modifications. Without these proposed changes Historic England cannot support the inclusion of a housing figure as national policy would not be satisfied. In the event a housing figure is included without the proposed changes we would be obliged to place an objection to the policy. If, however, the Inspectors and Councils Ross can agree and incorporate these changes into the policy, we can confirm that the objection from Historic England would be withdrawn. Historic England understands that the informal 341 961942 MM30 Historic England Simmonds view of the JLP Councils is that they do not fundamentally disagree with any of the points raised or modifications suggested, but recognise it is the role of the Inspectors to determine. We also understand that the Council is likely to introduce a general Supplementary Planning Document (SPD) that will cover a number of Joint Plan matters. For Dartington Estate this will provide greater clarity and certainty on the objectives of the Dartington Policy in the interests of an effective process and ensure heritage led outcomes. Therefore additional wording will be required in the text of the Dartington Policy to set out the context for bringing forward the Estate Framework and subsequent planning applications, we have provided a draft wording in the attached amendments for your consideration. We would respectfully request that you consider the inclusion of these changes to achieve a sound plan. Regards Ross Simmonds

Andrew Dartington Hall 344 1002035 MM30 Lichfields Jo Talling Please see attached. Cockett Trust

MM30 -TTV29.10 Woodlands Yard allocated floorspace was shown as 5,500 sq m. This is an error. The figure proposed by Dartington Hall Trust was 510 sq m (5,500 sq ft). DHT informed SHDC in late 2017 but the error was never corrected in the JLP. Although TTV29.10 is deleted in MM30, the incorrect figure of 5,500 sq m is still included in the JLP total 358 1016029 MM30 Janice Balch employment space for Dartington and in the TTV total employment space. The effect of the Beacon Park and Woodlands Yard errors is to overstate the Dartington employment floorspace total, currently shown in the JLP as 17,300 sq m, by about 8,500 to 9,000 sq m. This is SIGNIFICANT and could result in the JLP being flawed.

TTV(NEW1) Dartington Hall Estate Policy - Under the present wording of the JLP the Estate Framework does not appear to have any planning status. It should be a Supplementary 359 1016029 MM30 Janice Balch Planning Document to ensure that the Community are consulted under statutory consultation procedures. The status of the Estate Framework should also be linked in the JLP, to the Dartington Hall Trust whose Trustees are responsible for overseeing DHT’s pursuit of its objectives and who are regulated by the Charity Commission.

Amanda 389 1018467 MM30 Please see attached (Dartington) Chadwick

394 1191638 MM30 Adam Griffin Please see attached (Dartington)

399 1191642 MM30 Angla Hornby Please see attached (Dartington)

Agata 404 1191646 MM30 Please see attached (Dartington) Krajewska Ashley 409 1191654 MM30 Please see attached (Dartington) Parsons

414 1191660 MM30 Andrea Prew Please see attached (Dartington)

Mrs A 418 1191664 MM30 Please see attached (Dartington) Robinson Miss Ali 423 1094187 MM30 Please see attached (Dartington) Roscoe Mr Ashton 428 1114209 MM30 Please see attached (Dartington) Chadwick Cllr Andy 433 1191668 MM30 Please see attached (Dartington) Simms

31 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 438 1191677 MM30 A Smaldon Please see attached (Dartington) 443 1191679 MM30 Alan Whele Please see attached (Dartington) 448 1191680 MM30 Mrs Aydin Please see attached (Dartington)

453 1191681 MM30 Barbara Keen Please see attached (Dartington)

458 1191683 MM30 Bree Long Please see attached (Dartington)

463 1191687 MM30 Brian Mascall Please see attached (Dartington)

Carol 468 1191688 MM30 Please see attached (Dartington) Ballenger Christina 473 1097444 MM30 Please see attached (Dartington) Bennett

478 1191707 MM30 Chris Harding Please see attached (Dartington)

483 1017437 MM30 Clare Hornsey Please see attached (Dartington)

488 1191709 MM30 Mr C Mapsen Please see attached (Dartington)

493 1018458 MM30 Carole Powell Please see attached (Dartington)

498 1191712 MM30 Miss C Watt Please see attached (Dartington) Denis 503 1191715 MM30 Please see attached (Dartington) Anderson

508 1097433 MM30 David Barnett Please see attached (Dartington)

David 513 1097428 MM30 Please see attached (Dartington) Duncombe David 518 1191719 MM30 Please see attached (Dartington) Ferguson

523 1191720 MM30 Donald James Please see attached (Dartington)

Dick 528 1191723 MM30 Please see attached (Dartington) Kassabian 533 1191726 MM30 D Smaldon Please see attached (Dartington) 538 1191729 MM30 David Vitler Please see attached (Dartington) Doirrey 543 1191730 MM30 Please see attached (Dartington) Watterson 548 1191732 MM30 D Young Please see attached (Dartington) Elizabeth 553 1014700 MM30 Please see attached (Dartington) Callaway 558 1191743 MM30 E Ferguson Please see attached (Dartington) Elizabeth 563 1191745 MM30 Please see attached (Dartington) Turner Esther 568 1097402 MM30 Please see attached (Dartington) Watson

573 1017430 MM30 Fiona Bicknell Please see attached (Dartington)

Frances 579 1191752 MM30 Please see attached (Dartington) Brodrick

32 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Anne 583 1191751 MM30 Please see attached PDF (Dartington) Woodend 588 1191756 MM30 Colin Bastin Please see attached PDF (Dartington) 593 1191757 MM30 Fiona Tilley Please see attached (Dartington) 598 1191759 MM30 Claire Stoyle Please see attached PDF (Dartington) 605 1191766 MM30 Don Tucker Please see attached (Dartington)

606 1191762 MM30 Graham Black Please see attached (Dartington)

614 1191771 MM30 Ella Baillie Please see attached (Dartington)

617 1191772 MM30 Geoff Caplan Please see attached (Dartington)

625 1018737 MM30 EA Potter Please see attached (Dartington) Geoffrey 628 1018138 MM30 Please see attached (Dartington) Nickolls

634 1191776 MM30 Graham Prew Please see attached (Dartington)

638 1191777 MM30 Gail Johnson Please see attached (Dartington) Gordon 645 1191780 MM30 Please see attached PDF (Dartington) Woodend Gordon 648 1002916 MM30 Please see attached (Dartington) Riddel Isaac 653 1097358 MM30 Please see attached (Dartington) Bloomberg 659 1018485 MM30 D Hannaford Please see attached (Dartington)

663 1191782 MM30 I Underdown Please see attached (Dartington)

668 1191784 MM30 H Hannaford Please see attached (Dartington)

673 1018187 MM30 J Rich Please see attached (Dartington) 678 1191786 MM30 Lisa Daix Please see attached (Dartington) 683 1191788 MM30 Hon Ashton Please see attached (Dartington) 689 1191790 MM30 L Keel Please see attached (Dartington) 693 1016052 MM30 Heidi Orrell Please see attached (Dartington) Richard and 699 1018437 MM30 Jeanne Please see attached (Dartington) Hughes 703 1191793 MM30 M Cole Please see attached (Dartington) 708 1191795 MM30 Helen Welsh Please see attached (Dartington)

713 1016272 MM30 Isabelle Orrell Please see attached (Dartington)

718 1191800 MM30 Ian Smail Please see attached (Dartington)

723 1191801 MM30 John Callaway Please see attached (Dartington)

Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 732 1191806 MM30 Ros Durston but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 736 1095210 MM30 Barry Reeves but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

33 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 740 1191810 MM30 Anita Cole but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 745 1017703 MM30 Helen Tune but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

Miss Selena Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 750 1094766 MM30 Mara but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

I am concerned about policies which 1. Allow developers to build 2077 SURPLUS houses in South Hams- 27% above even the Joint Local Plan’s assessment of housing needs. 2. Allow Dartington Hall Trust to sidestep planning law and build almost 400 houses on its land to generate income rather than to supply local need (no-one else can legally do this). 2. Ignore the increase in air pollution that 1000 houses in Dartington and Totnes will create (1000 houses could mean 2000 more cars including deliveries etc). The A385 corridor already 753 1191812 MM30 Wig Sayell regularly breaks World Health Organisation safety levels for air quality. We are breathing toxic air as bad as that in any city. 3, Damage wildlife. We are so lucky to have Greater Horseshoe bats and dormice which are on the brink of extinction, but some policies in the JLP allow ‘mitigation’ to enable development. This means that precious habitats can be destroyed and a feature favoured by a species (eg a hedge) can be created elsewhere in the hope that the bats, dormice or otters will move in. Mitigation in the case of endangered species is illegal, so this policy must be changed. Councillor South Cllr Jacqi 754 1016671 MM30 Hams District Please see attached. Hodgson Council

Policy MM30 (TTV NEW).Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish, has not been founded on local housing needs, 756 1014631 MM30 Josh Zatz but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

Policy MM30 (TTV NEW): Allocating at least 120 houses on Dartington Hall Estate plus over 300 on DHT owned land in Dartington parish. This has not been founded on local housing 760 1095118 MM30 Sharon Ellis needs, but the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning.

I object to the planned further allocation of large numbers of houses to Totnes and Dartington, locations that have already seen considerable increases in housing. My objections are based on several concerns. Firstly the current availability of medical services will not support this increase. It already takes 2-3 weeks to get a routine appointment with a doctor at my local surgery. Through my work as a doctor in Plymouth I have witnessed at first hand the chaos that ensues when primary care services are insufficient to meet local need, the strain Dr Karen 763 1191813 MM30 that it imposes on secondary care, and the danger posed to patient safety. Primary care services are provided throughout South Hams, and housing should reflect this. Secondly the Gilmore roads are frequently already grid-locked in Totnes. Without a bypass this will only get worse. As the A385 corridor already regularly breaks WHO safety levels for air quality further traffic is likely to impact adversely on the health of current residents. Finally I understand that the proposed “mitigation” relating to endangered species is illegal, and will therefore be challenged where possible. We should all be working to preserve the endangered horseshoe bats

766 1191814 MM30 T Lang Please see attached (Dartington)

770 1191815 MM30 Joel Chadwick Please see attached (Dartington)

Janice 775 1018151 MM30 Please see attached (Dartington) Duncombe James 780 1097475 MM30 Please see attached (Dartington) Fordham John 785 1191817 MM30 Please see attached (Dartington) Greenhalgh 790 1097375 MM30 Joy Hanson Please see attached (Dartington)

795 1191818 MM30 Jenny Heaton Please see attached (Dartington)

800 1191819 MM30 Jane Hext Please see attached (Dartington) 805 1191820 MM30 June Hext Please see attached (Dartington) 810 1191821 MM30 J Hodgson Please see attached (Dartington) 816 1191822 MM30 John Lee Please see attached (Dartington) 821 1014649 MM30 J Marshall Please see attached (Dartington)

34 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Lesley 825 1191823 MM30 Please see attached (Dartington) Marshall 830 1191824 MM30 Josh Orrell Please see attached (Dartington) Jonathan 835 1191828 MM30 Please see attached (Dartington) Reeves Josephine 840 1013778 MM30 Please see attached (Dartington) Unwin Arthur 844 1191829 MM30 Please see attached (Dartington) Durrant 846 1073274 MM30 Joanna Watt Please see attached (Dartington)

852 1018385 MM30 Jacqui Wilkins Please see attached (Dartington)

861 1191830 MM30 Kevin Childs Please see attached (Dartington) Katherine 866 1191832 MM30 Please see attached (Dartington) Smaldon 870 1018193 MM30 Alex Sharp Please see attached (Dartington) 875 1191833 MM30 Kevin Weale Please see attached (Dartington)

881 1014279 MM30 Lucia Fausset Please see attached (Dartington)

886 1191834 MM30 Cass Wynne Please see attached (Dartington) 888 1191835 MM30 Lorna James Please see attached (Dartington) 895 1191836 MM30 L Korda Please see attached (Dartington) Mr and Mrs T 900 1191837 MM30 Please see attached (Dartington) Locker 905 1191860 MM30 Michael Cox Please see attached (Dartington)

910 1191861 MM30 Mary Hobden Please see attached (Dartington)

911 1191861 MM30 Mary Hobden Please see attached (Dartington)

916 1018405 MM30 Mavis Jones Please see attached (Dartington) Dr Malcolm 921 1017707 MM30 Please see attached (Dartington) Purcell 926 1191882 MM30 Mick Wicks Please see attached (Dartington) Mr Nigel 933 1094768 MM30 Please see attached (Dartington) Backhouse Lauryn 935 1191915 MM30 Please see attached (Dartington) Reeves Elizabeth 940 1018413 MM30 Please see attached (Dartington) Williams Matthew 945 1191933 MM30 Please see attached (Dartington) Heming Michael 952 1191935 MM30 Please see attached (Dartington) Brown 954 1191934 MM30 Nigel Hinks Please see attached (Dartington) 962 1017617 MM30 P Douglas Please see attached (Dartington) Mr Martin 966 1073037 MM30 Please see attached (Dartington) Crawford 972 1191937 MM30 Matt Harvey Please see attached (Dartington)

974 1191936 MM30 Philip R Jones Please see attached (Dartington)

35 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 981 1191938 MM30 Pete Reeves Please see attached (Dartington) Rosamund 986 1018175 MM30 Please see attached (Dartington) Bastin Martina 991 1191939 MM30 Please see attached (Dartington) Heming 996 1191943 MM30 Minni Jain Please see attached (Dartington) Ms Mary 1001 1095121 MM30 Please see attached (Dartington) Light Michelle 1006 1191948 MM30 Please see attached (Dartington) McHale

1011 1191949 MM30 Richard Hard Please see attached (Dartington)

Main 1016 1191951 MM30 Please see attached (Dartington) Patterson 1021 1191952 MM30 Rooh Star Please see attached (Dartington) 1026 1191953 MM30 Monika Pike Please see attached (Dartington)

1032 1191954 MM30 Rachel Tucker Please see attached (Dartington)

Marti 1036 1191955 MM30 Please see attached (Dartington) Valentine 1042 1191958 MM30 Mike Welsh Please see attached (Dartington) 1046 1191957 MM30 Sarah Curtis Please see attached (Dartington) 1051 1191961 MM30 Nell Admiral Please see attached (Dartington)

1056 1191963 MM30 Nicholas Keen Please see attached (Dartington)

1061 1191966 MM30 Mr O Clarke Please see attached (Dartington) Oliver 1066 1095333 MM30 Please see attached (Dartington) Tringham 1071 1191968 MM30 T Palm Please see attached (Dartington) 1077 1018745 MM30 Pollie Ash Please see attached (Dartington) Mr Phillip 1081 1094867 MM30 Please see attached (Dartington) Bridge

Philip and 1086 1097512 MM30 Minni Franses Please see attached (Dartington) and Jain

1092 1191972 MM30 Sara Ferguson Please see attached (Dartington)

1096 1095641 MM30 Paul Hornby Please see attached (Dartington) 1102 1191973 MM30 Sandra Hard Please see attached (Dartington) Pamela 1107 1191974 MM30 Please see attached (Dartington) Kassabian SC 1111 1191975 MM30 Please see attached (Dartington) Underdown 1116 1191977 MM30 Sue Wicks Please see attached (Dartington) 1122 1191978 MM30 T Backhouse Please see attached (Dartington) 1126 1191980 MM30 Tanya Bell Please see attached (Dartington) 1131 1191981 MM30 Tim Grevatt Please see attached (Dartington) 1136 1191979 MM30 Peter Mingo Please see attached (Dartington)

36 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

1141 1191982 MM30 Vicky Hadland Please see attached (Dartington)

Patricia 1147 1191983 MM30 Please see attached (Dartington) O'Carroll 1151 1191985 MM30 Vivien Hinks Please see attached (Dartington) 1157 1018364 MM30 R & VM Keel Please see attached (Dartington) Phil 1161 1191986 MM30 Please see attached (Dartington) Sheardown Miss MR 1166 1018574 MM30 Please see attached (Dartington) Brand 1171 1191987 MM30 V J May Please see attached (Dartington) 1176 1191993 MM30 R Orrell Please see attached (Dartington) 1181 1191995 MM30 Richard Pike Please see attached (Dartington)

1186 1191997 MM30 Rosie Roberts Please see attached (Dartington)

1192 1191998 MM30 Roger Shelley Please see attached (Dartington)

Mr & Mrs RH 1196 1018009 MM30 Please see attached (Dartington) Tripp 1202 1191989 MM30 Debbie Feld Please see attached (Dartington) Mr R 1206 1018359 MM30 Please see attached (Dartington) Valentine 1211 1018420 MM30 Janice Bragg Please see attached (Dartington) 1217 1192003 MM30 Susan Boal Please see attached (Dartington)

1221 1192004 MM30 John Chapple Please see attached (Dartington)

1227 1192007 MM30 Jane Parker Please see attached (Dartington) 1231 1017953 MM30 John Platt Please see attached (Dartington) 1237 1192006 MM30 S Carrol Please see attached (Dartington) 1241 1192010 MM30 Lise Platt Please see attached (Dartington) Sandra 1247 1018749 MM30 Please see attached (Dartington) Crawford

1251 1018584 MM30 Marion Baker Please see attached (Dartington)

1256 1192013 MM30 Mike Bridger Please see attached (Dartington)

1262 1018583 MM30 M Green Please see attached (Dartington)

Susan 1266 1018841 MM30 Please see attached (Dartington) Goldsworthy

1272 1018446 MM30 M Lang Please see attached (Dartington) Mrs Susan 1276 1018172 MM30 Please see attached (Dartington) Greenhalgh Margaret 1281 1192017 MM30 Please see attached (Dartington) Lewis Philomena 1286 1192019 MM30 Please see attached (Dartington) Wynne 1292 1018169 MM30 Sandra Lee Please see attached (Dartington) Mr Roger 1296 1093100 MM30 Please see attached (Dartington) Nicholson

37 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Susan 1302 1192021 MM30 Please see attached (Dartington) Nancholas Stephen 1306 1192022 MM30 Please see attached (Dartington) Harper 1311 1192023 MM30 S Niemeyer Please see attached (Dartington) Mrs Sue 1316 1017725 MM30 Please see attached (Dartington) Norris Simon 1321 1192025 MM30 Please see attached (Dartington) Patterson Shimako 1327 1018357 MM30 Please see attached (Dartington) Sharpe

1331 1192027 MM30 Susan Weare Please see attached (Dartington)

Timothy 1336 1192030 MM30 Please see attached (Dartington) Hornsey 1341 1192034 MM30 Wendy Cook Please see attached (Dartington) 1346 1192035 MM30 Wendy Fisk Please see attached (Dartington)

Reference: Policy MM30 (TTV NEW). Allocating over 300 houses on Dartington Hall Trust owned land outside the core estate of 1,200 acres and instead in Dartington parish has not been founded on local housing needs, but on the ‘need for housing and commercial development to generate long term funding streams…’ This is not a material consideration for planning and any development for this purpose needs to be confined to the Dartington Hall Trust Estate rather than creating a further burden of development on Dartington village with the associated loss of green space amenity, the increase in traffic through the village on the already congested A385 and the resultant in crease in air pollution when the A385 is already the subject of an AQMA with no sign that levels are reducing. To explain: building all the 300 allocated houses on the 1,200 acre Dartington estate will be closer to foot and 306 1015453 MM30 Karin Jordan cycle paths, the local Totnes rail station and inhabitants can enter and leave the estate via a road that reduces the impact on Dartington village. These elements have a significant opportunity to reduce impact on Dartington village which, as noted in comment 2, has already had a significant number of new homes built and been allocated yet more in the JLP. Should the planners consider that development to justify income stream is a material planning consideration then my preference, and a very practical and simple solution, is for an increase in the 120 houses allocated to the Dartington Hall Trust Estate itself and I understand from previous documents published by the Dartington Hall Trustees that they are willing to have up to 300 homes built on the estate itself, an increase from 120 to 300 would achieve an additional 180 homes of the 300 allocation. MM30 (TTV new) is not justified.

MM30: We advise that this new policy should be screened in. This is based on the fact that whilst the number of units has been reduced, there is no clarity about where in the area the new development will be located. Our advice is therefore that you consider this further as part of an Appropriate Assessment of the policy. As stated in our response to the SEA, we 74 1014005 MM30 - HRA Carol Reeder Natural England consider that the policy is too weak in relation to the impact of the development on the South Hams SAC and that the policy is strengthened as was done for policy TTV6 under Main Modification 23 point 9. If the policy is thus amended to provide the appropriate safeguards we consider that a conclusion of ‘no likely significant effects’ can be made.

Delete Policy TTV15.1 – West Alvington Hill West Alvington Hill, Kingsbridge, instead to be added as a commitment site given that it has planning consent. The above statement contained within MM31 is contradictory. The Planning inspectors have requested that TTV15.1 is deleted and the joint councils have agreed. They then include the statement in MM31 Mr Leslie to retain the site in the joint local plan. It was removed because of the level of harm occurring in the South Devon AONB area at Kingsbridge. Clearly the Joint Councils do not respect or 167 1190945 MM31 Pengelly understand that decision.

Delete all references to TTV15.1 in the plan. It has been deleted as a site. Nicole PCL Planning 339 1191551 MM31 Baker Estates Please see attached. Stacey Ltd MM31 (Policy TTV15.1 and TTV29.23) The MM to remove certain sites as allocations which are located in Area of Outstanding Natural Beauty (AONB) is welcomed. This has also been reflected on the updated Housing Trajectory (TP3L). The sites removed include: TTV15.1 West Alvington Hill, Kingsbridge (60 units) TTV29.23 Land South East of Carehouse Cross, Jonathan Walsingham Land Value Stokenhan (20 units) It is noted from the Revised Housing Topic Paper Addendum (October 2018) that it has not been necessary to allocate further sites to take into account the 348 1096270 MM31 Chick Planning Alliances (LVA) reduction in housing supply as a result of the AONB sites being removed as allocations. However, as set out in our comments on MM3, LVA still raise concerns regarding the ability of strategic sites to maintain a 5 year supply of housing. As the housing requirements are expressed as ‘minimum’ it is considered further sites should be allocated for flexibility in the TTVPA particularly in the ‘towns and key villages’.

38 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Ms Victoria 372 1095125 MM31 Tanner- SUPPORT the removal of allocation sites within the AONB. for West Alvington Hill and Land South East of Carehouse Cross Tremaine We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM32 Inclusion of the new point in TTV29.20 231 658611 MM32 Salmon Agency requiring development to not exacerbate water quality issues in the Salcombe to Kingsbridge SSSI. This was not one of our recommendations but we are strongly supportive of the addition.

The town needs more employment opportunities rather than just housing and the market area could provide this through the redevelopment of the pannier market, auctions and livestock market with regeneration plans to include education, training, start up business units etc. The Hatherleigh Community Market Development Group isÂ proposing plans to generate more jobs as well as strengthening social contact and wellbeing for residents in the town and wider rural community. Reducing the number of houses and developing the site Miss Freya 241 1094770 MM32 for further economic development, heritage and community use is seen to be vital to the growth and wellbeing of the local community Holland Plans are being made by the community to purchase the site with the use of Heritage Lottery Funding, other grant funds and economic investment in the area to regenerate the town centre so that the housing/ employment use is better balanced

Jonathan Walsingham Land Value 349 1096270 MM32 Please see attached. Chick Planning Alliances (LVA)

I refer to the following two policies: 'MM33 Strategy for TTV Policy Area – Policy TTV29.20 No exacerbating of water quality issues within the Salcombe to Kingsbridge SSSI'. 'MM26 Strategy for TTV Policy Area – Policy TTV13 and associated narrative TTV13 – The Quayside A site wide Sustainable Drainage Strategy to ensure that drainage requirements can be met on site without exacerbating water quality issues within the Salcombe to Kingsbridge SSSI and are designed to deliver landscape, biodiversity and amenity benefits'. Both these site are waterside or urbanised sites close to sea water level. It is not feasible to have these sustainable drainage policy statements for these locations. Much of the area is in flood zone 3 Mr Leslie 169 1190945 MM33 because it the sites are threatened by sea tidal levels within the estuary which is exasperated when southerly gales drive the tidal levels higher inside the estuary. The remaining area Pengelly of TTV13 is close to the estuary and does not have the space to include SUDs into there surface water sewer schemes. Therefore surface water sewers for these two locations will have to drain directly into the estuary and further exasperation of water quality will have to be accepted if these two sites are include.

Natural England's decision. They have a duty to protect the SSSI site.

Ms Victoria 373 1095125 MM33 Tanner- SUPPORT. Welcome proposed modifications to: 20. Shaddycombe point 2 and the new point regarding water quality in Salcombe to Kingsbridge SSSI. Tremaine

MM34 – As per the above the target in policy TTV30 should remain at 720. Any development that comes forward under this policy is almost certainly going to be on land adjoining the identified sustainable villages. We consider that the reference to the policy approach applying to sites ‘within’ the identified villages is unhelpful. There will inevitably be uncertainty over whether sites put forward under this policy can be considered ‘within’ a settlement. A plain English interpretation would be that the policy approach would only allow developments under TTV30 to come forward if they are within the existing built form. This is clearly perverse and we would suggest not really the intended consequence of the policy 7 1074071 MM34 Neal Jillings Place Land LLP approach. It would be far simpler to specifically state that sites ‘within or adjoining’ sustainable villages. It is illogical to have supporting text that relates to an exception rather than the norm expected under the policy approach.

Change required – supporting text changed as follows, “ Within or adjoining sustainable villages without neighbourhood plans the LPAs will still support development… ”

Para 5.156 - The incorporation of the report "the South Hams & West Devon Village Sustainability Assessment Framework Feb 2017’." in 5.156 is not compliant because this report did not go out to full public consultation with the March 2017 draft JLP nor was it listed as an appendix. If it had been, it would have been objected to for several inaccuracies and also the bench mark for ‘Sustainability’ is arbitrary and not based on any national independent research or definition. I believe that it and cannot now be incorporated at this late stage. I would have raised these objections with you at the Inspectors hearings, if I had had the opportunity, but I did point out, at the first hearing concerning TTV’s, that the report was not Mr Richard 14 1072792 MM34 included in the JLP . This report will negate the Inspectors’ requirement to delete the AONB villages from Para 5.10 and fig 5.8. Baker I would ask for reference to this report to be withdrawn and Neighbourhood Plans will then address what is suitable in each village on a case by case basis and in the AONB this will be done on local need and not on a pre-determined target. ie. delete from an indicative assessment.....the South Hams & West Devon Village Sustainability Assessment Framework Feb 2017’. This assessment...... in each settlement...

39 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

In Paragraph 5.156 the "South Hams & West Devon Village Sustainability Assessment Framework', Feb 2017" has been included and this was not included in the original submission and legally, I believe, cannot be included at this late stage as public consultation has not taken place. I understand that this was written by one person and was not the subject of site visits Mr Mike and thus many incorrect assumptions and calculations were made. Thus the statement that this document gives "an indicative assessment" cannot be made. The result is that the 17 1010886 MM34 Wynne- conclusions in this document are at odds with the valid striking out of villages as not being sustainable from the Figure 5.8 in MM35. Powell Removal of all references to the document South Hams & West Devon Village Sustainability Assessment Framework', Feb 2017.

Mr Michael Eden Land 20 1188472 MM34 Please refer to letter. Drake Planning Thurlestone Parish Council Policy TTV30 Development in the Sustainable Villages. We support this clarification that local housing and other development needs within Sustainable Villages should be provided 89 1002318 MM34 Sue Crowther and through neighbourhood plans. This is consistent with MM2. Neighbourhood Plan

Reference to the Village Assessment Framework should be removed in 5.156. I do not believe this assessment is a consistent or accurate reflection of sustainability criteria. For example, Ugborough has one bus on one day a week, surely this should not have the same sustainability value as a daily/frequent bus service. Ermington have the same bus service (in Mrs Joan fact the same one bus) as Ugborough and have half a score (rather than the full score that Ugborough has). Why does Sustainable Saturdays selling a very limited range of goods for 2 163 1190904 MM34 Fletcher hours once a fortnight score half points under the shop criteria? Ermington also have Sustainable Saturdays once a fortnight and they aren't scored at all for this.

The reference to the Village Assessment Framework should be removed. If not, at least reduce Ugborough's sustainability score (see above).

MM34: Policy TTV30 and associated narrative The policy refers to development proposals ‘within’ sustainable villages. The wording is ambiguous and could be interpreted to mean Emery Wainhomes Mr John that development must be within the settlement boundaries of a village. This would be inappropriate. Firstly, up-to-date settlement boundaries have not been established through this 211 893384 MM34 Planning (South West) Coxon plan. Secondly, it is clear that in order to achieve development at the sustainable villages land will be required on the edge of existing settlements. We therefore consider that the Partnership Holdings Ltd. wording should be amended to refer to development ‘within or adjoining ’ the sustainable villages. Paignton Mr David 221 1094326 MM34 Neighbourhood The Forum supports the proposals as published and in particular those of MM34. Watts Plan Forum

Mr Paul BBH Architects 351 1008424 MM34 Please see attached. Myers (Dartmouth) Ltd

Ugborough cannot 'accommodate around 30 dwellings'. Evidence base does not support the modification. Contrary to the provisions of the Ugborough Development Plan. Sarah Ugborough 15 1002392 MM35 Woodman Parish Council To be legally compliant, plan must reflect the provisions of the Ugborough Neighbourhood Development Plan. Suggested revised wording: Accommodate around 30 dwellings within the Ugborough Neighbourhood Development Plan Area.

Mr Michael Eden Land 21 1188472 MM35 Please refer to letter. Drake Planning At a stroke, villages within the AONB, which were considered 'sustainable' in the proposed Plan and have for many years been so classed are now removed from the list of sustainable villages. Many of these villages have settlement boundaries which has effectively defined, within each village, the boundary of sustainability. (Development within the SB is assumed sustainable, development outside the SB must demonstrate sustainability). The proposed response to MM35 leaves an unacceptable level of ambiguity with which to judge Planning applications. Are these villages sustainable or not? What purpose does the SB serve? If the JLP considers these villages as not sustainable and the NP differs, whose plan has the greater Mr Ric 44 1189943 MM35 weight? Does the JLP really consider Yelverton (much of which falls in the AONB) not sustainable while DNPA consider the other part of Yelverton a Local Centre which should Cheadle accommodate development?

The JLP need to develop less of a 'blanket' approach and understand which villages within the AONB are sustainable and which are not. Development within well established settlement boundaries in villages within the AONB which are identified as sustainable should be identified and development policies should reflect this.

40 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Thurlestone Parish Council Narrative relating to Policy TTV30. Para 5.158 . We support the removal of the AONB villages from the indicative housing figures for the Sustainable Villages (Figure 5.8). However, the 90 1002318 MM35 Sue Crowther and reference to how neighbourhood plans may still bring forward “positive allocations to meet local housing needs” is unnecessary, given that the policy approach to considering Neighbourhood development in AONBs is set out in Policy DEV27. Plan TTV30 and Fig 5.8 does not align with the adopted Ugborough NDP which is a Plan for the whole Plan Area and not a specific settlement. The focus in TTV30 and Fig 5.8 purely on Mrs Joan Ugborough village does not reflect the objectives of the Ugborough NDP. 164 1190904 MM35 Fletcher The indicative level of housing should be for the designated Plan Area and not specifically Ugborough Village. MM35: Fig 5.8 and associated narrative Brixton has been incorrectly removed from the list of sustainable villages. The AONB boundary runs from east to west along the A379, through Emery Wainhomes the middle of the village. The northern side of the village is therefore not within the AONB, and furthermore the Local Plan evidence base identified site options for development to the Mr John 212 893384 MM35 Planning (South West) north which are not constrained by the AONB (see the SHLAA Site Information Packs for Brixton and the accompanying plan: CD HO4A, pages 22-27 of the PDF version). Brixton should Coxon Partnership Holdings Ltd. therefore be re-instated to the list. Please note that our objections remain in relation to the indicative levels of development shown (including for Brixton), and also the inappropriate tick-box ranking of sustainability which underpins Policy TTV30 and Figure 5.8. Paignton Mr David 222 1094326 MM35 Neighbourhood The Forum supports the proposals as published and in particular those of MM35. Watts Plan Forum

This modification excludes all 41 formerly ‘sustainable villages’ located within the South Devon AONB from the Strategy for TTV Policy Area, resulting in a net 380 dwelling reduction in the villages of this part of the Plan area. The NPPF gives great weight to conserving and enhancing landscape and scenic beauty in AONBs, but the NPPF also indicates that this should not preclude limited small-scale development within an AONB (Paragraph 172). This is particularly true where there is an identified local need for new housing development in a wider policy climate where local planning authorities need to boost significantly the supply of both market and affordable housing. Paragraph 77 of the NPPF is clear that planning policies should be responsive to local circumstances and support housing developments that reflect local needs. This is true for villages within an AONB as much as anywhere else and this Big Tree Richard 289 1191475 MM35 Sam Grant modification would prevent that responsiveness. The effect of this modification will be to impose a moratorium on much-needed local market and affordable housing development Planning Ltd Sanderson within all AONB villages even those where there is an objective and identified need. This would be on the basis of a single, albeit important, material consideration and removing all villages within the AONB unacceptably tilts the planning balance away from the presumption in favour of sustainable development. The associated amendment to Para 5.158 indicates that neighbourhood plans may wish to bring forward allocations to meet local housing need. However, if the Plan is adopted inclusive of these main modifications any housing development, however needed or appropriate in principle, in any village which has no ‘made’ neighbourhood plan at the time of adoption will be precluded. Such a policy vacuum created on the date of adoption of a Local Plan is unacceptable. Therefore, we OBJECT to MM35 on the basis that it would result in the Plan being unsound on adoption.

Policy MM35 is particularly damaging, denying any growth or new affordable homes in all AONB villages. This will mean more second and retirement homes, less community and family facilities- in fact an ageing demographic as homes become less and less affordable- yet as these villages need essential services and key workers, lanes will be more full of traffic as workers drive in and out from miles away where they can afford to live. It will skew the demographics of the whole JLP area and create fossilised communities and villages. It will also skew housing towards thriving towns- choking them with estates while depriving AONB villages of new homes. I make this point as someone who has worked in South Devon AONB Unit Don't Bury and within the South Devon AONB for over 20 years. I have witnessed at least 10 village shops close, bus services shrivel to community run alternatives; run once a week for elderly 303 1014585 MM35 Trudy Turrell Dartington Under shoppers. I have seen families spending huge amounts of their wages on fuel, because there is no public transport and with cuts in services, a crisis in the provision of care for old and Concrete young. With no new houses at all (apart from brought forward by villages active enough to have a neighbourhood plan), second homes and houses bought by retirees will be even more prevalent. I believe that Salcombe has at least 65% second homes, yet needs local key workers and service employees to survive. Where will they live? I know that Salcombe School has been threatened with closure as have other South Hams village schools. These real social issues should be addressed by the JLP and yet the Modifications have exacerbated the trend. Whilst this plan swamps the ‘thriving towns and villages’ it fossilises the AONB villages. The AONB is not a ‘chocolate box’, a view without people; but a living working landscape. Denying a few new houses to each village will be cutting off its lifeblood and ageing its demographic. The policy is unsustainable and will harm young people and young families.

MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 321 1191000 MM35 Joyce Higgins concentrate new housing in ‘thriving’ villages, such as Dartington. Mrs F H MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 322 1191008 MM35 Williams concentrate new housing in ‘thriving’ villages, such as Dartington. MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 323 1190523 MM35 W Ollis concentrate new housing in ‘thriving’ villages, such as Dartington.

41 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Anthea MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 324 1013363 MM35 Scholefield concentrate new housing in ‘thriving’ villages, such as Dartington. MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 325 1017978 MM35 D Elphick concentrate new housing in ‘thriving’ villages, such as Dartington. Barbara MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 326 1017979 MM35 Henry concentrate new housing in ‘thriving’ villages, such as Dartington. MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 328 1190518 MM35 A Richards concentrate new housing in ‘thriving’ villages, such as Dartington. MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 329 1190522 MM35 Janet Wilce concentrate new housing in ‘thriving’ villages, such as Dartington. MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 330 1190525 MM35 Pam Gorman concentrate new housing in ‘thriving’ villages, such as Dartington.

Mrs Marilyn MM35 Removing housing allocations from AONB villages (Policy MM35), will deprive AONB villages of any new homes, drive up house prices, that will affect young families and further 337 1018842 MM35 H McConnell- concentrate new housing in ‘thriving’ villages, such as Dartington. Bloomberg

Mr Paul BBH Architects 352 1008424 MM35 Please see attached. Myers (Dartmouth) Ltd

Amanda 388 1018467 MM35 Please see attached (Dartington) Chadwick

393 1191638 MM35 Adam Griffin Please see attached (Dartington)

398 1191642 MM35 Angla Hornby Please see attached (Dartington)

Agata 403 1191646 MM35 Please see attached (Dartington) Krajewska Ashley 408 1191654 MM35 Please see attached (Dartington) Parsons

413 1191660 MM35 Andrea Prew Please see attached (Dartington)

Mrs A 419 1191664 MM35 Please see attached (Dartington) Robinson Miss Ali 424 1094187 MM35 Please see attached (Dartington) Roscoe Mr Ashton 429 1114209 MM35 Please see attached (Dartington) Chadwick Cllr Andy 434 1191668 MM35 Please see attached (Dartington) Simms 439 1191677 MM35 A Smaldon Please see attached (Dartington) 444 1191679 MM35 Alan Whele Please see attached (Dartington) 449 1191680 MM35 Mrs Aydin Please see attached (Dartington)

454 1191681 MM35 Barbara Keen Please see attached (Dartington)

459 1191683 MM35 Bree Long Please see attached (Dartington)

464 1191687 MM35 Brian Mascall Please see attached (Dartington)

Carol 469 1191688 MM35 Please see attached (Dartington) Ballenger

42 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Christina 474 1097444 MM35 Please see attached (Dartington) Bennett

479 1191707 MM35 Chris Harding Please see attached (Dartington)

484 1017437 MM35 Clare Hornsey Please see attached (Dartington)

489 1191709 MM35 Mr C Mapsen Please see attached (Dartington)

494 1018458 MM35 Carole Powell Please see attached (Dartington)

499 1191712 MM35 Miss C Watt Please see attached (Dartington) Denis 504 1191715 MM35 Please see attached (Dartington) Anderson

509 1097433 MM35 David Barnett Please see attached (Dartington)

David 514 1097428 MM35 Please see attached (Dartington) Duncombe David 519 1191719 MM35 Please see attached (Dartington) Ferguson

524 1191720 MM35 Donald James Please see attached (Dartington)

Dick 529 1191723 MM35 Please see attached (Dartington) Kassabian 534 1191726 MM35 D Smaldon Please see attached (Dartington) 539 1191729 MM35 David Vitler Please see attached (Dartington) Doirrey 544 1191730 MM35 Please see attached (Dartington) Watterson 549 1191732 MM35 D Young Please see attached (Dartington) Elizabeth 554 1014700 MM35 Please see attached (Dartington) Callaway 559 1191743 MM35 E Ferguson Please see attached (Dartington) Elizabeth 564 1191745 MM35 Please see attached (Dartington) Turner Esther 569 1097402 MM35 Please see attached (Dartington) Watson

574 1017430 MM35 Fiona Bicknell Please see attached (Dartington)

Frances 580 1191752 MM35 Please see attached (Dartington) Brodrick Anne 584 1191751 MM35 Please see attached PDF (Dartington) Woodend 590 1191756 MM35 Colin Bastin Please see attached PDF (Dartington) 594 1191757 MM35 Fiona Tilley Please see attached (Dartington) 599 1191759 MM35 Claire Stoyle Please see attached PDF (Dartington) 604 1191766 MM35 Don Tucker Please see attached (Dartington)

607 1191762 MM35 Graham Black Please see attached (Dartington)

615 1191771 MM35 Ella Baillie Please see attached (Dartington)

618 1191772 MM35 Geoff Caplan Please see attached (Dartington)

43 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 626 1018737 MM35 EA Potter Please see attached (Dartington) Geoffrey 629 1018138 MM35 Please see attached (Dartington) Nickolls

635 1191776 MM35 Graham Prew Please see attached (Dartington)

639 1191777 MM35 Gail Johnson Please see attached (Dartington) Gordon 646 1191780 MM35 Please see attached PDF (Dartington) Woodend Gordon 649 1002916 MM35 Please see attached (Dartington) Riddel Isaac 654 1097358 MM35 Please see attached (Dartington) Bloomberg 658 1018485 MM35 D Hannaford Please see attached (Dartington)

664 1191782 MM35 I Underdown Please see attached (Dartington)

670 1191784 MM35 H Hannaford Please see attached (Dartington)

674 1018187 MM35 J Rich Please see attached (Dartington) 679 1191786 MM35 Lisa Daix Please see attached (Dartington) 684 1191788 MM35 Hon Ashton Please see attached (Dartington) 690 1191790 MM35 L Keel Please see attached (Dartington) 694 1016052 MM35 Heidi Orrell Please see attached (Dartington) Richard and 700 1018437 MM35 Jeanne Please see attached (Dartington) Hughes 706 1191793 MM35 M Cole Please see attached (Dartington) 709 1191795 MM35 Helen Welsh Please see attached (Dartington)

714 1016272 MM35 Isabelle Orrell Please see attached (Dartington)

719 1191800 MM35 Ian Smail Please see attached (Dartington)

724 1191801 MM35 John Callaway Please see attached (Dartington)

Ref: Policy MM35 withdrawing housing allocations from villages in AONB: I object to this for several reasons in addition to that outlined above including: AONB villages require some new homes to enable young families to afford to purchase homes that enable them to stay in their village and ensure that the village community is sustainable. The allocations proposed in the first draft of the plan were as little as 10 new homes and my sense is that these allocations have been reallocated because developers will not make sufficient profits 729 1015453 MM35 Karin Jordan from building 10 homes. My solution is that the villages in the AONB are reallocated up to 10 homes each and that these are designated as self build/community land trust/housing association/shared ownership homes to enable these homes to be built without the need for developers who are looking for larger profit margins.This would allow for small mixed developments within the price range of local people and in keeping with the character of the AONB. Policy MM35 is not positively prepared as it does not achieve unmet need or sustainability. 765 1191814 MM35 T Lang Please see attached (Dartington)

771 1191815 MM35 Joel Chadwick Please see attached (Dartington)

Janice 776 1018151 MM35 Please see attached (Dartington) Duncombe James 781 1097475 MM35 Please see attached (Dartington) Fordham John 786 1191817 MM35 Please see attached (Dartington) Greenhalgh 791 1097375 MM35 Joy Hanson Please see attached (Dartington)

44 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

796 1191818 MM35 Jenny Heaton Please see attached (Dartington)

801 1191819 MM35 Jane Hext Please see attached (Dartington) 806 1191820 MM35 June Hext Please see attached (Dartington) 811 1191821 MM35 J Hodgson Please see attached (Dartington) 815 1191822 MM35 John Lee Please see attached (Dartington) 820 1014649 MM35 J Marshall Please see attached (Dartington) Lesley 826 1191823 MM35 Please see attached (Dartington) Marshall 833 1191824 MM35 Josh Orrell Please see attached (Dartington) Jonathan 836 1191828 MM35 Please see attached (Dartington) Reeves Josephine 841 1013778 MM35 Please see attached (Dartington) Unwin 847 1073274 MM35 Joanna Watt Please see attached (Dartington)

853 1018385 MM35 Jacqui Wilkins Please see attached (Dartington)

Arthur 857 1191829 MM35 Please see attached (Dartington) Durrant 860 1191830 MM35 Kevin Childs Please see attached (Dartington) Katherine 867 1191832 MM35 Please see attached (Dartington) Smaldon 871 1018193 MM35 Alex Sharp Please see attached (Dartington) 876 1191833 MM35 Kevin Weale Please see attached (Dartington)

882 1014279 MM35 Lucia Fausset Please see attached (Dartington)

887 1191834 MM35 Cass Wynne Please see attached (Dartington) 889 1191835 MM35 Lorna James Please see attached (Dartington) 896 1191836 MM35 L Korda Please see attached (Dartington) Mr and Mrs T 901 1191837 MM35 Please see attached (Dartington) Locker 906 1191860 MM35 Michael Cox Please see attached (Dartington)

912 1191861 MM35 Mary Hobden Please see attached (Dartington)

917 1018405 MM35 Mavis Jones Please see attached (Dartington) Dr Malcolm 922 1017707 MM35 Please see attached (Dartington) Purcell 927 1191882 MM35 Mick Wicks Please see attached (Dartington) Mr Nigel 932 1094768 MM35 Please see attached (Dartington) Backhouse Lauryn 936 1191915 MM35 Please see attached (Dartington) Reeves Elizabeth 941 1018413 MM35 Please see attached (Dartington) Williams Matthew 946 1191933 MM35 Please see attached (Dartington) Heming Michael 953 1191935 MM35 Please see attached (Dartington) Brown 955 1191934 MM35 Nigel Hinks Please see attached (Dartington) 963 1017617 MM35 P Douglas Please see attached (Dartington)

45 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Mr Martin 967 1073037 MM35 Please see attached (Dartington) Crawford 973 1191937 MM35 Matt Harvey Please see attached (Dartington)

975 1191936 MM35 Philip R Jones Please see attached (Dartington)

982 1191938 MM35 Pete Reeves Please see attached (Dartington) Rosamund 987 1018175 MM35 Please see attached (Dartington) Bastin Martina 992 1191939 MM35 Please see attached (Dartington) Heming 997 1191943 MM35 Minni Jain Please see attached (Dartington) Ms Mary 1002 1095121 MM35 Please see attached (Dartington) Light Michelle 1007 1191948 MM35 Please see attached (Dartington) McHale

1012 1191949 MM35 Richard Hard Please see attached (Dartington)

Main 1017 1191951 MM35 Please see attached (Dartington) Patterson 1022 1191952 MM35 Rooh Star Please see attached (Dartington) 1027 1191953 MM35 Monika Pike Please see attached (Dartington)

1033 1191954 MM35 Rachel Tucker Please see attached (Dartington)

Marti 1037 1191955 MM35 Please see attached (Dartington) Valentine 1043 1191958 MM35 Mike Welsh Please see attached (Dartington) 1047 1191957 MM35 Sarah Curtis Please see attached (Dartington) 1052 1191961 MM35 Nell Admiral Please see attached (Dartington)

1057 1191963 MM35 Nicholas Keen Please see attached (Dartington)

1062 1191966 MM35 Mr O Clarke Please see attached (Dartington) Oliver 1067 1095333 MM35 Please see attached (Dartington) Tringham 1072 1191968 MM35 T Palm Please see attached (Dartington) 1076 1018745 MM35 Pollie Ash Please see attached (Dartington) Mr Phillip 1082 1094867 MM35 Please see attached (Dartington) Bridge

Philip and 1087 1097512 MM35 Minni Franses Please see attached (Dartington) and Jain

1093 1191972 MM35 Sara Ferguson Please see attached (Dartington)

1097 1095641 MM35 Paul Hornby Please see attached (Dartington) 1103 1191973 MM35 Sandra Hard Please see attached (Dartington) Pamela 1108 1191974 MM35 Please see attached (Dartington) Kassabian SC 1113 1191975 MM35 Please see attached (Dartington) Underdown 1117 1191977 MM35 Sue Wicks Please see attached (Dartington)

46 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 1121 1191978 MM35 T Backhouse Please see attached (Dartington) 1127 1191980 MM35 Tanya Bell Please see attached (Dartington) 1132 1191981 MM35 Tim Grevatt Please see attached (Dartington) 1137 1191979 MM35 Peter Mingo Please see attached (Dartington)

1142 1191982 MM35 Vicky Hadland Please see attached (Dartington)

Patricia 1148 1191983 MM35 Please see attached (Dartington) O'Carroll 1152 1191985 MM35 Vivien Hinks Please see attached (Dartington) 1158 1018364 MM35 R & VM Keel Please see attached (Dartington) Phil 1162 1191986 MM35 Please see attached (Dartington) Sheardown Miss MR 1167 1018574 MM35 Please see attached (Dartington) Brand 1172 1191987 MM35 V J May Please see attached (Dartington) 1177 1191993 MM35 R Orrell Please see attached (Dartington) 1182 1191995 MM35 Richard Pike Please see attached (Dartington)

1187 1191997 MM35 Rosie Roberts Please see attached (Dartington)

1191 1191998 MM35 Roger Shelley Please see attached (Dartington)

Mr & Mrs RH 1197 1018009 MM35 Please see attached (Dartington) Tripp 1203 1191989 MM35 Debbie Feld Please see attached (Dartington) Mr R 1207 1018359 MM35 Please see attached (Dartington) Valentine 1212 1018420 MM35 Janice Bragg Please see attached (Dartington) 1218 1192003 MM35 Susan Boal Please see attached (Dartington)

1222 1192004 MM35 John Chapple Please see attached (Dartington)

1226 1192007 MM35 Jane Parker Please see attached (Dartington) 1232 1017953 MM35 John Platt Please see attached (Dartington) 1238 1192006 MM35 S Carrol Please see attached (Dartington) 1242 1192010 MM35 Lise Platt Please see attached (Dartington) Sandra 1248 1018749 MM35 Please see attached (Dartington) Crawford

1252 1018584 MM35 Marion Baker Please see attached (Dartington)

1257 1192013 MM35 Mike Bridger Please see attached (Dartington)

1263 1018583 MM35 M Green Please see attached (Dartington)

Susan 1267 1018841 MM35 Please see attached (Dartington) Goldsworthy

1273 1018446 MM35 M Lang Please see attached (Dartington) Mrs Susan 1277 1018172 MM35 Please see attached (Dartington) Greenhalgh Margaret 1282 1192017 MM35 Please see attached (Dartington) Lewis

47 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Philomena 1287 1192019 MM35 Please see attached (Dartington) Wynne 1293 1018169 MM35 Sandra Lee Please see attached (Dartington) Mr Roger 1297 1093100 MM35 Please see attached (Dartington) Nicholson Susan 1303 1192021 MM35 Please see attached (Dartington) Nancholas Stephen 1307 1192022 MM35 Please see attached (Dartington) Harper 1312 1192023 MM35 S Niemeyer Please see attached (Dartington) Mrs Sue 1317 1017725 MM35 Please see attached (Dartington) Norris Simon 1322 1192025 MM35 Please see attached (Dartington) Patterson Shimako 1326 1018357 MM35 Please see attached (Dartington) Sharpe

1332 1192027 MM35 Susan Weare Please see attached (Dartington)

Timothy 1337 1192030 MM35 Please see attached (Dartington) Hornsey 1342 1192034 MM35 Wendy Cook Please see attached (Dartington) 1347 1192035 MM35 Wendy Fisk Please see attached (Dartington)

The Highampton Neighbourhood Plan Group is concerned about the Main Modification MM36 and in particular Policy TTV(NEW2). 1 The problem is that it potentially allows unscrupulous developers to sidestep the Neighbourhood Plan provisions and thus invalidate the process. 2 Sustainable Village Neighbourhood Plans are typically set within a rural parish and will draw new built environment boundaries or reinforce existing boundaries within an overall plan or vision for the development of their village. 3 They will also (must also) Highampton take into account the village affordable housing needs and the housing mix needs of the village. 4. They will also be subject to review every 5 years so if the needs change then the Mr Steve 18 1002307 MM36 Neighbourhood Neighbourhood Plan can be amended by the local Neighbourhood Plan Group and Parish Council with the guidance from WDBC. 5 Therefore, there should be no positive need for this Male Planning Group policy and its presence can only undermine the whole Neighbourhood Planning ethos of the JLP for sustainable villages.

This main amendment should not be adopted where there is a sustainable village Neighbourhood Plan. Villages without a Neighbourhood Plan would naturally be subject to such developments so this policy has no effect. Therefore, the main modification should not be approved.

48 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Policy TTV (NEW 2) Meeting local housing needs in rural areas [Rural Exception Sites] Whilst we support rural exception sites as a mechanism for delivering housing developments that meet clearly identified local needs, we do not consider that the location (“adjoining or very near to an existing settlement”) or the percentage of open market housing permitted (up to 40%) should be predetermined in the wording of the policy. More specifically: Re: sites . The location of these sites should depend on local circumstances. A site may be “adjoining or very near” a settlement which has limited, or even no facilities, whilst another site may form part of an existing rural cluster and have reasonable access to a vibrant mixed use centre (Policy SPT2.1). Neighbourhood plans, particularly in AONB parishes, are best placed to decide the location of these rural exception sites based on local circumstances and evidence gathered as part of their neighbourhood planning process. This principle has already been established in the case of AONB Sustainable Villages in the TTV Policy Area. One of the main legal requirements (Basic Conditions) of a neighbourhood plan is to demonstrate that it contributes to the achievement of sustainable development. Re: open market housing up to 40% . This is, in effect, a licence to build in the countryside and is inconsistent with the Framework (Annex 2: Glossary): “ Small numbers of market homes may be allowed at the local authority’s discretion, for example, where essential to enable the delivery of affordable units without grant funding .” Shockingly, there is no specific requirement for an open-book development appraisal to justify any open market housing - let alone up to 40%, which is excessive for the TTV Policy Area (particularly within the South Devon AONB). Rural exception Thurlestone sites are intended to be small-scale sites that are expected to deliver 100% affordable housing and the overriding consideration must be the provision of affordable housing to meet Parish Council proven local need. The failure to require an appraisal is a fundamental flaw that will only serve to exacerbate local housing issues by creating more second homes and skewing the 91 1002318 MM36 Sue Crowther and demographic imbalance even further. An SPD will not suffice. Re: perpetuity . This refers to all the dwellings (affordable and open market) being required to continue to meet identified Neighbourhood need in perpetuity. This is presumably an error and should relate only to the affordable housing Re: other relevant policies . It is entirely unclear how a proposal could meet the Plan requirement of any other relevant policies of the Plan. For example, Policy TTV31 (Development in the Countryside) makes no reference to rural exception sites. There is a reference to Rural Exception Sites and Village Housing Initiative provisions in the supporting text (para 5.163), but this is presumably an oversight. Similarly, it is unclear how a proposal could meet the requirements of Policies DEV8 (Meeting local housing need in the TTV Policy Area) DEV27 (AONBs) and DEV25 (Undeveloped Coast and Heritage Coast). This needs to be clarified.

Suggested additional criteria: Scale and design . Just as individual residential extensions to dwellings are required to be appropriate in scale and design in the context of the setting of the host dwelling [MM37], it would be reasonable to require that all residential development on rural exception sites should be appropriate in scale and design in the context of the surrounding countryside (particularly in the AONBs). Scheme Design . The open market housing should be integrated with the affordable homes to be a single scheme and the architectural design of the open market housing should be indistinguishable from the affordable housing (to accord with criterion 3 of Policy DEV10 (Delivering high quality housing)). Finally, the present supporting text to this policy, which consists of a short paragraph about community-led housing initiatives, does not provide sufficient clarification. Terms such as “proven need”, “perpetuity” and “a mix of affordable and market housing products where necessary to be financially viable” need some basic explanation. This rural exception policy is arguably the single-most important development policy in this Plan for the TTV Policy Area and will have the most far-reaching consequences.

TTV1, TTV31 - We are assured that the term “Countryside” will be sufficient protection for the land running up to Dartmoor. Unfortunately this is unbelievable as it is “countryside” that Miss is being offered up for the development plans. And because of these changes it has an impact on Neighbourhood Plans that are in the final stages of acceptance. Thereby weakening 149 1013602 MM36 Elizabeth their effect. TTV9 - This refers quite specifically to land needing protection up to Dartmoor from Ivybridge. As only part of the Parish of Bickleigh is within the Urban Fringe Boundary Gilmour why is the land outside the boundary not being given the same level of identification and protection? MM36: Policy TTV31 and associated narrative We support the introduction of Policy TTV (NEW2) which in principle reflects the discussions at the hearings in relation to rural housing Emery Wainhomes Mr John exceptions. However we consider that the maximum level of market housing should be increased from 40% to 50%. This would provide a greater degree of flexibility and scope to 213 893384 MM36 Planning (South West) Coxon deliver affordable housing in areas of significant need. Of note the Cornwall Local Plan: Strategic Policies (Policy 9) includes a similar exception policy with an allowance of up to 50% Partnership Holdings Ltd. market housing.

We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment 232 658611 MM36 Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM36 Although not one of our Salmon Agency recommendations we support point 4 of the new TTV policy (horse related developments) requiring protection of watercourses and groundwater.

49 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM36 TTV1 TTV31 The modifications made to TTV31 fail to provide adequate protection for the areas of Bickleigh Parish that lie outside of the Plymouth Policy Area between the area of the proposed New Development and Dartmoor National Park. There can be no dispute that this land is of High Landscape Value. I refer to the 2016 proposal as a STRATEGIC LAND AREA recognising the role of as a Green Buffer Zone between the Plymouth Urban fringe and Dartmoor National Park. I refer you to Plymouth and Plymouth Urban Fringe Landscape Assessment 2016 where there is clear evidence. This proposal received significant local support but was subsequently dropped from the Submission version of the JLP, while other parts of the urban fringe within the Plymouth Policy Area retained the proposed designation. A policy in the Bickliegh Neighbourhood Plan (Bick 03) that sought to replicate the original 2016 approach by designating areas of 'Special Landscape Significance' was deleted by the examiner due to the uncertainty over JLP policy, and it is now too late to seek to reinstate anything similar in the NP which is nearly at referendum. However Following the Examination of the JLP and the Examiners report, proposed modification MM50 removes the proposed designations entirely and replaces them with a new policy (Policy PLY (NEW)) that seeks to provide similar criteria-based protection for countryside areas within the Plymouth Policy Area to that provided by TTV31 for countryside areas elsewhere in the plan area. Therefore, the ‘default’ policies that will be used to determine planning applications within the area under discussion are TTV1 and TTV31. Of these, TTV31 is considered the most relevant. The original Policy TTV31 contains as a first paragraph the following wording: Housing and Cllr Michael employment development adjoining or very near to an existing settlement will only be supported where it meets the essential, small scale local development needs of the community 244 1004109 MM36 Blake and provides a sustainable solution. Modification MM36 removes this paragraph, replacing it with Policy TTV (NEW2). The new policy relates only to residential development and there is no mention of employment or other types of development. Bickleigh Parish Council considers that this modification therefore creates a policy vacuum that leaves areas of countryside around existing settlements vulnerable to inappropriate development. This is particularly relevant for areas surrounding the settlement of Bickleigh due to its location very close to the Plymouth urban area, since these areas are likely to come under increased development pressure following the development of Woolwell. Given the importance of this landscape and the removal of the protection provided by the previously proposed landscape designations in the JLP and the Neighbourhood Plan, this issue is considered to be of the utmost importance not only for the future of Bickleigh Parish, but also for the landscape setting of both the Plymouth urban area and Dartmoor National Park. This modification does not deliver on the Strategic Objectives set out with the JLP, in particular paragraph 8 of Strategic Objective SO6 - Delivering a prosperous and sustainable South West Devon, which reads: Protecting, conserving and enhancing the natural beauty of south west Devon's countryside, protecting the countryside from inappropriate development, and maximising our environmental assets. For the reasons set out above, it is considered that Policy TTV31 incorporating modification MM36 cannot be considered sound. Further comment: The removal of the first paragraph, despite its replacement by a new policy (TTV NEW2), potentially opens the way to uncontrolled development on the edge of existing settlements that is not covered by TTV (NEW2), for example non-residential development. This does not appear to be the purpose of the modification but may be an unintended consequence.

MM36 TTV1 TTV31 As a resident of Bickleigh I feel we have lost the protection that was in MM36 and the new Policy TTV (New2) which creates a vulnerability to areas of countryside Mrs Linda 251 1096832 MM36 surrounding existing settlements such as Bickleigh as its location is so close to the Plymouth Urban area that it will come under pressure for increased development following that of Crowe Woolwell. MM36 TTV1 TTV31 As a resident of Bickleigh I feel we have lost the protection that was in MM36 and the new Policy TTV (New2) which creates a vulnerability to areas of countryside 257 1096834 MM36 Mr M Crowe surrounding existing settlements such as Bickleigh as its location is so close to the Plymouth Urban area that it will come under pressure for increased development following that of Woolwell. Whilst we support the addition of new Policy NEW2, which recognizes the NPPF’s requirement for responsiveness to local circumstances and meeting local housing need in rural areas, the specific target of a maximum of 40% open market housing is too prescriptive. Setting a ‘hard’ upper threshold does not take account of the issue of viability, which can be particularly acute in schemes providing high levels of affordable housing. A more appropriate and positive approach would be a site-specific viability approach, for example requiring Big Tree Richard 290 1191475 MM36 Sam Grant viability assessments for any proposal including more than 40% affordable housing to show the level of open market provision is necessary to support the provision of the affordable Planning Ltd Sanderson units. This would allow more schemes to come forward in the areas where affordable housing is most required and to stimulate provision rather than preventing it. Therefore, we request that the proposed modification be AMENDED to allow for a higher level of open market housing on sites in rural areas where they are required for the overall viability of a scheme.

I know it is very late in the day but I would like to point out something which should be considered in relation to policy TTV1 (para 5.10) and TTV31. For instance, some villages listed in paragarph 5.10 of TTV31 do not comply with policy SPT2 para 3.17 fig 3.2. In relation to shops especially (Halwell, Moreleigh and many more). Besides, the sustainability reason involving shops is hardly relevant with home delivery TTV31 does not take into account infill sites between buildings in built up areas which are not included in the villages in paragraph 5.10. This is a too arbitrary approach. A paragraph should be inserted at TTV31 paragraph 2 sub para v which states: Small infill sites for one or two houses between residential 293 1190381 MM36 Sam Balsdon developments in villages or hamlets outside those contained in paragraph 5.10 may be considered suitable for development providing (and here you can list the requirement for a Land and Visual Impact Assessment etc) There are probably many suitable sites that fall into this category. As the South Hams gets ever more popular with people relocating, new modern homes in the countryside are still needed. Land should be used effectively and if a plot is eminently suitable for development but the location fails outside the sustainability 'test' then it should still be considered providing all other matters are complied with. As it stands, the policies above will prevent suitable plots being undeveloped. It may be too late but that's it.

50 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Don't Bury TTV (NEW2) Meeting Housing Needs in Rural Areas- seems to imply that extending housing on to existing villages and towns will be allowed. This could create urban sprawl- especially 302 1014585 MM36 Trudy Turrell Dartington Under as all allocations are taken now from all AONB villages in Policy MM35. Concrete

TTV NEW 2 The removal of the first paragraph, despite its replacement by a new policy (TTV NEW2), potentially opens the way to uncontrolled development on the edge of existing settlements that is not covered by TTV (NEW2), for example non-residential development. This does not appear to be the purpose of the modification but may be an unintended consequence. MM36 Bickleigh Parish Council is concerned that the modifications made to Policy TTV31 do not provide adequate protection for that area of Bickleigh Parish that lies outside the Plymouth Policy Area between the proposed new development at Woolwell, and Dartmoor National Park. This area of land is of high landscape value and in 2016 was proposed as a ‘Strategic Land Area’ in recognition of its role as a green buffer between the Plymouth urban fringe and Dartmoor National Park (as evidenced in the Plymouth and Plymouth Urban Fringe Landscape and Seascape Assessment, 2016 ). This proposal received significant local support but was subsequently dropped from the Submission version of the JLP, while other parts of the urban fringe within the Plymouth Policy Area retained the proposed designation. A policy in the Bickleigh Neighbourhood Plan (Bick 03) that sought to replicate the original 2016 approach by designating areas of 'Special Landscape Significance' was deleted by the examiner due to the uncertainty over JLP policy, and it is now too late to seek to reinstate anything similar in the NP which is nearly at referendum. Following the Examination of the JLP and the Examiners report, proposed modification MM50 removes the proposed designations entirely and replaces them with a new policy (Policy PLY (NEW)) that seeks to provide similar criteria-based protection for countryside areas within the Plymouth Steve Policy Area to that provided by TTV31 for countryside areas elsewhere in the plan area. Therefore, the ‘default’ policies that will be used to determine planning applications within the Bickleigh Parish 319 1007783 MM36 Clement- area under discussion are TTV1 and TTV31. Of these, TTV31 is considered the most relevant. The original Policy TTV31 contains as a first paragraph the following wording: Housing and Council Large employment development adjoining or very near to an existing settlement will only be supported where it meets the essential, small scale local development needs of the community and provides a sustainable solution. Modification MM36 removes this paragraph, replacing it with Policy TTV (NEW2). The new policy relates only to residential development and there is no mention of employment or other types of development. Bickleigh Parish Council considers that this modification therefore creates a policy vacuum that leaves areas of countryside around existing settlements vulnerable to inappropriate development. This is particularly relevant for areas surrounding the settlement of Bickleigh due to its location very close to the Plymouth urban area, since these areas are likely to come under increased development pressure following the development of Woolwell. Given the importance of this landscape and the removal of the protection provided by the previously proposed landscape designations in the JLP and the Neighbourhood Plan, this issue is considered to be of the utmost importance not only for the future of Bickleigh Parish, but also for the landscape setting of both the Plymouth urban area and Dartmoor National Park. In the Parish Council’s view, this modification does not deliver on the Strategic Objectives set out with the JLP, in particular paragraph 8 of Strategic Objective SO6 - Delivering a prosperous and sustainable South West Devon, which reads: Protecting, conserving and enhancing the natural beauty of south west Devon's countryside, protecting the countryside from inappropriate development, and maximising our environmental assets. For the reasons set out above, it is considered that Policy TTV31 incorporating modification MM36 cannot be considered sound.

Ms Victoria SUPPORT. I support the changes to TTV31. SUPPORT the inclusion of TTV(NEW2) Meeting housing need in rural areas. SUPPORT the inclusion of TTV(NEW3) Horse related 374 1095125 MM36 Tanner- development in the countryside. Tremaine

Policy TTV (NEW2) - Meeting local housing needs in rural areas [MM36] Setting a clear policy stipulating the circumstances in which such development will be acceptable adjacent to South West HARP existing settlement boundaries will assist in the delivery of such housing, boosting the opportunities to meet needs. We therefore support the inclusion of such a policy. We are of the Annie Tetlow King 747 864196 MM36 Planning view that enabling sustainable development adjacent to settlement boundaries, is the most appropriate approach to settlement boundaries. This approach recognises that settlement Gingell Planning Consortium boundaries should be used as a guide for development rather than an absolute barrier to those proposals that would meet needs, particularly for affordable housing. As a result, a policy of this nature will increase options for affordable housing development across the Authorities in areas that are in most need.

Thurlestone Parish Council Policy TTV32 Residential extensions and replacement dwellings in the countryside We support this new point that residential extensions in the countryside should be appropriate in 92 1002318 MM37 Sue Crowther and scale and design in the context of the setting of the host dwelling, which provides helpful clarification. Neighbourhood Plan Ms Victoria 375 1095125 MM37 Tanner- SUPPORT. I support the modifications requiring extensions to be appropriate in scale and design and the context of the setting of the host dwelling. Tremaine Ms Victoria 376 1095125 MM38 Tanner- SUPPORT with reservations. Disappointed to see that the suggested inclusion of light pollution has not been included in the modifications. Tremaine

51 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Dear Strategic Planners, I am writing to voice my opposition to the Joint Local Plan. I understand that planning inspectors have allocated 504 houses in Dartington and almost another 500 in Totnes. It is unfair and unsustainable, to grow our village by 63% in 20 years. It will damage our countryside, rural character and choke our roads. I object to the development of 98 1190458 MM39 Nisha Toppin the green fields of Broom Park and Sawmills West. In particular I object to the modifications that have been proposed to the Plan - I am concerned about policies which: 3. Ignore the increase in air pollution that 1000 houses in Dartington and Totnes will create (1000 houses could mean 2000 more cars including deliveries etc). The A385 corridor already regularly breaks World Health Organisation safety levels for air quality. We are breathing toxic air as bad as that in any city.

MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 103 1018487 MM39 Gill Gairdner Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 108 1018748 MM39 Hazel Fuller Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. Anthea MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 112 1013363 MM39 Scholefield Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 116 1017978 MM39 D Elphick Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. Barbara MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 120 1017979 MM39 Henry Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 124 1190518 MM39 A Richards Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. Miss Rosa MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 128 1013608 MM39 Bloomberg Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. McConnell- MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 132 1190520 MM39 Bloomberg Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 136 1190522 MM39 Janet Wilce Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 140 1190523 MM39 W Ollis Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 144 1190525 MM39 Pam Gorman Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 175 1191000 MM39 Joyce Higgins Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. Mrs F H MM39 Air Quality in AQMAs. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 179 1191008 MM39 Williams Dartington and Totnes, where World Health Organisation limits are already breached on a daily basis, will adversely affect people’s health. MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 186 1191016 MM39 Pippa Palmer Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. Paignton Mr David 223 1094326 MM39 Neighbourhood The Forum supports the proposals as published and in particular those of MM39. Watts Plan Forum We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment 233 658611 MM39 Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM39 Whilst not our recommendation we Salmon Agency support the various changes to DEV2 in respect of air, water, soil, noise, land and light.

52 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Air Quality. Focussing so much development on South Hams ‘thriving towns and villages’ acts to funnel traffic through many areas now declared AQMA’s for poor air quality. No account seems to have been taken for the ‘in combination’ effects of building so many houses in small areas centred around AQMA road areas- they are often the only roads in and out and the only routes to the A38 for commuting to work in Plymouth and Exeter. Building almost 1000 new homes in Dartington and Totnes is the worst example of this. In areas already challenged by pollution, and in Totnes and Dartington, where WHO limits are breached daily, it is incontrovertible that building more new houses in parishes that have already experienced massive increases in the last 10 years, will cause traffic and unacceptable pollution, with clear hazards to human health. Policy MM39 AQMA (Air quality) Appears a Don't Bury welcome policy, but is weak. It should include the ‘in combination’ effects of developments upon roads and air quality. Para 6.9 -The ‘appropriately considered’ terms are ineffectual 304 1014585 MM39 Trudy Turrell Dartington Under and weak and a loophole to allow development that may directly and indirectly lead to declining air quality and more breaches of WHO levels of safety. I suggest it should read Concrete ‘development in AQMA’s must not reduce air quality in any way in AQMA areas, it should seek to improve it’ Air Quality Action Plans and transport programmes implemented after allowing thousands of new housing clustered around or generating traffic to funnel through AQMA areas makes ‘avoiding unacceptable impacts’ to air quality untenable. It is shutting the gate after the horse has bolted. Again ‘acceptable’ has no defined measure. I suggest it should read ‘should not result in the breach of World Health Organisation limits for air quality’. This policy is vital and needs to safeguard health from road pollution and improve air quality in AQMA areas by preventing further developments there and feeding into AQMA road area. It conflicts directly with policies to focus development around many thriving towns and villages, especially allocating around 1000 new houses in Totnes and Dartington and the revised Housing Topic paper’s allowance for 2077 surplus houses.

Ms Victoria SUPPORT with reservations. I support the modifications except for the deletion of 'or mitigate' in point 1 as this is the an important part of the mitigation hierarchy. The modifications 377 1095125 MM39 Tanner- do not address the fact that light pollution can be avoided, rather than merely 'limited'. Avoidance is first in the mitigation hierarchy, then minimising/limiting. Light pollution is one of Tremaine the most easily avoidable forms of pollution. Amanda 390 1018467 MM39 Please see attached (Dartington) Chadwick

395 1191638 MM39 Adam Griffin Please see attached (Dartington)

400 1191642 MM39 Angla Hornby Please see attached (Dartington)

Agata 405 1191646 MM39 Please see attached (Dartington) Krajewska Ashley 410 1191654 MM39 Please see attached (Dartington) Parsons

415 1191660 MM39 Andrea Prew Please see attached (Dartington)

Mrs A 420 1191664 MM39 Please see attached (Dartington) Robinson Miss Ali 425 1094187 MM39 Please see attached (Dartington) Roscoe Mr Ashton 430 1114209 MM39 Please see attached (Dartington) Chadwick Cllr Andy 435 1191668 MM39 Please see attached (Dartington) Simms 440 1191677 MM39 A Smaldon Please see attached (Dartington) 445 1191679 MM39 Alan Whele Please see attached (Dartington) 450 1191680 MM39 Mrs Aydin Please see attached (Dartington)

455 1191681 MM39 Barbara Keen Please see attached (Dartington)

460 1191683 MM39 Bree Long Please see attached (Dartington)

465 1191687 MM39 Brian Mascall Please see attached (Dartington)

Carol 470 1191688 MM39 Please see attached (Dartington) Ballenger Christina 475 1097444 MM39 Please see attached (Dartington) Bennett

53 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

480 1191707 MM39 Chris Harding Please see attached (Dartington)

485 1017437 MM39 Clare Hornsey Please see attached (Dartington)

490 1191709 MM39 Mr C Mapsen Please see attached (Dartington)

495 1018458 MM39 Carole Powell Please see attached (Dartington)

500 1191712 MM39 Miss C Watt Please see attached (Dartington) Denis 505 1191715 MM39 Please see attached (Dartington) Anderson

510 1097433 MM39 David Barnett Please see attached (Dartington)

David 515 1097428 MM39 Please see attached (Dartington) Duncombe David 520 1191719 MM39 Please see attached (Dartington) Ferguson

525 1191720 MM39 Donald James Please see attached (Dartington)

Dick 530 1191723 MM39 Please see attached (Dartington) Kassabian 535 1191726 MM39 D Smaldon Please see attached (Dartington) 540 1191729 MM39 David Vitler Please see attached (Dartington) Doirrey 545 1191730 MM39 Please see attached (Dartington) Watterson 550 1191732 MM39 D Young Please see attached (Dartington) Elizabeth 555 1014700 MM39 Please see attached (Dartington) Callaway 560 1191743 MM39 E Ferguson Please see attached (Dartington) Elizabeth 565 1191745 MM39 Please see attached (Dartington) Turner Esther 570 1097402 MM39 Please see attached (Dartington) Watson

575 1017430 MM39 Fiona Bicknell Please see attached (Dartington)

Frances 581 1191752 MM39 Please see attached (Dartington) Brodrick Anne 585 1191751 MM39 Please see attached PDF (Dartington) Woodend 591 1191756 MM39 Colin Bastin Please see attached PDF (Dartington) 596 1191757 MM39 Fiona Tilley Please see attached (Dartington) 600 1191759 MM39 Claire Stoyle Please see attached PDF (Dartington) 608 1191766 MM39 Don Tucker Please see attached (Dartington)

610 1191762 MM39 Graham Black Please see attached (Dartington)

616 1191771 MM39 Ella Baillie Please see attached (Dartington)

620 1191772 MM39 Geoff Caplan Please see attached (Dartington)

627 1018737 MM39 EA Potter Please see attached (Dartington)

54 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Geoffrey 630 1018138 MM39 Please see attached (Dartington) Nickolls

636 1191776 MM39 Graham Prew Please see attached (Dartington)

640 1191777 MM39 Gail Johnson Please see attached (Dartington) Gordon 647 1191780 MM39 Please see attached PDF (Dartington) Woodend Gordon 650 1002916 MM39 Please see attached (Dartington) Riddel Isaac 655 1097358 MM39 Please see attached (Dartington) Bloomberg 661 1018485 MM39 D Hannaford Please see attached (Dartington)

666 1191782 MM39 I Underdown Please see attached (Dartington)

671 1191784 MM39 H Hannaford Please see attached (Dartington)

676 1018187 MM39 J Rich Please see attached (Dartington) 680 1191786 MM39 Lisa Daix Please see attached (Dartington) 685 1191788 MM39 Hon Ashton Please see attached (Dartington) 691 1191790 MM39 L Keel Please see attached (Dartington) 696 1016052 MM39 Heidi Orrell Please see attached (Dartington) Richard and 701 1018437 MM39 Jeanne Please see attached (Dartington) Hughes 705 1191793 MM39 M Cole Please see attached (Dartington) 710 1191795 MM39 Helen Welsh Please see attached (Dartington)

715 1016272 MM39 Isabelle Orrell Please see attached (Dartington)

720 1191800 MM39 Ian Smail Please see attached (Dartington)

725 1191801 MM39 John Callaway Please see attached (Dartington)

Ref: MM39 Air Quality in AQMA’s.This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new 727 1015453 MM39 Karin Jordan houses in Dartington village and Totnes, where World Health Organisation limits are breached daily, will adversely affect people’s health and there are no signs that any reduction in unsafe levels of toxins has been achieved since the A385 was designated an AQMA on 13 July 2009. The MM39 is inconsistent with national policy.

MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 733 1191806 MM39 Ros Durston Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. As far as we are concerned that if the planning authority approves planning applications in this area that it knows will increase traffic pollution, this will as far we are concerned seriously interfere with our rights under Article 8 of the 737 1095210 MM39 Barry Reeves European Convention on Human Rights that provides a right to respect for one's private and family life . As all planners now know there is a ton of incontrovertible evidence which clearly shows the serious long term impact on human health of traffic pollution and this would materially affect our family life, particularly that of our children whose long term health would be affected by traffic pollution. If traffic pollution were to increase as a result of a deliberate planning decision that knowingly and deliberately ignored the pollution consequences, we would certainly mount a class action against the planners.

55 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. As far as we are concerned that if the planning authority approves planning applications in this area that it knows will increase traffic pollution, this will as far we are concerned seriously interfere with our rights under Article 8 of the 741 1191810 MM39 Anita Cole European Convention on Human Rights that provides a right to respect for one's private and family life . As all planners now know there is a ton of incontrovertible evidence which clearly shows the serious long term impact on human health of traffic pollution and this would materially affect our family life, particularly that of our children whose long term health would be affected by traffic pollution. If traffic pollution were to increase as a result of a deliberate planning decision that knowingly and deliberately ignored the pollution consequences, we would certainly mount a class action against the planners. MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 744 1017703 MM39 Helen Tune Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. Miss Selena MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 751 1094766 MM39 Mara Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. MM39 Air Quality in AQMA’s. This policy is weak and should include the ‘in combination’ effects of developments that generate increased traffic. Allocating around 1000 new houses in 757 1014631 MM39 Josh Zatz Dartington and Totnes, where World Health Organisation limits are breached daily will adversely affect people’s health. MM39 Air Quality in AQMA’s: This policy is weak and should include the combined effects of developments that generate increased traffic. Allocating around 1000 new houses in 761 1095118 MM39 Sharon Ellis Dartington and Totnes, where World Health Organisation limits on air pollution are breached daily, will adversely affect people’s health. 767 1191814 MM39 T Lang Please see attached (Dartington)

772 1191815 MM39 Joel Chadwick Please see attached (Dartington)

Janice 777 1018151 MM39 Please see attached (Dartington) Duncombe James 782 1097475 MM39 Please see attached (Dartington) Fordham John 787 1191817 MM39 Please see attached (Dartington) Greenhalgh 792 1097375 MM39 Joy Hanson Please see attached (Dartington)

797 1191818 MM39 Jenny Heaton Please see attached (Dartington)

802 1191819 MM39 Jane Hext Please see attached (Dartington) 807 1191820 MM39 June Hext Please see attached (Dartington) 812 1191821 MM39 J Hodgson Please see attached (Dartington) 817 1191822 MM39 John Lee Please see attached (Dartington) 822 1014649 MM39 J Marshall Please see attached (Dartington) Lesley 827 1191823 MM39 Please see attached (Dartington) Marshall 831 1191824 MM39 Josh Orrell Please see attached (Dartington) Jonathan 837 1191828 MM39 Please see attached (Dartington) Reeves Josephine 842 1013778 MM39 Please see attached (Dartington) Unwin 848 1073274 MM39 Joanna Watt Please see attached (Dartington)

856 1018385 MM39 Jacqui Wilkins Please see attached (Dartington)

Arthur 858 1191829 MM39 Please see attached (Dartington) Durrant 862 1191830 MM39 Kevin Childs Please see attached (Dartington) Katherine 868 1191832 MM39 Please see attached (Dartington) Smaldon 872 1018193 MM39 Alex Sharp Please see attached (Dartington) 878 1191833 MM39 Kevin Weale Please see attached (Dartington)

56 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

883 1014279 MM39 Lucia Fausset Please see attached (Dartington)

890 1191835 MM39 Lorna James Please see attached (Dartington) 892 1191834 MM39 Cass Wynne Please see attached (Dartington) 897 1191836 MM39 L Korda Please see attached (Dartington) Mr and Mrs T 902 1191837 MM39 Please see attached (Dartington) Locker 907 1191860 MM39 Michael Cox Please see attached (Dartington)

913 1191861 MM39 Mary Hobden Please see attached (Dartington)

919 1018405 MM39 Mavis Jones Please see attached (Dartington) Dr Malcolm 923 1017707 MM39 Please see attached (Dartington) Purcell 928 1191882 MM39 Mick Wicks Please see attached (Dartington) Mr Nigel 931 1094768 MM39 Please see attached (Dartington) Backhouse Lauryn 937 1191915 MM39 Please see attached (Dartington) Reeves Elizabeth 942 1018413 MM39 Please see attached (Dartington) Williams Matthew 947 1191933 MM39 Please see attached (Dartington) Heming Michael 956 1191935 MM39 Please see attached (Dartington) Brown 958 1191934 MM39 Nigel Hinks Please see attached (Dartington) 964 1017617 MM39 P Douglas Please see attached (Dartington) Mr Martin 968 1073037 MM39 Please see attached (Dartington) Crawford

976 1191936 MM39 Philip R Jones Please see attached (Dartington)

978 1191937 MM39 Matt Harvey Please see attached (Dartington) 983 1191938 MM39 Pete Reeves Please see attached (Dartington) Rosamund 988 1018175 MM39 Please see attached (Dartington) Bastin Martina 993 1191939 MM39 Please see attached (Dartington) Heming 998 1191943 MM39 Minni Jain Please see attached (Dartington) Ms Mary 1003 1095121 MM39 Please see attached (Dartington) Light Michelle 1008 1191948 MM39 Please see attached (Dartington) McHale

1013 1191949 MM39 Richard Hard Please see attached (Dartington)

Main 1019 1191951 MM39 Please see attached (Dartington) Patterson 1023 1191952 MM39 Rooh Star Please see attached (Dartington) 1028 1191953 MM39 Monika Pike Please see attached (Dartington)

1034 1191954 MM39 Rachel Tucker Please see attached (Dartington)

57 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Marti 1038 1191955 MM39 Please see attached (Dartington) Valentine 1044 1191958 MM39 Mike Welsh Please see attached (Dartington) 1048 1191957 MM39 Sarah Curtis Please see attached (Dartington) 1053 1191961 MM39 Nell Admiral Please see attached (Dartington)

1058 1191963 MM39 Nicholas Keen Please see attached (Dartington)

1063 1191966 MM39 Mr O Clarke Please see attached (Dartington) Oliver 1068 1095333 MM39 Please see attached (Dartington) Tringham 1073 1191968 MM39 T Palm Please see attached (Dartington) 1078 1018745 MM39 Pollie Ash Please see attached (Dartington) Mr Phillip 1083 1094867 MM39 Please see attached (Dartington) Bridge

Philip and 1088 1097512 MM39 Minni Franses Please see attached (Dartington) and Jain

1094 1191972 MM39 Sara Ferguson Please see attached (Dartington)

1098 1095641 MM39 Paul Hornby Please see attached (Dartington) 1104 1191973 MM39 Sandra Hard Please see attached (Dartington) Pamela 1109 1191974 MM39 Please see attached (Dartington) Kassabian SC 1112 1191975 MM39 Please see attached (Dartington) Underdown 1118 1191977 MM39 Sue Wicks Please see attached (Dartington) 1123 1191978 MM39 T Backhouse Please see attached (Dartington) 1128 1191980 MM39 Tanya Bell Please see attached (Dartington) 1134 1191981 MM39 Tim Grevatt Please see attached (Dartington) 1138 1191979 MM39 Peter Mingo Please see attached (Dartington)

1143 1191982 MM39 Vicky Hadland Please see attached (Dartington)

Patricia 1149 1191983 MM39 Please see attached (Dartington) O'Carroll 1153 1191985 MM39 Vivien Hinks Please see attached (Dartington) 1159 1018364 MM39 R & VM Keel Please see attached (Dartington) Phil 1163 1191986 MM39 Please see attached (Dartington) Sheardown Miss MR 1169 1018574 MM39 Please see attached (Dartington) Brand 1173 1191987 MM39 V J May Please see attached (Dartington) 1178 1191993 MM39 R Orrell Please see attached (Dartington) 1183 1191995 MM39 Richard Pike Please see attached (Dartington)

1189 1191997 MM39 Rosie Roberts Please see attached (Dartington)

1193 1191998 MM39 Roger Shelley Please see attached (Dartington)

Mr & Mrs RH 1198 1018009 MM39 Please see attached (Dartington) Tripp

58 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 1204 1191989 MM39 Debbie Feld Please see attached (Dartington) Mr R 1209 1018359 MM39 Please see attached (Dartington) Valentine 1213 1018420 MM39 Janice Bragg Please see attached (Dartington) 1219 1192003 MM39 Susan Boal Please see attached (Dartington)

1223 1192004 MM39 John Chapple Please see attached (Dartington)

1228 1192007 MM39 Jane Parker Please see attached (Dartington) 1233 1017953 MM39 John Platt Please see attached (Dartington) 1239 1192006 MM39 S Carrol Please see attached (Dartington) 1243 1192010 MM39 Lise Platt Please see attached (Dartington) Sandra 1249 1018749 MM39 Please see attached (Dartington) Crawford

1253 1018584 MM39 Marion Baker Please see attached (Dartington)

1258 1192013 MM39 Mike Bridger Please see attached (Dartington)

1264 1018583 MM39 M Green Please see attached (Dartington)

Susan 1268 1018841 MM39 Please see attached (Dartington) Goldsworthy

1274 1018446 MM39 M Lang Please see attached (Dartington) Mrs Susan 1278 1018172 MM39 Please see attached (Dartington) Greenhalgh Margaret 1283 1192017 MM39 Please see attached (Dartington) Lewis Philomena 1288 1192019 MM39 Please see attached (Dartington) Wynne 1294 1018169 MM39 Sandra Lee Please see attached (Dartington) Mr Roger 1298 1093100 MM39 Please see attached (Dartington) Nicholson Susan 1304 1192021 MM39 Please see attached (Dartington) Nancholas Stephen 1308 1192022 MM39 Please see attached (Dartington) Harper 1313 1192023 MM39 S Niemeyer Please see attached (Dartington) Mrs Sue 1318 1017725 MM39 Please see attached (Dartington) Norris Simon 1323 1192025 MM39 Please see attached (Dartington) Patterson Shimako 1328 1018357 MM39 Please see attached (Dartington) Sharpe

1333 1192027 MM39 Susan Weare Please see attached (Dartington)

Timothy 1338 1192030 MM39 Please see attached (Dartington) Hornsey 1343 1192034 MM39 Wendy Cook Please see attached (Dartington) 1348 1192035 MM39 Wendy Fisk Please see attached (Dartington)

59 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Rockspring Mr Alistair Boyer 335 1191547 MM40 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd

Policy DEV7 - Meeting local housing need in the Plymouth Policy Area [MM40] Point 2 of Policy DEV7 indicates that on sites between 11 and 14 dwellings an off-site affordable housing provision will be required. We are concerned with why an off-site requirement has been applied in the first instance when this this policy approach is not supported by the 2017 Local Plan Viability Study. Smaller sites often form a considerable proportion of windfall delivery and as a result can significantly increase affordable housing delivery. This is due to the fact that these types of sites generally take less time to be build out and consequently will be available to the market sooner than provision on larger schemes. By recommending an off-site South West HARP contribution in the first instance, the policy is likely to have a negative impact on much needed affordable housing delivery. The Local Plan should seek to drive change across the joint Annie Tetlow King 748 864196 MM40 Planning plan area through a pragmatic and ambitious approach to affordable housing, encouraging greater diversity to meet all needs. We strongly encourage the Council to set ambitious Gingell Planning Consortium targets for affordable housing as a mechanism to significantly increase delivery and improve affordability across the joint plan area. For the policy to operate as intended we recommend the following amendments: "2. For developments of above ten homes, at least 30 per cent of the total number of dwellings should be affordable homes without public subsidy, subject to viability. These homes should be provided on-site, except in the cases of sites of between 11 and 14 or dwellings or where robustly justified. In such circumstances the requirement can be met by providing an off-site contribution provision or commuted payments in lieu of on-site provision to deliver affordable housing elsewhere in the policy area. "

The proposed modification to Policy DEV8 to remove the reference to additional planning obligations for single dwellings in high value areas is supported. This proposed policy was not considered to be in accordance with National Policy, and nor was it justified. The addition of a reference to the policy option for commuted payments is also supported. However, the policy wording of DEV8 is still not considered to be fully compliant with the NPPF in respect of obligations being subject to viability, as set out and established by policy DEL1 and the modification to this [AM176]. Therefore, it is considered that the policy wording of DEV8 should be clarified as such, suggestion as follows: 2. …. at least 30 per cent of the total number Jonathan Premier Marinas 5 1096244 MM41 CBRE Ltd of dwellings in the scheme subject to viability considerations as per Policy DEL1 . 3. …. at least 30 per cent on-site affordable housing will be sought for all schemes of 11 or more Stoddart (Dart) Limited dwellings subject to viability considerations as per Policy DEL1 . Off-site provision or commuted payments in lieu of on-site provision will only be allowed where robustly justified, and be subject to viability considerations as per Policy DEL1. The Planning Practice Guidance also sets out that ‘ L o c al authorities should ensure that the c ombined total impact of such requests does not threaten the viability of the sites and scale of development identified in the development plan.’ (Paragraph: 002 Reference ID: 23b-002-20140306). As such, Policy DEV8 would not currently pass the soundness test and should therefore be revised to bring it in accordance with National Planning Policy.

Emphasis needs to be placed on redressing an existing housing imbalance in Okehampton and the surrounding area. Mrs Emma Okehampton 79 1187545 MM41 James Town Council There is a need for additional social and affordable housing in the town by the identification and utilisation of brownfield sites, ensuring the housing targets meeting the needs of younger people, working families and other groups. Ms Victoria 378 1095125 MM41 Tanner- SUPPORT with reservations. The glossary should include Heritage Coast within the rural areas with special designations Tremaine Miss DEV13 - This states ..”…scale of development should not dominate the nearest settled community and should avoid placing undue pressure on the local infrastructure” The 150 1013602 MM42 Elizabeth development plan at Woolwell totally overloads the environment of the Parish as well as the A386 and all its travelling users. Gilmour MM42 DEV13 This states ..”…scale of development should not dominate the nearest settled community and should avoid placing undue pressure on the local infrastructure” The Cllr Michael 238 1004109 MM42 development plan at Woolwell totally overloads the environment of the Parish as well as the A386 and all its travelling users. It will be impossible to avoid placing undue pressure on Blake the Local Infrastructure Mrs Linda MM42 DEV13 It states "scale of development should not dominate the nearest settlement and should avoid placing undue pressure on the local infrastructure" The pressure is 250 1096832 MM42 Crowe already there when they do there daily commute. MM42 DEV13 It states "scale of development should not dominate the nearest settlement and should avoid placing undue pressure on the local infrastructure" The pressure is 256 1096834 MM42 Mr M Crowe already there when they do there daily commute. Steve MM42 DEV 13 This states, ”…scale of development should not dominate the nearest settled community and should avoid placing undue pressure on the local infrastructure” The Bickleigh Parish 317 1007783 MM42 Clement- development plan at Woolwell totally overloads the environment of the Parish as well as the A386 and all its travelling users. It will be impossible to avoid placing undue pressure on Council Large the Local Infrastructure The proposed modificat i ons in the Tracked changes version of the JLP document differ from those in the Schedule of Main Modifications document . The Schedule of Main Ms Victoria Modifications document states: "New sites should not be located i n the open countryside away from near to existing settlements, with a..." The tracked changes version states: "New 379 1095125 MM42 Tanner- sites should not be located in the open countryside away from near to existing settlements ,with a..." As you can see they are contradictory in meaning. I SUPPORT the modifications Tremaine as set out in the Schedule of Main Modifications.

60 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) MM46 – in the draft Policy (DEV20) at paragraph 4. reference is made to delivering ‘locally distinctive design’ . We are concerned that his part of the draft Policy, as modified, may be misinterpreted as requiring development to follow existing patterns and character/design of development at all costs. There are situations where it is appropriate to introduce Jillings Heynes Diocese of development that has adopted a contemporary design approach. This may be acceptable providing it follows accepted design principles. Further, it is not always the case that 195 964187 MM46 Ed Heynes Planning Ltd Plymouth development should be ‘distinctive’. Again, the use of the term suggests that it should stand out but in the majority of cases it should actually blend in with the existing built and natural environment. That being the case then the Council should not prevent it from taking place. It would be more acceptable in our view to introduce the words ‘ Delivering high quality development which has been designed such that it is appropriate for its location’; MM46 – in the draft Policy (DEV20) at paragraph 4. reference is made to delivering ‘locally distinctive design’. We are concerned that this part of the draft Policy may be misinterpreted as requiring development to follow existing patterns and character/design of development at all costs. There are situations where it is appropriate to introduce development that has Mr/Mrs Jillings Heynes adopted a contemporary design approach. This may be acceptable providing it follows accepted design principles. Further, it is not always the case that development should be 200 1095768 MM46 Ed Heynes David/Jane Planning Ltd ‘distinctive’. Again, the use of the term suggests that it should stand out but in the majority of cases it should actually blend in with the existing built and natural environment. That Stratton being the case then the Councils should not prevent it from taking place. It would be more acceptable in our view to introduce the words ‘ Delivering high quality development which has been designed such that it is appropriate for its location’. MM46 – in the draft Policy (DEV20) at paragraph 4. reference is made to delivering ‘locally distinctive design’. We are concerned that this part of the draft Policy may be misinterpreted as requiring development to follow existing patterns and character/design of development at all costs. There are situations where it is appropriate to introduce development that has Mr/Mrs Jillings Heynes adopted a contemporary design approach. This may be acceptable providing it follows accepted design principles. Further, it is not always the case that development should be 203 964051 MM46 Ed Heynes Richard/Barb Planning Ltd ‘distinctive’. Again, the use of the term suggests that it should stand out but in the majority of cases it should actually blend in with the existing built and natural environment. That ara Bennett being the case then the Councils should not prevent it from taking place. It would be more acceptable in our view to introduce the words ‘ Delivering high quality development which has been designed such that it is appropriate for its location’. Ms Victoria SUPPORT with reservations. The proposed change I suggested to include biodiversity in the list of assets to retain has not been included in the modifications to point 2. But I fully 380 1095125 MM46 Tanner- support the addition of landscape to this list. And support the changed wording regarding locally distinctive design in point 4. Tremaine Thurlestone Parish Council SPT (NEW) – Formerly DEV21. Strategic approach to the historic environment We strongly support prioritising the historic environment, since heritage makes a vital contribution to 94 1002318 MM47 Sue Crowther and local distinctiveness and a community’s sense of place, wellbeing and cultural identity. This is particularly important in areas, such as our own, where the LPA has no Local Listing of Neighbourhood Heritage Assets for non-designated heritage assets. Plan Ms Victoria 381 1095125 MM47 Tanner- SUPPORT the relocation of this policy to the strategic section of the plan. Tremaine Thurlestone Parish Council DEV22 Development affecting the historic environment We support this modification, in particular, the new point dealing with the protection of locally important non-designated 95 1002318 MM48 Sue Crowther and heritage assets. This is important in areas, such as our own, where the LPA has no Local Listing of Heritage Assets for non-designated heritage assets. Neighbourhood Plan

MM48 – we note the content of the Proposed Modification. It is vital that the changes reflect the objectives of the NPPF and take into account PPG and the law (including case law) regarding the approach to be taken where development affects the historic environment and designated/non-designated heritage assets. We consider that the Modification does not provide clarity in the case of where there may be substantial harm to a designated heritage asset or less than substantial harm and objection is raised to the Modification as proposed. We duly request that the Councils and Inspectors review the Modification taking this into account. As stated earlier we note that the tracked change version of the Plan, as modified, Jillings Heynes Diocese of does not reflect the Schedule of Modifications. Indeed, at sub-para. 3 in the tracked change version of the Plan we note that it states that ‘any harm to the significance of a designated 196 964187 MM48 Ed Heynes Planning Ltd Plymouth heritage asset they must be fully justified against significant wider public benefits ….”. In our view, the proposed wording in the tracked change version does not reflect the approach adopted in the NPPF regarding the assessment of proposals for development in terms of their impact on both designated and non-designated heritage assets. For example, paragraph 196 of the NPPF makes it clear that where there is less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal. In that respect, the harm could be ‘any’ harm but paragraph 196 does not require a ‘significant’ wider public benefit to be demonstrated. For the avoidance of doubt the Modification in the tracked change version should not be relied upon;

61 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM48 – we note the content of the Proposed Modification. It is vital that the changes reflect the objectives of the NPPF and take into account PPG and the law (including case law) regarding the approach to be taken where development affects the historic environment and designated/non-designated heritage assets. We consider that the Modification does not provide clarity in the case of where there may be substantial harm to a designated heritage asset or less than substantial harm and objection is raised to the Modification as proposed. We duly request that the Councils and Inspectors review the Modification taking this into account. As stated earlier we note that the tracked change version of the Plan as modified Mr/Mrs Jillings Heynes does not reflect the Schedule of Modifications. Indeed, at sub-para. 3 in the tracked change version of the Plan we note that it states that ‘any harm to the significance of a designated 201 1095768 MM48 Ed Heynes David/Jane Planning Ltd heritage asset they must be fully justified against significant wider public benefits ….”. In our view, the proposed wording in the tracked change version does not reflect the approach Stratton adopted in the NPPF regarding the assessment of proposals for development in terms of their impact on both designated and non-designated heritage assets. For example, paragraph 196 of the NPPF makes it clear that where there is less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal. In that respect, the harm could be ‘any’ harm but paragraph 196 does not require a ‘significant’ wider public benefit to be demonstrated. For the avoidance of doubt the Modification in the tracked change version should not be relied upon.

MM48 – we note the content of the Proposed Modification. It is vital that the changes reflect the objectives of the NPPF and take into account PPG and the law (including case law) regarding the approach to be taken where development affects the historic environment and designated/non-designated heritage assets. We consider that the Modification does not provide clarity in the case of where there may be substantial harm to a designated heritage asset or less than substantial harm and objection is raised to the Modification as proposed. We duly request that the Councils and Inspectors review the Modification taking this into account. As stated earlier we note that the tracked change version of the Plan as modified Mr/Mrs Jillings Heynes does not reflect the Schedule of Modifications. Indeed, at sub-para. 3 in the tracked change version of the Plan we note that it states that ‘any harm to the significance of a designated 202 964051 MM48 Ed Heynes Richard/Barb Planning Ltd heritage asset they must be fully justified against significant wider public benefits ….”. In our view, the proposed wording in the tracked change version does not reflect the approach ara Bennett adopted in the NPPF regarding the assessment of proposals for development in terms of their impact on both designated and non-designated heritage assets. For example, paragraph 196 of the NPPF makes it clear that where there is less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal. In that respect, the harm could be ‘any’ harm but paragraph 196 does not require a ‘significant’ wider public benefit to be demonstrated. For the avoidance of doubt the Modification in the tracked change version should not be relied upon.

MM48 - (Policy DEV22) Appropriate development and wider Estate planning is needed to secure long term financial, community and social sustainability and the future of the Estate, including the conservation of its historic buildings and landscape. The Trust is fully committed to ensuring any future development on the Estate pays special attention to and is informed by the Estate’s heritage assets and that consideration is given to opportunities to enhance their settings. The Trust is therefore supportive of policies which ensure development proposals take account of these points. However, there are a number of points within policy DEV22 which the Trust believe require further attention and these are Andrew Dartington Hall 345 1002035 MM48 Lichfields Jo Talling discussed in further detail below. As a general point, the phrasing of policy DEV22 is in places informal and ambiguous. The first sentence of Policy DEV22 makes reference to national Cockett Trust and local significance of heritage assets. Heritage assets do not have different national and local significances and this should simply read ‘according to their significance’. A new point is added which states: ‘Where harm to designated and non-designated heritage assets can be justified applicants will be required to undertake excavation or recording as appropriate, followed by analysis and publication to professionally acceptable standards’. This point is vague and therefore open to different forms of interpretation. The requirement to provide excavation or recording must be clearly justified.

Ms Victoria 382 1095125 MM48 Tanner- SUPPORT Tremaine Ms Victoria 383 1095125 MM49 Tanner- SUPPORT Tremaine MM50 – Development Policies DEV26 It is welcome that the Plymouth Ubran Fringe is recognised as having special characteristics and I believe that the amendments help to Cllr. Nicky characterise the Urban fringe. Policy PLY (NEW) 1.iii ‘The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate 25 684616 MM50 Hopwood settlements’, surely by 1880 homes proposed on the Plymouth Urban Fringe with direct access and view to the Dartmoor National park gives a justifiable reason for this development being in completely the wrong place. MM50 I disagree with this. Any building is going to be an INTRUSION TO LOCAL WILDLIFE. We are so fortunate to live in harmony with so many wild animals. Badgers, foxes, deer. We 32 1006285 MM50 Ms Liz Hore used to also have an abundance of wild rabbits but most have these seem to have disappeared since their habitat was occupied by the eco homes.

MM50 – Development Policies DEV26 Plymouth Urban Fringe is recognised having special characteristics i believe that the amendments help to characterise that Urban fringe. Policy 37 1096357 MM50 N Parr PLY (NEW) 1.iii ‘The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements’, but with 1880 homes proposed on the Plymouth Urban Fringe having direct access to view Dartmoor National park gives a justifiable reason for this development being in completely the wrong location.

62 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) MM50 – Development Policies (DEV26) As South Hams residents, the impact of the Plymouth Ubran Fringe, and all its implications for our immediate environment, cannot be over- emphasised! The special characteristics of this rural area, which separates Plymouth from The Dartmoor National Park, should be preserved and, as such, the new Policy PLY (NEW) 1.iii 40 1016378 MM50 Ian Kempsell "The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements" is totally incongruous! How can the building of 1880+ homes on the so-called Plymouth Urban Fringe, with direct access to, and view from, the Dartmoor National park, be justified. You consideration of the points raised above would be welcome. MM50: Development Policies DEV26: It is welcome that the PLYMOUTH Urban Fringe is recognised as having special characteristics and I believe that the amendments help to characterise the Urban Fringe. Policy PLY (NEW) 1. iii “THE PROPOSAL DOES NOT RESULT IN SIGNIFICANT INTRUSION INTO THE OPEN COUNTRYSIDE OR CONTRIBUTE TO THE 48 1096356 MM50 Anni Parr COALESCENCE OF SEPARATE SETTLEMENTS”, I strongly suggest 1880 homes proposed on the PLYMOUTH Urban Fringe with direct access and view to the DARTMOOR NATIONAL PARK gives a justifiable reason for this development being in completely the wrong place. I am happy that the Plymouth Urban Fringe is recognised as having special characteristics. However Policy PLY (NEW) 1.iii ‘ The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements’ , surely by 1880 homes proposed on the Plymouth Urban Fringe with direct access and view to the 53 1190044 MM50 Jo Smith Dartmoor National park gives a justifiable and valid reason for this whole development being in completely the wrong place. I believe that this site was considered back in 2000 along with the Sherford urban extension, but was rejected at that time because of proximity to the Dartmoor National Park and the adverse effect it would have on it by way of views out of the Park. Nothing has changed in this respect. I am pleased that the Plymouth Urban Fringe is recognised, and that states that future development proposals should ; 'not result in significant intrusion into the open countryside or 55 1190053 MM50 Simon Nobbs contribute to the coalescence of separate settlements’. The proposed plan for the large future development of Woolwell area surely contravenes both items in this statement given its location. I am happy that the Plymouth Urban Fringe is recognised as having special characteristics. However Policy PLY (NEW) 1.iii ‘ The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements’ , surely by 1880 homes proposed on the Plymouth Urban Fringe with direct access and view to the 59 1190062 MM50 Daniel Smith Dartmoor National park gives a justifiable and valid reason for this whole development being in completely the wrong place. I believe that this site was considered back in 2000 along with the Sherford urban extension, but was rejected at that time because of proximity to the Dartmoor National Park and the adverse effect it would have on it by way of views out of the Park. Nothing has changed in this respect. Policy PLY – Development in Plymouth’s Urban Fringe(NEW) . The urban fringe forms a potentially important ecological link between the less/undeveloped areas of countryside and farmland, and green infrastructure within the City but is one of competing pressures on land-use. For this reason we feel it important to highlight the need to protect and enhance 67 1014005 MM50 Carol Reeder Natural England ecological networks within the area. We therefore advise that the need to promote the conservation, restoration and enhancement of ecological networks within the area be referred to within the Plan text.

MM50: Clearly whomsoever has drawn lines through the immense changes to the open countryside and adverse contribution to the coalescence of separate settlements that 1880 new properties built on the fringes of Woolwell, Dartmoor National Park and small village of Bickleigh will have, neither live nor quite likely have never visited the area. Maybe such 78 1190081 MM50 Nicki Wheeler person/persons observing the area on Google Earth could have prevented these absurd changes being made. It is abundantly clear that locals opinions matter not a jot because the main issues that have been expressed since day one and that have previously been listened to now have had a metaphorical and physical line drawn through them.

Stating the the development does not have significant impact on Plymouth Urban Fringe...... it is ridiculous to state the 1880 houses being built on the edge of Dartmoor National Park will have no effect. This planet as a whole is having issues with ourselves killing it by our intrusion into green areas, global warming, plastic pollution etc. This WILL HAVE AN AFFECT on 83 1190410 MM50 Sarah Jackson the natural habitat of LOTS of animals we see regularly in Woolwell . Deer, foxes and Hedgehog’s are a few that are commonly seen on a daily basis; there are also the birds and other animals that help the ecosystem to be considered (I however am not knowledgeable on this to quote names). Humans are not the only inhabitants of the area, a Wildlife and trees make this lovely county what it is (and draws in our tourism) so why be so flippant in killing it off!

63 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

DEV26- new PLY The total loss of DEV26 and the creation of a new Plymouth policy has had a major impact on the Bickleigh Neighbourhood Plan (and others). Through 2016 and 2017 there has been much discussion between the Bickleigh Working Group and SHDC concerning the land definitions. Many individual letters were delivered to SHDC on this matter. (hopefully in your filing system) Our position was that “ an important piece of countryside, which provides a significant gap between the city of Plymouth and the Dartmoor National Park has been classified differently to similar countryside elsewhere in the Parish of Bickleigh, because it lies outside the Plymouth Urban Fringe boundary. The previous consultation version of the Joint Local Plan designated both these areas as strategic landscape areas. This was endorsed by the community when it was part of the Neighbourhood Plan consultation in November 2016. No reason is given as to why the latest version of the Joint Local Plan no longer regards the countryside around Bickleigh village and up to the National Park Miss boundary as having strategic landscape value. To designate adjacent areas of countryside differently merely because they lie either side of an arbitrary planning boundary is 151 1013602 MM50 Elizabeth inappropriate and likely to have the effect of the areas being viewed differently by developers. To regard the area around Bickleigh village merely as 'countryside' fails to provide a Gilmour strong landscape context for the proposed Woolwell extension or adequately protect the setting of the Dartmoor National Park .” After the Inspectors passed their decision on the JLP the Examiner of the Bickleigh NP informed us we had to remove our policy BICK03. There are words within the new policy which imply care will be taken and careful management will take place with reference to the landscape and protection from urban sprawl. This is good. However, I believe the development of a relevant policy for the vital swathe of countryside in Bickleigh parish that serves as buffer between city and the nationally designated areas has been a struggle for the JLP. I believe it was on the right lines in the spring of 2016; and we were in agreement with its approach. It received a lot of support when the original proposed map of ‘strategic landscape areas’ was shared with the community of Bickleigh parish in 2016. Something got lost along the way. I believe that the former policy Bick03 had merit and much to commend it. I recommend that the JLP is asked to think again.

1880 house for Woolwell, you are having a laugh!!!!! As I have stated above the road system cannot cope now and would not cope with a further 4,500 / 5,000 cars daily going down this road, plus who knows how many more thousands if the proposed developments in Yelverton and Tavistock are carried out. This development would in the words of one of our 156 1190530 MM50 Robert Tolley prominent figureheads be "a carbuncle on the landscape". What is wrong with developing Brown Field sites in Plymouth, you seem quite happy to leave sites derelict or develop them into "another tower block" for students so why not turn them into more private housing, sorry I forgot, you will tell me the town centre couldn't cope with increased traffic, how silly of me to not realise this!!!! but i's ok to foist it on Woolwell.

MM50 MM52. The proposed changes e.g. deletion of Dev 26 have re-cast (some of) the intentions and conclusions reached in the public consultation and examination of the JLP. The following are intended to re-align or clarify them. You will find 3 areas of comment below. While understanding the main change from safeguarding to qualification, we have found it impossible to distinguish between the profusion of greenspace/ landscape categories that results. A table of definitions of the categories (current and future) would be most helpful. This should include definitions across the whole of the JLP area and a harmonisation, if relevant, as we have noted similar concerns in adjacent areas in South Hams. 2. MM50 and Tamerton Foliot MM52.In laying out potential tests for developments, instead of blanket safeguarding,the explicit recognition and ranking of Conservation Areas and their setting s should be made in Mr Dennis Village the evaluation of development proposals – in particular in the urban fringe. Conservation Area greenspace should be ranked with or classified as City Greenspace as it can be argued 158 487799 MM50 Silverwood Conservation that this designation (Conservation Area) is given by PCC in committee and therefore ranks above Neighbourhood Plans which are subsidiary to Local Authority plans. There is an Society internal disagreement between SPT 11(10) and new policy 2(i) replacing Dev 26. Re development of public rights of way – the wording ‘protect and improve’ implies stasis whereas SPT 11 implies there should be active increase and extension. Proposed amendments to reflect these points are shown in red in Annex A of the attachment. Comments and correction to the policies map are shown in Annex B of the attachment

See attachment

MM50: Policy DEV26, associated narrative and consequential amendments The amended policy is overly restrictive and not justified by the evidence base. It appears to retain the emphasis of the special landscape policy which has already been considered to be unsound. In our view it would be sufficient to have a general development management policy which Emery Wainhomes requires development to have regard to the landscape character areas and their characteristics. It is important to note that the plan proposes significant site allocations within Mr John 214 893384 MM50 Planning (South West) Plymouth’s urban fringe. Furthermore, when other constraints are factored in (principally Strategic Green Space) there are effectively no potential directions for future growth of a Coxon Partnership Holdings Ltd. regionally significant city. If additional land is required to meet development needs in the future, for example beyond the plan period or in response to a housing land supply shortfall, the urban fringe represents one of the only logical options for future growth. Under these circumstances the application of a restrictive landscape policy is unjustified and places an unreasonable additional burden on land which is almost certainly needed to accommodate development in the future.

Paignton Mr David 224 1094326 MM50 Neighbourhood The Forum supports the proposals as published and in particular those of MM50. Watts Plan Forum Cllr Michael 245 1004109 MM50 Please see attached. Blake

Mrs Linda MM50 Policy DEV26 New Policy The removal of DEV26 for the New Policy is rather contradictory as it acknowledges the Status and Special characteristics of the Plymouth Fringe as it 252 1096832 MM50 Crowe specifies that Development will only be permitted where the criteria are met. To those living in the area it is obvious that this Developement should be brought into question.

64 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM50 Policy DEV26 New Policy The removal of DEV26 for the New Policy is rather contradictory as it acknowledges the Status and Special characteristics of the Plymouth Fringe as it 258 1096834 MM50 Mr M Crowe specifies that Development will only be permitted where the criteria are met. To those living in the area it is obvious that this Developement should be brought into question.

MM50: The Plymouth Urban Rural fringe is now recognised specifically as having “special characteristics” which totally justifies that the site of PLY44 cannot be considered as a significant site for new development for the following reasons as stated in the modifications: i. The form, scale and design is not visually intrusive and is well integrated into the landscape. The landscape does not lend its self to having a large scale development that wpuld not be visually intrusive. The majority of the settlement will be seen from the entire south side of the Dartmoor National park and very intrusive so close to the parks boundaries, as well as all of the other smaller settlements within the national park. Travelling from Rebecca 262 1096845 MM50 Yelverton it will ensure that all doing so will see Plymouth devouring the countryside which will mean that it is not well integrated into the landscape. ii. PLY44 site is not Clayton suited and therefore this statement justifies not developing the area. iii. PLY44 is not the correct site and will be intruding into open countryside and devours the Village of Roborough into the new settlement additional apart from a small section it will also destroy the desirable element of Bickleigh which is its rural elements by making it an annexe of Woolwell. Which is completely against what the JLP amendment is stating. iv. Please see above. v. Be complementary to and not prejudice any viable agricultural operations on a farm and other existing viable uses. Significant farmland is being destroyed and viability of farm businesses including the viability of tenant farmers will be jeopardised.

MM50: The Plymouth Urban Rural fringe is now recognised specifically as having “special characteristics” this is very welcomed! In this respects it totally justifies that the site of PLY44 cannot be justified as a significant site for new development for the following reasons as stated in the modifications: The form, scale and design is not visually intrusive and is well integrated into the landscape. The topography of the landscape does not lend its self to allowing a large scale development not to be visually intrusive. The majority of the settlement will be seen from the entire south side of the Dartmoor National park as well as all of the other smaller settlements within the national park. Travelling from Yelverton it will ensure that all will see Plymouth sprawling into the countryside which will mean that it is not well integrated into the landscape. The development, either individually or cumulatively does not 266 1096858 MM50 Ben Gavan significantly harm the open character, key characteristics, valued attributes, or sensitive features of the area or important views. As above. PLY44 site is not suited and therefore this statement justifies not developing the area. The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements. PLY44 is not the correct site and will be against this due to it intruding into open countryside and will cause separate settlements especially the Village of Roborough to be amalgamated into the new settlement additional apart from a small section it will amalgamate Bickleigh which is completely against what the JLP amendment is stating. The setting, individual character and identity of adjoining settlements is not significantly harmed. As point 3. Be complementary to and not prejudice any viable agricultural operations on a farm and other existing viable uses. Significant farmland is being destroyed and viability of farm businesses including the viability of tenant farmers will be jeopardised.

MM50: The Plymouth Urban Rural fringe is now recognised specifically as having “special characteristics” this is very welcomed! In this respects it totally justifies that the site of PLY44 cannot be justified as a significant site for new development for the following reasons as stated in the modifications: The form, scale and design is not visually intrusive and is well integrated into the landscape. The topography of the landscape does not lend its self to allowing a large scale development not to be visually intrusive. The majority of the settlement will be seen from the entire south side of the Dartmoor National park as well as all of the other smaller settlements within the national park. Travelling from Yelverton it will ensure that all will see Plymouth sprawling into the countryside which will mean that it is not well integrated into the landscape. The development, either individually or cumulatively does not 270 1096861 MM50 Tara Gavan significantly harm the open character, key characteristics, valued attributes, or sensitive features of the area or important views. As above. PLY44 site is not suited and therefore this statement justifies not developing the area. The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements. PLY44 is not the correct site and will be against this due to it intruding into open countryside and will cause separate settlements especially the Village of Roborough to be amalgamated into the new settlement additional apart from a small section it will amalgamate Bickleigh which is completely against what the JLP amendment is stating. The setting, individual character and identity of adjoining settlements is not significantly harmed. As point 3. Be complementary to and not prejudice any viable agricultural operations on a farm and other existing viable uses. Significant farmland is being destroyed and viability of farm businesses including the viability of tenant farmers will be jeopardised.

MM50: The Plymouth Urban Rural fringe is now recognised specifically as having “special characteristics”, this is a major step forward however, it now surely identifies that the site of 274 1191389 MM50 Larry Taylor PLY44 can now no longer be justified as a significant site for new development? Regional Director Mr Keith 284 1096040 MM50 Pegasus A&M Trust Please see attached. Fenwick Planning Group Mr Ed Donna 291 833927 MM50 EJFP Planning Please see attached Persse Forshaw Carole MM50 (DEV26) – OBJECTION. The building of 1880 homes in clear view of Dartmoor National Park and intruding into the open countryside is in direct contradiction with the whole 296 1096742 MM50 Spencer permitted development outcomes stated in 1.i. to 1.v inclusive.

65 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM50: The Plymouth Urban Rural fringe is now recognised specifically as having “special characteristics” this is very welcomed! In this respects it totally justifies that the site of PLY44 cannot be justified as a significant site for new development for the following reasons as stated in the modifications: The form, scale and design is not visually intrusive and is well integrated into the landscape . The topography of the landscape does not lend its self to allowing a large scale development not to be visually intrusive. The majority of the settlement will be seen from the entire south side of the Dartmoor National park as well as all of the other smaller settlements within the national park. Travelling from Yelverton it will ensure that all will see Plymouth sprawling into the countryside which will mean that it is not well integrated into the landscape. The development, either individually or cumulatively does not 299 1191484 MM50 R Pengelly significantly harm the open character, key characteristics, valued attributes, or sensitive features of the area or important views. As above. PLY44 site is not suited and therefore this statement justifies not developing the area. The proposal does not result in significant intrusion into the open countryside or contribute to the coalescence of separate settlements . PLY44 is not the correct site and will be against this due to it intruding into open countryside and will cause separate settlements especially the Village of Roborough to be amalgamated into the new settlement additional apart from a small section it will amalgamate Bickleigh which is completely against what the JLP amendment is stating. The setting, individual character and identity of adjoining settlements is not significantly harmed. As point 3. Be complementary to and not prejudice any viable agricultural operations on a farm and other existing viable uses. Significant farmland is being destroyed and viability of farm businesses including the viability of tenant farmers will be jeopardised.

MM50- Policy PLY (NEW) 1.iii Woolwell borders Dartmoor National Park, an area of Outstanding Natural beauty. At present the existing Woolwell does not cause much intrusion to the 309 1191513 MM50 Emma Hogg park but with the addition of over 1800 new homes as per the proposed development (all with direct access to and a view of this National Park) surely suggests that this development is in the wrong place. This size of development will become an eyesore on the open countryside and will greatly intrude on one of the precious national parks of this country.

Steve Bickleigh Parish 320 1007783 MM50 Clement- Please see attached. Council Large

MM50: The Plymouth Urban Rural fringe is now recognised specifically as having “special characteristics” this is very welcomed! In this respects it totally justifies that the site of PLY44 cannot be justified as a significant site for new development for the following reasons as stated in the modifications: The form, scale and design is not visually intrusive and is well integrated into the landscape . The topography of the proposed site does not support such a dense large scale development to not to be visually intrusive. The majority of the settlement will be seen from the entire south side of the Dartmoor National park giving the impression the two blend directly from one into the other. The development, either individually or cumulatively does not significantly harm the open character, key characteristics, valued attributes, or sensitive features of the area or important views. As above. PLY44 Glenn 362 1191554 MM50 site is not suited impacting the open character of the area ,therefore this statement justifies not developing the area. The proposal does not result in significant intrusion into the open Pengelly countryside or contribute to the coalescence of separate settlements . PLY44 is not the correct site and will be against this due to it bordering the open countryside and will cause separate settlements especially the Village of Roborough to be amalgamated into the new settlement. Likewise apart from a small section of green space Bickleigh village which merge with the new development which is completely against what the JLP amendment is stating. The setting, individual character and identity of adjoining settlements is not significantly harmed. As point 3. Be complementary to and not prejudice any viable agricultural operations on a farm and other existing viable uses. Significant farmland is being destroyed. One tenant farm being completely consumed and viability of the other farm bordering New Road will mean there is not enough land to make this tenant farm a viable business.

Ms Victoria SUPPORT . The proposed modifications make it clear that a purpose of greater restrictions on development in Plymouth's urban fringe is to conserve and enhance the surrounding 384 1095125 MM50 Tanner- designated landscapes. Tremaine New para after 6.97 re intertidal habitats. We suggest that “are priority habitats” in the first sentence be replaced with “(including priority habitats)” to reflect the fact that priority 68 1014005 MM51 Carol Reeder Natural England habitats are identified in discreet areas. We also suggest that the brackets surrounding the words “coastal squeeze” are removed and replaced with commas as coastal squeeze is a distinct issue in its own right. Dear Strategic Planners, I am writing to voice my opposition to the Joint Local Plan. I understand that planning inspectors have allocated 504 houses in Dartington and almost another 500 in Totnes. It is unfair and unsustainable, to grow our village by 63% in 20 years. It will damage our countryside, rural character and choke our roads. I object to the development of the green fields of Broom Park and Sawmills West. In particular I object to the modifications that have been proposed to the Plan - I am concerned about policies which: 4. Damage 100 1190458 MM51 Nisha Toppin wildlife. We are so lucky to have Greater Horseshoe bats and dormice which are on the brink of extinction, but some policies in the JLP allow ‘mitigation’ to enable development. This means that precious habitats can be destroyed and a feature favoured by a species (eg a hedge) can be created elsewhere in the hope that the bats, dormice or otters will move in. Mitigation in the case of endangered species is illegal, so this policy must be changed.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 104 1018487 MM51 Gill Gairdner (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

66 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 109 1018748 MM51 Hazel Fuller (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation Anthea 113 1013363 MM51 (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development Scholefield and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 117 1017978 MM51 D Elphick (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation Barbara 121 1017979 MM51 (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development Henry and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 125 1190518 MM51 A Richards (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation Miss Rosa 129 1013608 MM51 (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development Bloomberg and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation McConnell- 133 1190520 MM51 (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development Bloomberg and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 137 1190522 MM51 Janet Wilce (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

67 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 141 1190523 MM51 W Ollis (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 145 1190525 MM51 Pam Gorman (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Miss 152 1013602 MM51 Elizabeth DEV28 - Approve Gilmour

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 176 1191000 MM51 Joyce Higgins (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation Mrs F H 180 1191008 MM51 (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development Williams and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate conflict with policy MM51. GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 187 1191016 MM51 Pippa Palmer (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal

Paignton Mr David 225 1094326 MM51 Neighbourhood The Forum supports the proposals as published and in particular those of MM51. Watts Plan Forum

We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment 234 658611 MM51 Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM51 Inclusion of a new paragraph after 6.97, Salmon Agency as part of the narrative on DEV28, which highlights the importance of inter-tidal habitats in the plan area and the need to avoid any loss.

68 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Wildlife Potection. Policies that deal with wildlife protection, especially European or UK protected species are spread throughout the JLP and its modifications. I believe that the policies conflict and some may be undeliverable. Policy SPT11 1. Allows harmful impacts to protected habitats and species and mitigation elsewhere or compensation for harmful measures, rather than curbing or not allowing harm to known habitats and rare species as a guiding principle of the JLP. This is an unacceptable approach; trading our rarest species and their vital habitats and migration routes or flyways for cash. Offering compensatory measures for damage allows development that will knowingly damage or destroy protected wildlife and habitats. To work against the UK and EU laws that should protect such sites would appear to be illegal. Species cannot move and recolonise new areas to suit our wishes. Providing a network of greenspace Policy SPT11 (4.8 ), may offer open spaces for people to enjoy but will not safeguard and nurture species on the edge such as dormice, bats or cirl buntngs. These species are endangered because they depend on very specific, often declining habitats that cannot just be recreated anew elsewhere. These overarching policies affect the decision making on wildlife and its value throughout the JLP and I would object strongly to their weakness and even legality when applied. Specific policy MM51 is generally welcomed however, in recognising the importance of protection Greater Horseshoe bats. Recognising the ‘in combination’ effects of development is good, as is reminding decision makers of the legal derogation tests for assessing sites within the SAC. Removing the ‘wherever possible’ will tighten the policy in regard of BAP species. On its own, this policy would be applauded, however its aims are, I would argue, undeliverable given the number of houses allocated in Dartington and Totnes; the area covered by the SAC and by major flyways of Greater Horseshoe bats. There are many acknowledged roosts scattered throughout the area (in addition to the major maternity and hibernation roosts at Buckfastleigh etc) and the area lies directly under the flyzone between the Buckfastleigh and Berry Head colonies. Given the massive areas of new building in the Torbay area also along this vital flyzone, the JLP Don't Bury modifications do not take account of the ‘in combination’ effects of development upon the whole areas used by this species but vital for survival and protecting the isolation of 305 1014585 MM51 Trudy Turrell Dartington Under colonies. Consideration needs to extend beyond planning area boundaries. The first step required is to effectively map the actual EPS bat corridors in any areas before allocations can Concrete proceed. As a query, the roosts and activity areas that I refer to are taken from DCC maps of recordings that are the base maps for the revision of the SPD on Greater Horseshoe bats. Were these maps used as base maps and to inform planning inspectors in this JLP? If they were, and should have been as they have been agreed as a good understanding of the spatial pattern of roosting and use of the area, then it would appear that decisions to allow large tracts of new housing in this area would conflict with protection measures for the species. If they were not, then I ask that these be referred to and used to inform revisions to policy and allocations in this area. Policy TTV 30 (NEW) Point 7, for Dartington Estate, recognises the importance of greater Horseshoe bats in particular but allows for mitigation of loss to allow development. This policy is weak for wildlife protection and it would better read that instead of ‘where appropriate’ ‘unless an alternative cannot be provided on the estate or off’, that mitigation be allowed’ This would recall the 3 derogation tests and the precedence that development affecting protected species may only be permitted if there is an ‘over riding public imperative’, the definition of this has been tested and informed by case law. To explain our very real concerns for protected wildlife within the plan area, please add the attached paper on Greater Horseshoe Bats and planning in Dartington as our evidence that on the ground, allowing over development and relying on planning conditions and the measures offered by developers come far too short of protection for this endangered species. A catalogue of insufficient and failing surveys, planning conditions and breaches in our parish alone points to the likely outcome of policies that allow damage to, rather than protect this species. Greater Horseshoes are the canaries down our mine; an indicator of the effects of too much development, habitat loss and fragmentation and light pollution on so many of the species in our area. Please accept this paper as part of this response to the JLP modifications. In addition, if you would like some of those who compiled it to meet and discuss its findings with you, we would very much welcome positive dialogue, Thank you. Trudy Turrell, Chair, Don’t Bury Dartington Under Concrete

Ms Victoria SUPPORT with reservations the proposed modifications The first new point referring to European sites refers to " alone or in com b ina ti on with other development' ' this should be 385 1095125 MM51 Tanner- other projects not solely other developments if it is to correctly reflect the law for European sites. The prop do not address a minor change I suggested to point 2. which was to Tremaine exchange 'wildlife' for 'biodiversity' with regards enhancements as biodiversity includes flora as well as fauna (wildlife). Amanda 391 1018467 MM51 Please see attached (Dartington) Chadwick

396 1191638 MM51 Adam Griffin Please see attached (Dartington)

401 1191642 MM51 Angla Hornby Please see attached (Dartington)

Agata 406 1191646 MM51 Please see attached (Dartington) Krajewska Ashley 411 1191654 MM51 Please see attached (Dartington) Parsons

416 1191660 MM51 Andrea Prew Please see attached (Dartington)

Mrs A 421 1191664 MM51 Please see attached (Dartington) Robinson Miss Ali 426 1094187 MM51 Please see attached (Dartington) Roscoe Mr Ashton 431 1114209 MM51 Please see attached (Dartington) Chadwick

69 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Cllr Andy 436 1191668 MM51 Please see attached (Dartington) Simms 441 1191677 MM51 A Smaldon Please see attached (Dartington) 446 1191679 MM51 Alan Whele Please see attached (Dartington) 451 1191680 MM51 Mrs Aydin Please see attached (Dartington)

456 1191681 MM51 Barbara Keen Please see attached (Dartington)

461 1191683 MM51 Bree Long Please see attached (Dartington)

466 1191687 MM51 Brian Mascall Please see attached (Dartington)

Carol 471 1191688 MM51 Please see attached (Dartington) Ballenger Christina 476 1097444 MM51 Please see attached (Dartington) Bennett

481 1191707 MM51 Chris Harding Please see attached (Dartington)

486 1017437 MM51 Clare Hornsey Please see attached (Dartington)

491 1191709 MM51 Mr C Mapsen Please see attached (Dartington)

496 1018458 MM51 Carole Powell Please see attached (Dartington)

501 1191712 MM51 Miss C Watt Please see attached (Dartington) Denis 506 1191715 MM51 Please see attached (Dartington) Anderson

511 1097433 MM51 David Barnett Please see attached (Dartington)

David 516 1097428 MM51 Please see attached (Dartington) Duncombe David 521 1191719 MM51 Please see attached (Dartington) Ferguson

526 1191720 MM51 Donald James Please see attached (Dartington)

Dick 531 1191723 MM51 Please see attached (Dartington) Kassabian 536 1191726 MM51 D Smaldon Please see attached (Dartington) 541 1191729 MM51 David Vitler Please see attached (Dartington) Doirrey 546 1191730 MM51 Please see attached (Dartington) Watterson 551 1191732 MM51 D Young Please see attached (Dartington) Elizabeth 556 1014700 MM51 Please see attached (Dartington) Callaway 561 1191743 MM51 E Ferguson Please see attached (Dartington) Elizabeth 566 1191745 MM51 Please see attached (Dartington) Turner Esther 571 1097402 MM51 Please see attached (Dartington) Watson

576 1017430 MM51 Fiona Bicknell Please see attached (Dartington)

70 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Frances 582 1191752 MM51 Please see attached (Dartington) Brodrick Anne 586 1191751 MM51 Please see attached PDF (Dartington) Woodend 592 1191756 MM51 Colin Bastin Please see attached PDF (Dartington) 595 1191757 MM51 Fiona Tilley Please see attached (Dartington) 601 1191759 MM51 Claire Stoyle Please see attached PDF (Dartington) 609 1191766 MM51 Don Tucker Please see attached (Dartington)

611 1191762 MM51 Graham Black Please see attached (Dartington)

619 1191772 MM51 Geoff Caplan Please see attached (Dartington)

621 1191771 MM51 Ella Baillie Please see attached (Dartington) 624 1018737 MM51 EA Potter Please see attached (Dartington) Geoffrey 631 1018138 MM51 Please see attached (Dartington) Nickolls

637 1191776 MM51 Graham Prew Please see attached (Dartington)

641 1191777 MM51 Gail Johnson Please see attached (Dartington) Gordon 643 1191780 MM51 Please see attached PDF (Dartington) Woodend Gordon 651 1002916 MM51 Please see attached (Dartington) Riddel Isaac 656 1097358 MM51 Please see attached (Dartington) Bloomberg 662 1018485 MM51 D Hannaford Please see attached (Dartington)

665 1191782 MM51 I Underdown Please see attached (Dartington)

672 1191784 MM51 H Hannaford Please see attached (Dartington)

675 1018187 MM51 J Rich Please see attached (Dartington) 681 1191786 MM51 Lisa Daix Please see attached (Dartington) 686 1191788 MM51 Hon Ashton Please see attached (Dartington) 692 1191790 MM51 L Keel Please see attached (Dartington) 695 1016052 MM51 Heidi Orrell Please see attached (Dartington) Richard and 702 1018437 MM51 Jeanne Please see attached (Dartington) Hughes 704 1191793 MM51 M Cole Please see attached (Dartington) 711 1191795 MM51 Helen Welsh Please see attached (Dartington)

716 1016272 MM51 Isabelle Orrell Please see attached (Dartington)

721 1191800 MM51 Ian Smail Please see attached (Dartington)

726 1191801 MM51 John Callaway Please see attached (Dartington)

71 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Ref Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law). The attention to this welcomed and the recognition of the ‘in combination’ effects of development is good. However the plan is not sound because the policy is not deliverable owing to the allocation of some 1000 houses in Dartington and Totnes. Much of Dartington village is covered by the Special Area for Conservation (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.Greater Horshoe bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species 730 1015453 MM51 Karin Jordan and their habitat (including the SAC) is illegal and the plan is therefore not only unsound but also potentially non compliant legally. It is well documented that mitigation measures do not work and especially given the density of development proposed in Dartington village alone, the proximity of the new developments proposed will negate any mitigation attempts as the flyways will be severely disrupted in many directions. My proposal is that the density, complexity and scale of development is reviewed and reduced to protect existing flyways and that local Greater Horseshoe bat experts the William Pengelly Centre in Buckfastleigh are invited to work in partnership to identify what is possible to ensure that the bats are protected. Ref Policy MM51 is not positively prepared as it does not achieve unmet need or sustainability; neither is it justified or consistent with National Policy.

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 734 1191806 MM51 Ros Durston (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 738 1095210 MM51 Barry Reeves (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 742 1191810 MM51 Anita Cole (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 746 1017703 MM51 Helen Tune (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation Miss Selena 752 1094766 MM51 (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development Mara and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the ‘in combination’ effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation 758 1014631 MM51 Josh Zatz (SAC) for Greater Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH bats and other species have established flyways and foraging patterns and cannot change them. Loss of EU and UK protected species and their habitat (including the SAC) is illegal.

72 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Policy MM51 to protect endangered species, including Greater Horseshoe bats, (legally protected by European and UK law), is welcomed. The recognition of the effects of development is good, but may be undeliverable when allocating almost 1000 houses in Dartington and Totnes. Much of Dartington is covered by the Special Area for Conservation (SAC) for Greater 762 1095118 MM51 Sharon Ellis Horseshoe Bats and Totnes is crisscrossed by established bat flyways. Policy STP11 that allows offsetting for loss of protected species’ habitats due to development and STP30 that offer mitigation for loss of GH bat habitat lost to development on the Dartington Hall Estate, conflict with policy MM51.GH . Bats and other species have established flyways and foraging patterns and cannot change them. My understanding is that loss of EU and UK protected species and their habitat (including the SAC) is illegal.

768 1191814 MM51 T Lang Please see attached (Dartington)

773 1191815 MM51 Joel Chadwick Please see attached (Dartington)

Janice 778 1018151 MM51 Please see attached (Dartington) Duncombe James 783 1097475 MM51 Please see attached (Dartington) Fordham John 788 1191817 MM51 Please see attached (Dartington) Greenhalgh 793 1097375 MM51 Joy Hanson Please see attached (Dartington)

798 1191818 MM51 Jenny Heaton Please see attached (Dartington)

803 1191819 MM51 Jane Hext Please see attached (Dartington) 808 1191820 MM51 June Hext Please see attached (Dartington) 813 1191821 MM51 J Hodgson Please see attached (Dartington) 818 1191822 MM51 John Lee Please see attached (Dartington) 823 1014649 MM51 J Marshall Please see attached (Dartington) Lesley 828 1191823 MM51 Please see attached (Dartington) Marshall 832 1191824 MM51 Josh Orrell Please see attached (Dartington) Jonathan 838 1191828 MM51 Please see attached (Dartington) Reeves Josephine 843 1013778 MM51 Please see attached (Dartington) Unwin 849 1073274 MM51 Joanna Watt Please see attached (Dartington)

855 1018385 MM51 Jacqui Wilkins Please see attached (Dartington)

Arthur 859 1191829 MM51 Please see attached (Dartington) Durrant 863 1191830 MM51 Kevin Childs Please see attached (Dartington) Katherine 869 1191832 MM51 Please see attached (Dartington) Smaldon 873 1018193 MM51 Alex Sharp Please see attached (Dartington) 877 1191833 MM51 Kevin Weale Please see attached (Dartington)

884 1014279 MM51 Lucia Fausset Please see attached (Dartington)

891 1191835 MM51 Lorna James Please see attached (Dartington) 893 1191834 MM51 Cass Wynne Please see attached (Dartington) 898 1191836 MM51 L Korda Please see attached (Dartington) Mr and Mrs T 903 1191837 MM51 Please see attached (Dartington) Locker 908 1191860 MM51 Michael Cox Please see attached (Dartington)

914 1191861 MM51 Mary Hobden Please see attached (Dartington)

73 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 918 1018405 MM51 Mavis Jones Please see attached (Dartington) Dr Malcolm 924 1017707 MM51 Please see attached (Dartington) Purcell 929 1191882 MM51 Mick Wicks Please see attached (Dartington) Mr Nigel 934 1094768 MM51 Please see attached (Dartington) Backhouse Lauryn 938 1191915 MM51 Please see attached (Dartington) Reeves Elizabeth 943 1018413 MM51 Please see attached (Dartington) Williams Matthew 948 1191933 MM51 Please see attached (Dartington) Heming Michael 957 1191935 MM51 Please see attached (Dartington) Brown 959 1191934 MM51 Nigel Hinks Please see attached (Dartington) 965 1017617 MM51 P Douglas Please see attached (Dartington) Mr Martin 969 1073037 MM51 Please see attached (Dartington) Crawford

977 1191936 MM51 Philip R Jones Please see attached (Dartington)

979 1191937 MM51 Matt Harvey Please see attached (Dartington) 984 1191938 MM51 Pete Reeves Please see attached (Dartington) Rosamund 990 1018175 MM51 Please see attached (Dartington) Bastin Martina 994 1191939 MM51 Please see attached (Dartington) Heming 999 1191943 MM51 Minni Jain Please see attached (Dartington) Ms Mary 1004 1095121 MM51 Please see attached (Dartington) Light Michelle 1009 1191948 MM51 Please see attached (Dartington) McHale

1014 1191949 MM51 Richard Hard Please see attached (Dartington)

Main 1020 1191951 MM51 Please see attached (Dartington) Patterson 1024 1191952 MM51 Rooh Star Please see attached (Dartington) 1029 1191953 MM51 Monika Pike Please see attached (Dartington)

1035 1191954 MM51 Rachel Tucker Please see attached (Dartington)

Marti 1039 1191955 MM51 Please see attached (Dartington) Valentine 1045 1191958 MM51 Mike Welsh Please see attached (Dartington) 1049 1191957 MM51 Sarah Curtis Please see attached (Dartington) 1054 1191961 MM51 Nell Admiral Please see attached (Dartington)

1059 1191963 MM51 Nicholas Keen Please see attached (Dartington)

1064 1191966 MM51 Mr O Clarke Please see attached (Dartington) Oliver 1069 1095333 MM51 Please see attached (Dartington) Tringham 1074 1191968 MM51 T Palm Please see attached (Dartington)

74 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) 1079 1018745 MM51 Pollie Ash Please see attached (Dartington) Mr Phillip 1084 1094867 MM51 Please see attached (Dartington) Bridge

Philip and 1089 1097512 MM51 Minni Franses Please see attached (Dartington) and Jain

1095 1191972 MM51 Sara Ferguson Please see attached (Dartington)

1099 1095641 MM51 Paul Hornby Please see attached (Dartington) 1105 1191973 MM51 Sandra Hard Please see attached (Dartington) Pamela 1110 1191974 MM51 Please see attached (Dartington) Kassabian SC 1114 1191975 MM51 Please see attached (Dartington) Underdown 1119 1191977 MM51 Sue Wicks Please see attached (Dartington) 1124 1191978 MM51 T Backhouse Please see attached (Dartington) 1129 1191980 MM51 Tanya Bell Please see attached (Dartington) 1135 1191981 MM51 Tim Grevatt Please see attached (Dartington) 1139 1191979 MM51 Peter Mingo Please see attached (Dartington)

1144 1191982 MM51 Vicky Hadland Please see attached (Dartington)

Patricia 1150 1191983 MM51 Please see attached (Dartington) O'Carroll 1154 1191985 MM51 Vivien Hinks Please see attached (Dartington) 1160 1018364 MM51 R & VM Keel Please see attached (Dartington) Phil 1164 1191986 MM51 Please see attached (Dartington) Sheardown Miss MR 1170 1018574 MM51 Please see attached (Dartington) Brand 1174 1191987 MM51 V J May Please see attached (Dartington) 1179 1191993 MM51 R Orrell Please see attached (Dartington) 1184 1191995 MM51 Richard Pike Please see attached (Dartington)

1188 1191997 MM51 Rosie Roberts Please see attached (Dartington)

1194 1191998 MM51 Roger Shelley Please see attached (Dartington)

Mr & Mrs RH 1199 1018009 MM51 Please see attached (Dartington) Tripp 1205 1191989 MM51 Debbie Feld Please see attached (Dartington) Mr R 1208 1018359 MM51 Please see attached (Dartington) Valentine 1214 1018420 MM51 Janice Bragg Please see attached (Dartington) 1220 1192003 MM51 Susan Boal Please see attached (Dartington)

1224 1192004 MM51 John Chapple Please see attached (Dartington)

1229 1192007 MM51 Jane Parker Please see attached (Dartington) 1234 1017953 MM51 John Platt Please see attached (Dartington) 1240 1192006 MM51 S Carrol Please see attached (Dartington) 1244 1192010 MM51 Lise Platt Please see attached (Dartington)

75 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee) Sandra 1250 1018749 MM51 Please see attached (Dartington) Crawford

1254 1018584 MM51 Marion Baker Please see attached (Dartington)

1260 1192013 MM51 Mike Bridger Please see attached (Dartington)

1265 1018583 MM51 M Green Please see attached (Dartington)

Susan 1269 1018841 MM51 Please see attached (Dartington) Goldsworthy

1275 1018446 MM51 M Lang Please see attached (Dartington) Mrs Susan 1279 1018172 MM51 Please see attached (Dartington) Greenhalgh Margaret 1284 1192017 MM51 Please see attached (Dartington) Lewis Philomena 1289 1192019 MM51 Please see attached (Dartington) Wynne 1295 1018169 MM51 Sandra Lee Please see attached (Dartington) Mr Roger 1299 1093100 MM51 Please see attached (Dartington) Nicholson Susan 1305 1192021 MM51 Please see attached (Dartington) Nancholas Stephen 1309 1192022 MM51 Please see attached (Dartington) Harper 1314 1192023 MM51 S Niemeyer Please see attached (Dartington) Mrs Sue 1319 1017725 MM51 Please see attached (Dartington) Norris Simon 1324 1192025 MM51 Please see attached (Dartington) Patterson Shimako 1329 1018357 MM51 Please see attached (Dartington) Sharpe

1334 1192027 MM51 Susan Weare Please see attached (Dartington)

Timothy 1339 1192030 MM51 Please see attached (Dartington) Hornsey 1344 1192034 MM51 Wendy Cook Please see attached (Dartington) 1349 1192035 MM51 Wendy Fisk Please see attached (Dartington)

MM52 – Development Policies DEV29 The deletion of this policy has a significant impact on the part of Woolwell known as Pinewood. I commended South Hams for including Pinewood as a Local Green Space as this gave residents comfort that with this high level protection this area would never be built on. As the Inspector has questioned this policy and it has been Cllr. Nicky totally rewritten this protection is no longer there. The new policy relies on Neighbourhood Plans to designate areas as Local Green Space but the Bickleigh Parish Council 26 684616 MM52 Hopwood Neighbourhood Plan does not include Pinewood as a local green space and it therefore moving forward will have no protection until the NP comes up for review. This in my mind will be to late and this policy as it is new will carry little weight in protecting this area from a planning application that is already with the local authority. I would ask that protection for this area is looked at as it will have a significant impact on residents in that area if development goes ahead.

76 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

To whom it may concern. Firstly I would like to say how I have found it difficult to navigate my way through the modifications and so I am having to email my concerns. My concerns are with the removal of Local Green Space within the plan. In particular to that at the end of Pinewood Drive, Woolwell. This piece of land is already with the Local Authority to build around 90 house on this plot of land. The land itself was scheduled for Local green space and so the original planning permission was declined. The owner put in new planning permission months ago when Inspector were called to question the designation of local green space. Its awaiting a decision. But in the meantime the inspector has chosen just to remove this policy of local green space protection entirely. This will have a huge impact of residence within the area. the removal of such protection from the designation of Local green Lucina Space leads me to believe the JLP is in the interest of building further properties. Also read that amongst other things the JLP will now allow people to reside in properties buildt in the 28 1014124 MM52 George Woolwell extension once built even if this is before the completion of making the infrastructure to the Woolwell site is completed. This is obsurd. There needs to be a better infrastruction on the A386 around the George and Tavistock Road by Woolwell and on road to tavistock. The roads within Woolwell are all ready overwhelmed by the amount of vehicles it cannot cope with more. This modification needs further consideration and changed back to previous policy of road first then the building of extension. I truly believe that if the JLP was to be completely rewritten so that all the council involves can just build houses without a care to residence within these areas or the infrastructure within then why ask the residence their opinions. The inspectors have literally just changed these policies and all we can do is comment but I am very unreassured that these comments will hold no weight at all.... I am very disappointed in how the JLP jas changed for the worst. Regards Lucina George

DEV29 - I should like to oppose the rewriting of this plan in relation to the area at Pinewood Woolwell. This green space on the edge of Woolwell follows along from the green space Rosemary 29 1018605 MM52 which surrounds the area of Woolwell. As such the deer foxes badgers etc among other animals use this area which naturally flows around Woolwell making a natural green belt Beasley around Woolwell. Rosemary Beasley MM52 Pinewood should be treated as local green space with the protection that that would afford. This would allow a bit of a buffer for local wildlife. If you could see the wildlife that 33 1006285 MM52 Ms Liz Hore we see on a regular basis perhaps this would already have been made a preserved area. It really is vital that we do not build on all of the wild areas that is their habitat. Please, please ensure that nature is put above monetary gain. Once it's gone, it's gone!

MM52 – Development Policies DEV29 The removal of the policy has a larger impact on the Woolwell area known as Pinewood. I appreciate South Hams have included that area and identified it as a Local Green Space giving residents knowledge that a high level of protection for that area is considered and would never be built on. The Inspector questioned the policy and it has been totally rewritten but the protection is no longer covered stating it relies on Neighbourhood Plans to designated areas as Local Green Space. However Bickleigh 38 1096357 MM52 N Parr Parish Council Neighbourhood Plan does not include Pinewood as a local green space and therefore it will not be afforded protection until the NP comes up for review. I consider that will be to late and this policy as it is currently carries little or no weight in protecting the area from any planning application that is already held with the local authority. I therefore ask that protection for that area is looked at again as it will have a significant impact on residents in the area if development goes ahead and those of us on the fringes.

MM52: Development Policies DEV29: The deletion of this policy has a huge impact on the part of WOOLWELL known as PINEWOOD. SOUTH HAMS is to be commended for including PINEWOD as a Local Green space as this gave residents comfort tht with the high level of protection this area would never be able to be built upon. As the inspector has questioned this policy and it has been totally rewritten, this protection is no longer in place! The new policy relies on neighbourhood plans to designate areas as local green space but the BICKLEIGH 49 1096356 MM52 Anni Parr PARISH COUNCIL NEIGHBOURHOOD PLAN does NOT include PINEWOOD as a local green space and it therefore moving forward will have no protection until the neighbourhood plan comes up for review. This will be too late and this policy as it is now will carry little or no weight in protecting this are3a from a planning application that is already with the Local Aughority I would ask that protection for this area is looked at as it will have a hugely significant impact on residents in that area if development goes ahead.

Peter I am also concerned about the possible loss of the green space at the bottom of Pinewood Drive following the loss of its protected status and, again, I would query what benefit this is 51 1190043 MM52 Goodman to the local community. At present, Woolwell is a great area in which to live and I am concerned that the proposed changes will have an adverse effect on quality of life in the area.

I am very disappointed that this section has been deleted, as it will affect the local green space known as Pinewood. This will not only affect those who live in the residential area adjacent to this LGS, but the wider community (I often meet people from further afield than Woolwell there) who frequently visit or pass through this open area. This does not even take into consideration the major disruption that any future development would have on the residents adjacent to Pinewood. The impact of construction traffic through a very 57 1190053 MM52 Simon Nobbs constricted access route I feel is not acceptable in an area that already is recognised as having access issues. This area is not currently in the Bickleigh Parish Council Neighbourhood Plan and would therefore not be protected until Neighbourhood plan comes up for review which until then I feel leaves this area vulnerable. Even then it could still be at risk as it would be a new addition and a possible target for planning application (which I believe may have already been submitted).

Local Green Space. The new para to follow the new development management policy on Local Green Space refers to policy for green belt. It would be useful if the text could clarify 69 1014005 MM52 Carol Reeder Natural England whether this is a reference national green belt policy. Local Green Space - Pinewood Area This has been removed and for the reasons I have stated above, the residents want a Green Space as we are concerned about the impact of the 84 1190410 MM52 Sarah Jackson Area. We moved here to see green areas not to live in a built up urban area. This is a rural area and as such we want it to stay this way. Miss 153 1013602 MM52 Elizabeth DEV29 - How can Green Space be ‘enhanced’ by the addition of ‘sports, cafes, transport routes’? All of which mean more concrete and tarmac. Gilmour

77 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Why do you need to develop Pinewood? If you have a policy for Green Spaces why destroy one, oh I forgot again, it's all about getting more cars on the road. How can developing Green Spaces be Environmentally good for Woolwell. The development along side the A386 has change significantly since it was first proposed so what makes you think this one would be any better. All you want is for the residents of this area to have concrete and brick with no thought to how they will enjoy the walking that they did and the wildlife you will drive 157 1190530 MM52 Robert Tolley out. It is clear to me and other people in Woolwell, that know and understand only to clearly, the Plymouth Plan is a joke and NO ONE is taking our views SERIOUSLY. When will you start to listen to the people (THE EXPERTS) who live here, and take note of what we know is best for us, which is not further development,traffic congestion and pollution. We thought we lived in a Democracy but it seems that Animal Farm has taken over and some are more equal than others and certainly only MONEY talks!!! I rest my case.

Friends of Ham Woods, response to consultation on main modifications to the JLP: Main Modification 52. Change of Local Green Space designation in Plymouth to City or Neighbourhood Green Space. Friends of Ham Woods is a constituted friends group with around 950 members. Although primarily concerned with Ham Woods LNR we recognise that ‘green corridors’ which join green spaces are an essential resource to enable wildlife to move between sites and recolanise areas where they may have become locally extinct. This is essential as if all green spaces were isolated, being relatively small habitats they would, over time, loose species resulting in reduced biodiversity. We regard the downgrading of designated Local Green Space in the JLP as significant and would strongly request that this modification is reversed. While we appreciate that there is agreement to add the new designation of City Green Space to some green spaces, we are worried that this designation and the Neighbourhood Green Spaces listing is insufficient protection for a thriving joined Mr David 161 490698 MM52 up green space network. As you are no doubt aware, green spaces in Plymouth have some important species within the city boundaries (e.g. Plymouth pear and European eel) and Curno without ‘green corridors’ the diverse habitats within the city and their unique wildlife would not be fully protected. There was considerable local consultation on the JLP over several years, and the Friends of Ham Woods were fully engaged in this process. I believe the Council have evidence of this consultation. Green Space protection is essential for wildlife and is becoming increasingly important resource for health and wellbeing, flood reduction, reduced air pollution and other ecosystem services and Friends of Ham Woods feel strongly that these green spaces require Local Green Space designation. Designating Neighbourhood Plans is a difficult process, especially city wide and would not necessarily address ‘green corridors’ between neighbourhoods. Friends of Ham Woods request that the value placed on these spaces by the group, discussed over many meetings, is acknowledged and the designation remains Local Green Space.

Main Modifications No.52 Policy DEV29 Paragraph 2ii of the new version of this policy should be removed. The new policy states that existing open space…………should not be built on unless it can be demonstrated that: The important function(s) and characteristics of the green space are retained. In making this judgement, the LPAs will have regard to evidence of the identified value of the green space's attributes as set out in any relevant Open Space Assessments. In the case of open space used for public recreation, the open space is surplus to requirements or the loss will be replaced by equivalent or better provision in a suitable location. will be assessed in relation to the impacts of development on the function(s) and 166 1190942 MM52 Mrs Jane Fox characteristics of the green space, and taking In making this judgement account will be taken of the plan's green space and play accessibility standards Our submission is that para i. of this policy is all that is needed. Why single out recreation? Section ii makes it sound as if recreation is not an ‘important’ function. Is recreation not part of the identified value of the green space's attributes? If not, it should be. This proposed two-part policy will make valued areas used for recreation much more difficult to defend against development. The phrases ‘ the open space is surplus to requirements or the loss will be replaced by equivalent or better provision in a suitable location inherently weakens the Council’s and the community’s position in defending these spaces. Why do not these phrases apply to other greenspace attributes?

MM50 MM52. The proposed changes e.g. deletion of Dev 26 have re-cast (some of) the intentions and conclusions reached in the public consultation and examination of the JLP. The following are intended to re-align or clarify them. You will find 3 areas of comment below. While understanding the main change from safeguarding to qualification, we have found it impossible to distinguish between the profusion of greenspace/ landscape categories that results. A table of definitions of the categories (current and future) would be most helpful. This should include definitions across the whole of the JLP area and a harmonisation, if relevant, as we have noted similar concerns in adjacent areas in South Hams. 2. MM50 and Tamerton Foliot MM52.In laying out potential tests for developments, instead of blanket safeguarding,the explicit recognition and ranking of Conservation Areas and their setting s should be made in Mr Dennis Village the evaluation of development proposals – in particular in the urban fringe. Conservation Area greenspace should be ranked with or classified as City Greenspace as it can be argued 173 487799 MM52 Silverwood Conservation that this designation (Conservation Area) is given by PCC in committee and therefore ranks above Neighbourhood Plans which are subsidiary to Local Authority plans. There is an Society internal disagreement between SPT 11(10) and new policy 2(i) replacing Dev 26. Re development of public rights of way – the wording ‘protect and improve’ implies stasis whereas SPT 11 implies there should be active increase and extension. Proposed amendments to reflect these points are shown in red in Annex A of the attachment. Comments and correction to the policies map are shown in Annex B of the attachment

See attachment

78 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

I write to formerly object to two points in the main modification on the JLP. Objection in relation to MM52 – Development Policies DEV29 The total deletion of this policy will have a major impact on the part of Woolwell known as Pinewood. I am at total loss as to why this policy has been deleted. Initially South Hams included Pinewood as a Local Green Space and this gave our community hope that our views had been listened to and how much we value this area as a green space and therefore it would be offered a high level protection and not built on. However now that the Inspector has questioned this policy, it has been totally rewritten and this protection is no longer there. I strongly urge that protection for this area be looked at. Building on this green space will have a significant impact on residents, including families who value this area. I have no idea if residents objections will make any difference, Mrs Sarah to date it is clear that residents views are largely ignored however I shall make this one final attempt in the hope Woolwell residents can make a difference. 181 1190871 MM52 Daniels Well in the ideal work there would be no further development of an already large community however as that’s not likely to happen then I strongly urge that firstly the main access into Woolwell be sorted before ANY housing developments are started. We are at total breaking point with only one way in. How on earth do you expect residents to be able to come or go with the added pressure of construction traffic. Traffic that will run right past our primary school. It’s an accident waiting to happen!!! I also urge you to look into the sudden change to pinewood no longer being deemed a protected green space. If the plan is to turn Woolwell into a concreate jungle and dig up all our beautiful green space and drive the wildlife out, then you’re going about it the right way. Please leave us some green space!!!

MM52 Development policies DEV29 The deletion of this policy, is taking away what little protection we have from further development on Pinewood Drive. It is not an ideal access 183 1012890 MM52 Mr Jon Todd road, nor an ideal site. There is clearly collusion in respect of this development proposal.

The inspectors review of the council LGS designation in EX15 states " Having considered this additional evidence we are concerned with the Councils’ methodology and overall assessment" " The approach in the JLP is to designate a significant number of sites across the PPA which results in the designation being commonplace rather than of a limited and special nature" " Open spaces will be used by local communities for informal recreational uses including dog walking. However these are inevitably commonplace activities within urban areas. Sites may also contain varying levels of wildlife, beauty and tranquillity. Nevertheless the available evidence does not sufficiently demonstrate why sites are ‘special’ and of ‘particular local significance’ to distinguish them from other green areas and open spaces" " sites are already covered wholly or in part by other designations, including local nature reserves, county wildlife sites, conservation areas and tree preservation orders, or other policy protections including allotments, woodlands and biodiversity networks. Such areas are therefore already protected by national and local planning policies or through other legislation." " The Planning Practice Guidance states that landowners should be contacted at an early stage about proposals to designate any part of their land as LGS and have opportunities to make representations. There is little available evidence demonstrating that such landowners were contacted during the LGS selection process and that their comments have been robustly addressed within the assessments." As a response the council have now re- assessed the boundaries of areas and re-assessed the designation of areas. This is the first opportunity given to comment on the new boundary and designation of land related to PLY41. Within SGA1 - Part 2 page 29, Fig 33 Land Ownership, LDA documents the land in the greater boundary area and lists ALL landowners. At this very early stage the document fails to correctly allocate 6 acres of private land DN91278 & DN152135 as private ownership. No contact was made to the owner. To compound the error the land in question is designated as being owned by PCC (area section 24). Sites smaller than this were listed as private ownership, so size of the land is not the reason for this error. Within EN34 page 10 of 127 Mr Duncan 190 1187131 MM52 Derriford Community Park greater area is outlined. DN91278 & DN152135 is designated within this area. All parts are described as " Green spaces that are not accessible" to the general Westlake public. Within EN34A page 55 of 3755 surveyors "JS/ZG" state they have "Access to whole site" to conduct a Policy Area Open Space Assessment of site 9 "Derriford Community Park" on 27-Apr-15 from 11:10am for a duration of 10 (was this Minutes? Hours?). The diagram of the site accessed and assessed includes private land DN91278 & DN152135. At no point was permission requested to access private land, and at no point was permission granted to do so. Did "JS/ZG trespass to conduct the PAOSA? The whole site is assessed as nature reserve and Poole farm, DN91278 & DN152135 is neither of these. As such the cumulative score of 17 is not valid. Allocation of PLY41 boundary is now drastically different from the site 9 PAOSA area in EN34A it is based upon. PLY40 & PLY47 have reduced the areas tested in EN34A . Due to the information listed above I strongly reject DN91278 & DN152135 being included within the boundary of PLY41 and being designated as Strategic Green Space. The very basis of including DN91278 & DN152135 in SGA1 without contacting the legal owner disqualifies all future involvement. The matter of "JS/ZG" illegally accessing and assessing DN91278 & DN152135 within site 9 disqualifies all future involvement. The constant movement of the PLY41 boundary, being based on flawed site 9 assessment, which at best is only 50% the size of PLY41 disqualifies all future involvement of DN91278 & DN152135 within PLY41. By PCC designating DN91278 & DN152135 within PLY41 I would argue that the council are still exhibiting the previous issues described by the inspector in EX15 , listed above. As the inspector has stated, there is already sufficient policy to protect green space and to manage development in the national planning policy. As such no designation of DN91278 & DN152135 to be within PLY41 is required.

Remove DN91278 & DN152135 from PLY41. Do not designate DN91278 & DN152135 as any specific DEV29 category. Exclude DN91278 & DN152135 from any designation in the JLP.

79 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM52 – we note reference to Local Green Space and that the Plan does not provide any designations although such designations may appear in future development plans and Neighbourhood Plans. With that in mind it is surely for those Plans to confirm how the impact of inappropriate development will be treated as opposed to the Joint Local Plan. We note the wording at paragraph 2, sub-paragraph i). If development does take place on a green space in its entirety, then its existing function and character are not going to be retained. This part of the proposed Policy needs to be deleted. Assuming we have interpreted the proposed Modification correctly the objective of it is to ensure that development should only take Jillings Heynes Diocese of place where it is considered appropriate to do so taking into account the key criteria of i) the quality of the space to be lost/affected; and ii) the contribution the space to be lost makes 197 964187 MM52 Ed Heynes Planning Ltd Plymouth to the existing built and natural environment. That being the case, then the draft Policy (through the proposed Modification) should reflect those criteria but also take into account any public benefits that accrue through a proposed development being brought forward which may outweigh any harm through the loss of the space and/or take into account any situation where public accessibility is provided to an area of green space where there was no public access previously. In other words, where private land becomes available for public recreational use as part of a development proposal. The NPPF has a separate Section (no. 8) which seeks to ensure that planning decisions and the planning process, generally, leads to healthy communities. The Policy and Explanatory Text needs to reflect this part of the NPPF.

My comments below are to request an amended / addition to MM52 - Policy Dev 29 within MM5 Existing Policy DEV29 states Development that would result in an unacceptable conflict with the function(s) or characteristic of Strategic Green Spaces and Local Green Spaces (Plymouth Policy Area) will be resisted. In these areas development will normally only be permitted where it enhances the value of the green space, for example through sports, allotment and play provision, lighting, cafes, educational uses and sustainable transport routes. As the goal of the policy focuses on green spaces and wildlife, i am concerned that the net gain to the green space is not a permitted option. The only existing option that might add some gain is allotments. But this is possibly only marginal gain. I believe adding the option of getting a net gain for wild life for the whole site in question should be included as well. That net gain should be dependant on each site, whether the goal is to add diversity, enhance existing the local wild life or both. If some-one can actively show the whole site has a net Mr Duncan gain for wildlife from enhancements, additions and an active management plan, this should give a net gain and therefore be a permitted option for Policy Dev29 option 1. 205 1187131 MM52 Westlake To the existing policy of Policy DEV29 Development that would result in an unacceptable conflict with the function(s) or characteristic of Strategic Green Spaces and Local Green Spaces (Plymouth Policy Area) will be resisted. In these areas development will normally only be permitted where it enhances the value of the green space, for example through sports, allotment and play provision, lighting, cafes, educational uses and sustainable transport routes. Add the following content (or similar) Policy DEV29 Development that would result in an unacceptable conflict with the function(s) or characteristic of Strategic Green Spaces and Local Green Spaces (Plymouth Policy Area) will be resisted. In these areas development will normally only be permitted where it enhances the value of the green space, for example through enhancement of existing green space for net gain of site , sports, allotment and play provision, lighting, cafes, educational uses and sustainable transport routes.

MM52: Policy DEV29 and associated narrative Policy DEV29 as revised is inconsistent with the Framework. The policy now proposes a more restrictive approach to development proposals involving open space than Policy DEV29 as originally drafted. By doing so it effectively seeks to introduce a quasi-Local Green Space policy in response to the original Local Green Space designations being found not to meet the relevant tests. There is no justification for prescribing that existing open space, including the proposed ‘City Green Spaces’ and ‘Neighbourhood Green Spaces’, should not be built on unless it can be demonstrated that “the important function(s) and characteristics of the green space are retained” . Such an Emery Wainhomes approach is wholly inconsistent with paragraph 74 of the Framework (and indeed paragraph 97 of the revised Framework), which clearly allows for the development of open space Mr John 215 893384 MM52 Planning (South West) where specific criteria are met. This should be reflected in Policy DEV29. We also strongly disagree that the Plymouth Area Open Space Assessment (EN34 / EN34a) justifies a tiered Coxon Partnership Holdings Ltd. policy differentiation with a very high level of policy protection (effectively akin to Local Green Space) afforded to a very significant number of sites in the highest tier. We note from EN34a that the City Green Spaces vary significantly and therefore a blanket restrictive approach cannot be justified. Taking for example Radford Quarry (site ID: 121 in EN34a), the site is not publically accessible and is of limited (if any) value as open space. Ecology would be effectively already covered by other policies in the plan. Therefore contrary to the Council’s assertion, EN34 does not provide sufficient justification for a further highly restrictive open space policy on this site. We therefore object in principle to the proposed policy and designations. Without prejudice to our principle objection, in the event that the policy is taken forward we object to the designation of Radford Quarry as City Green Space.

MOD generally supports the proposed changes to Policy DEV29, (your ref. MM52), and the associated deletion of Local Green Spaces from the Policies Map, (your ref. PMM5). In our view, the extensive designation of sites as Local Green Space was not in accordance with the National Planning Policy Framework. However, having regard to the proposed Defence Rob redesignation of open space at RM Stonehouse as a City Green Space and the possibility that essential operational development might be required on the site, we would request that 216 1069486 MM52 Infrastructure Sanderson criterion 2 be amended to read: ‘Existing open space, which also includes designated City Green Spaces and Neighbourhood Green Spaces should not normally be built on…’ The Organisation suggested amendment would ensure consistency with criterion 1 relating to Strategic Green Spaces and takes into account the possibility that there may be unforeseen circumstances which justify development on part of a City Green Space / other open space, while making it clear that such circumstances would be exceptional.

80 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Main Modification 52. Change of Local Green Space designation in Plymouth to City or Neighbourhood Green Space. We regard the downgrading of designated Local Green Space in the JLP as significant and would ask to have this modification reversed. While we appreciate that there is agreement to add the new designation of City Green Space to some green spaces, we are worried that this designation and the Neighbourhood Green Spaces listing is not enough to protect valued wellbeing assets. There was significant local consultation on the JLP over several years in neighbourhoods and communities, and this process is outlined in the new evidence document EN31. The green spaces identified by these communities are the ones most valued by them. This was the aspect of the plan which generated most involvement, and the high level of protection given was approved both by communities and the Hoe council (as shown in the submission version of the JLP and its evidence base). We are aware that this is a pioneering level of protection not normally seen in Joint Local Plans, and that, 227 1095700 MM52 Penny Tarrant Neighbourhood whatever the designation, Plymouth City Council will protect these spaces where they can. However in the balance needed for a healthy city between green space and Forum housing/industrial development, the City/Neighbourhood Green Space protection now allocated is not enough to prevent development, however well-intentioned the Council may be. Especially if developers take plans to appeal level. We can see the logic of ensuring complete local buy-in by using Neighbourhood Forums and Plans, but this is a very complex and difficult process in a large city. While a few (3 so far) areas of the city are in the process of creating Neighbourhood Plans and will build in Local Green Space levels of protection, many of the most vulnerable areas of the city do not have this level of organisation in place. We would therefore ask that the value placed on these spaces by the people of Plymouth is respected and the modification removed so that the designation remains Local Green Space.

We welcome the proposed modifications which we consider will clarify and strengthen the plan policies and narrative. The changes are consistent with our agreed Statement of Marcus Environment 235 658611 MM52 Common Ground (SoCG) and subsequent discussions during the Examination. In particular we support the following Main Modifications: MM52 Addition to narrative text (regarding Salmon Agency policy DEV29) after paragraph 6.100 highlighting the multifunctional benefits of Green Infrastructure (i.e. flood risk, water quality, climate change adaptation and health/well-being).

The Joint Local Plan, (JLP), was a thorough and democratic exercise with enthusiastic engagement and response from communities: Peoples’ responses were significantly in favour of protecting green space, and the JLP designation as Local Green Space, (LGS), upheld this desire to preserve valued green spaces in line with citizens’ wishes. Reclassification of LGS goes against the stated wishes of respondents and is therefore undemocratic. Green spaces will be potentially jeopardized against the public’s expressed views. Reclassification runs counter to the Ministry of Housing, Communities and Local Government guidelines regarding green space to afford them a very high level of protection from redevelopment or inappropriate use , (see attached document). The public engagement process throughout the JLP allowed communities to do exactly as this recommends: “making provision for communities to identify and protect green areas of particular importance to them through the designation of land as Local Green Space”…. in line with the guidance from Ministry of Housing, Communities and Local Government. PCC has exceeded Government targets for required provision for housing, so to weaken the protection of green space (as designated in the submitted JLP) by reclassifying green space with a lower level of protection is surely contrary to the guidance set out by the Ministry of Housing, Communities and Local Government in the revised planning rule book, (July 2018), both in its implied intention and the spirit of its stated aim to afford green space “a very high level of protection from redevelopment or inappropriate use”. If Main Modification 52’s redesignation of Local Green Space as City and Neighbourhood Green Space results in an increased likelihood of developers overturning LPA’s decisions on appeal, it appears to lessen the Government’s desired protection from “a very high level”. Consequently, this decision appears in conflict with the Ministry of Housing, Communities and Local Government’s guidance. If the aim of plans is to achieve both a prosperous and healthy city, a reasonable balance between protecting green space and delivering housing and industrial development can and should be struck. Where PCC have overachieved in the delivery of the latter, (provision for future housing), the citizens’ expressed wish to protect the former, (green space), should and can be honoured without compromise or conflict. The revised City/Neighbourhood Green Space protection as the Modifications sets out is not necessarily enough to protect valued green space from redevelopment or use that is inappropriate, if decisions in favour of preserving green space can be Plymouth Open 240 893608 MM52 James Brown subsequently overturned on appeal. The expectation that communities across the city mobilize into Local Neighbourhood Forums to enable an alternative mechanism for green spaces Spaces Network to achieve LGS designation, is possibly more aspirational than practical, as in many areas, especially deprived areas (most in need of the benefits of green space), the process of setting up and running a Local Neighbourhood Forum is a considerable challenge in terms of people’s time, organization, expertise and knowledge. Moreover, in the context of having already participated in the JLP consultation and expressed their views in support of the protection of LGS, the subsequent reclassification of green space demonstrates that their stated wishes have now been challenged and overturned. This indicates a democratic deficit, which predicates against further participation through Local Neighbourhood Plans, which are a more time consuming, complex and demanding process. Local consultation on the JLP took place over several years among communities, (as shown in the new evidence document EN31). POSN and various Friends of (parks and green spaces) groups undertook numerous community engagement activities over the course of the JLP process. The predominant response from the public was they wanted to protect the city’s green spaces. The high level of protection afforded green spaces as LGS was approved both by communities and the council (as evidenced in the submission version of the JLP and its evidence base). On one site, over 170 responses were received to preserve and protect the space as a Local Green Space, (as per the JLP submission). This has now been re-classified as a Neighbourhood Green Space, which both diminishes the democratic exercise undertaken and the likelihood of long term protection in the event of an appeal by a developer.

POSN would ask the Inspector to reconsider the reclassification of LGS and reverse the decision. We would urge that the value attached to these spaces by the people of Plymouth, demonstrated through the lengthy and well participated in consultation process is respected and the public, who have already expressed their wishes, do not feel they have been ignored and that the process is ultimately undemocratic. We ask that the modification is reversed so that the green space designation supported by the city’s communities remains Local Green Space.

81 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM52 DEV29 Whilst supporting the principle I would draw to the Inspectors notice the following During the process of producing the Neighbourhood Plan the inclusion of Local Green Space in the JLP was both noticed and supported by the parish Council and the people of Woolwell. The Parish Council held a number of consultations and it was very evident that Local Green Space was very important to those people who live here. In some cases people said it was the main reason for moving here. The council was presented with petitions and supported by objections to planning applications by individuals submitting their own objections to the plans. Having identified that Local Green space was included within the JLP and being supportive of the areas identified the Neighbourhood plan was confident that the Local Green Spaces would remain in the JLP. Now that they have been removed the areas identified are clearly at risk to be developed against the wishes of those living here. Also there is no facility to review the Parish NP as it’s soon to be going to referendum. In the meantime it is an opportunity for land owners to avail themselves of submitting planning applications as there is little opportunity to review the NP. We would respectfully request that Cllr Michael 246 1004109 MM52 the inspectors re consider this. The parish Council were of the view that the assessment procedure was sound and complied with the previous version of NPPF One planning Blake application in particular that has united the Parish is an application to develop an area which is off Pinewood Drive in Woolwell. Many people have turned up to the planning meetings. There have been numerous objections and petitions with people saying how much they value and need that open space In my view the conditions expressed in paras 1 and 2 along with those in para 6.98 (to become separate Para) of MM 52 Policy Dev 29 are well satisfied. The removal of Local Green space and replacing with the modification creates difficulties for those Neighbourhood plans that are either with inspectors or awaiting referendum. They are at a disadvantage in that they can make no changes until review. Bickleigh Parish Council was encouraged to to complete its plan before the JLP and now finds itself at a distinct disadvantage There is one further concern that I have in reading the documents there several occasions where Bickleigh Village appears to be treated differently to the way other villages have been treated and I question why No explanation has been offered and in my view this can only stir the thoughts of suspicion as to why this has been done

MM52 DEV29 Removing Local Green Spaces from the JLP has and will continue to create problems when planning applications are submitted. Residents who assisted and those who Mrs Linda attended the Consultations when preparing our NP ALL stated that LGS were important factors when they had chosen where to live. It seems that any objections from Residents whose 253 1096832 MM52 Crowe lives are going to be disrupted not just at Woolwell but also at Tamerton and elsewhere are never taken on board as they are the ones who have to continue to live in what was a desirable location until the greed of the developers. MM52 DEV29 Removing Local Green Spaces from the JLP has and will continue to create problems when planning applications are submitted. Residents who assisted and those who attended the Consultations when preparing our NP ALL stated that LGS were important factors when they had chosen where to live. It seems that any objections from Residents whose 259 1096834 MM52 Mr M Crowe lives are going to be disrupted not just at Woolwell but also at Tamerton and elsewhere are never taken on board as they are the ones who have to continue to live in what was a desirable location until the greed of the developers. Rebecca MM52 Development policies DEV 29 It is important that within the modifications that this area is specified within the plan as a Green Space in order to prevent significant 263 1096845 MM52 Clayton environmental damage. This needs to be worded in far better terminology so that it doesn't take 4 people to explain it coherently

MM52 Development policies DEV 29 Deleting this policy will have a significant impact on designated Green Spaces in my area including Pinewood. Due to the inspector’s questioning of this policy and the subsequent rewrite there seems to be no protection for this area which is very significant. Bickleigh Parish Council’s Neighbourhood Plan has overlooked this area of 267 1096858 MM52 Ben Gavan local green space and it is not within the plan. This means that there is no protection for this area due to the mistake of my Parish Council. Therefore it is important that within the modifications that this area is specified within the plan as a Green Space in order to prevent significant environmental damage. Please do not destroy our beautiful village

MM52 Development policies DEV 29 Deleting this policy will have a significant impact on designated Green Spaces in my area including Pinewood. Due to the inspector’s questioning of this policy and the subsequent rewrite there seems to be no protection for this area which is very significant. Bickleigh Parish Council’s Neighbourhood Plan has overlooked this area of 271 1096861 MM52 Tara Gavan local green space and it is not within the plan. This means that there is no protection for this area due to the mistake of my Parish Council. Therefore it is important that within the modifications that this area is specified within the plan as a Green Space in order to prevent significant environmental damage. Please do not destroy our beautiful village

MM52 Development policies DEV29 Deleting this policy will have a significant impact on designated Local Green Spaces in and around my area including Pinewood at Woolwell, which 275 1191389 MM52 Larry Taylor has already been the subject of recent planning applications which gave rise to a significant objection from the parish residents. Due to the inspector’s assessment of this policy and the subsequent rewrite there seems to be no protection for this particular area and those of other Local Green Spaces, which is very disappointing and to which I object strongly.

82 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

Main Modification MM52 – Revised Policy DEV29 Objection is raised to both POLICY DEV (NEW) and its accompanying new explanatory text. The JLP no longer seeks to identify any LGS. This policy is therefore unnecessary and simply repeats that any LGS designated through other development plan documents will be subject to national planning policy. All development is in any event subject to national planning policy as the NPPF is a material consideration in all applications. It is therefore an unnecessary policy as it adds nothing to the JLP, it simply repeats the content of NPPF. Moreover, absent any LGS designations the presence of the policy is confusing. It is also prepared in the context of NPPF 2012. If the Plan remained silent, then the provisions of the more up to date NPPF 2018 as they relate to LGS would apply. In their Post Hearing Advice Note EXC15, the Inspectors gave the JLP Councils two options with regard to LGS; 1) to remove the LGS designations and undertake a comprehensive review of the LGS methodology and assessment process, or 2) re-visit the methodology and designations within the submitted JLP, taking on board the factors the Inspectors had highlighted. The JLP Councils have chosen to exercise Option 2 but have done so partially. They have revisited the designations, but have failed to revisit the methodology, or address the factors highlighted by the Inspectors as being of concern. Those factors included; a) the additional evidence prepared by the Council on LGS for the Hearings was not sufficiently rigorous; b) the use of over designation, resulting in designations being commonplace, and not limited to sites that are special in their nature (and therefore meriting policy protection); c) absence of evidence demonstrating the special and locally significant nature of the allocations; d) allocation of sites already protected wholly or in part by a multitude of other designation The LGS assessment work had not adequately considered these Pegasus (Nature Reserves, County Wildlife Sites, Conservation Areas, TPOs, allotments, woodlands, biodiversity networks); e) scale of sites being inappropriate for designation; and f) failure to Mr Keith 285 1096040 MM52 Planning A&M Trust consult or robustly address landowner comments with regard their land holding None of these factors highlighted by the Inspectors as needing to be addressed, have been tackled with Fenwick Group new evidence. Moreover, the principal document relied upon by the Council to justify the reshuffling of the green space designations (EN31 (rev) para 1.7 confirms), is the Plymouth Policy Area Open Space Assessment (“ POSA ”) from February 2017 (EN34). This document was already before the Inspectors when the Hearings were held. It was deemed insufficient then to address the Inspectors’ concerns (as set out in a) to e) above), and absent any change to this document or any additional evidence, it is impossible to understand how the JLP Councils consider that the Inspectors’ comments are addressed by re-submitting the same information. It is tantamount to saying that the Inspectors were simply wrong to conclude as they did in EXC15. The POSA (EN34) was not prepared as an evidence base for the purpose of categorizing or assessing green space across the JLP area. Section 2 of the POSA sets out the purpose of the study, stating at para 2.3 that it is to be used: to draw conclusions on the provision and state of open space; to understand variations in open space; and to understand the challenges facing open space. It is not a green space designation tool. It contains no assessment of landscape value, ecological value, or wider connectivity value. Moreover, it is an ‘open space’ assessment, not a ‘green space’ assessment. These terms have different meanings and apply to different sites. They are not interchangeable. Regarding MM52 therefore: i) the POSA ‘evidence’ base is not new. It has been examined before and found insufficiently robust for supporting the previous policy. Renaming the policy and recategorizing the green space, does not make the evidence base any more robust. ii) The evidence provided does not seek to address any of the five concerns set out in the Inspectors’ advice note (EXC15). In failing to do this, the Inspectors may feel duty bound to continue to find this aspect of the plan unsound. iii) MM52 introduces an unnecessary policy regarding the status of LGS, which simply replicates the existing content of NPPF.

The amendments here have a large impact on the Pinewood area of Woolwell Bickleigh Parish Council’s Neighbourhood Plan has failed to include this area as a Local Green Space, Mr Barrie 288 673928 MM52 through omission The protection otherwise offered is no longer available. It is clearly too late to change this but this policy, as it is currently stands, carries little or no weight in Spencer protecting the area from any planning application It seems unfortunately, to say the least, that the local residents suffer as a result of the Parish Council’s error

Mr Ed Donna 292 833927 MM52 EJFP Planning Please see attached Persse Forshaw

MM52 Development policies DEV29 Deleting this policy will have a significant impact on designated Green Spaces in my area including Pinewood. Due to the inspector’s questioning of this policy and the subsequent rewrite there seems to be no protection for this area which is very significant. Bickleigh Parish Council’s Neighbourhood Plan has overlooked this area of 300 1191484 MM52 R Pengelly local green space and it is not within the plan. This means that there is no protection for this area due to the mistake of my Parish Council. Therefore it is important that within the modifications that this area is specified within the plan as a Green Space in order to prevent significant environmental damage.

MM52 : Having green space in a built up residential area is essential to residents wellbeing and for the environment. Woolwell's Pinewood area is an invaluable green space, used by all of the community. The area is used for recreation but also provides a natural habitat for a whole ecosystem of life including herd of deer. Removing the protection of this green space 310 1191513 MM52 Emma Hogg not only inhibits the well-being of all residents but also endangers more species of birds/ deer/ rabbits and many other forms of wildlife by removing their natural habitats. This area could be developed in future to provide a learning platform for school children to get much closer to nature and should under no circumstances be built on.

83 Comme Consultee Full Name Organisation Full Name Organisation Mod Ref. Comment 1 and 2 nt ID ID (Agent) (Agent) (Consultee) (Consultee)

MM52 Dev 29 Whilst supporting the principle we would draw to the Inspectors notice the following. During the process of producing the Neighbourhood Plan the inclusion of Local Green Space in the JLP was both noticed and supported by the parish Council and the people of Woolwell. The Parish Council held a number of consultations and it was very evident that Local Green Space was very important to those people who live here. In some cases people said it was the main reason for moving here. The council was presented with petitions and supported by objections to planning applications by individuals submitting their own objections to the plans. Having identified that Local Green space was included within the JLP and being supportive of the areas identified the Neighbourhood plan was confident that the Local Green Spaces would remain in the JLP. Now that they have been removed the areas Steve identified are clearly at risk to be developed against the wishes of those living here. Also there is no facility to review the Parish NP as it’s soon to be going to referendum. In the Bickleigh Parish 318 1007783 MM52 Clement- meantime it is an opportunity for land owners to avail themselves of submitting planning applications as there is little opportunity to review the NP. We would respectfully request that Council Large the inspectors re consider this. The parish Council were of the view that the assessment procedure was sound and complied with the previous version of NPPF One planning application in particular that has united the Parish is an application to develop an area which is off Pinewood Drive in Woolwell. Many people have turned up to the planning meetings. There have been numerous objections and petitions with people saying how much they value and need that open space. In our view the conditions expressed in pares. 1 and 2 along with those in para 6.98 (to become separate Para) of MM 52 Policy Dev 29 are well satisfied. The removal of Local Green space and replacing with the modification creates difficulties for those Neighbourhood plans that are either with inspectors or awaiting referendum. They are at a disadvantage in that they can make no changes until review. Bickleigh Parish Council was encouraged to complete its plan before the JLP and now finds itself at a distinct disadvantage

MM52 Development policies DEV 29 Deleting this policy will have a significant impact on designated Green Spaces in my area including Pinewood. Due to the inspector’s questioning of Glenn this policy and the subsequent rewrite there seems to be no protection for this area which is very significant. Bickleigh Parish Council’s Neighbourhood Plan has overlooked this area of 363 1191554 MM52 Pengelly local green space and it is not within the plan. This means that there is no protection for this area due to the mistake of my Parish Council. Therefore it is important that within the modifications that this area is specified within the plan as a Green Space in order to prevent significant environmental damage.

MM52 Mr Ben 3 961443 Please see attached. EN31 (rev) Stafford Rockspring Mr Alistair Boyer 336 1191547 MM54 Barwood Please see attached letter. MacDonald Planning (Plymouth) Ltd Ms Victoria SUPPORT with reservations. I welcome the modifications to point 2 with regards to cumulative impacts,and impacts in terms of landscape capacity. I cannot support the deletion of 386 1095125 MM55 Tanner- heritage assets from point 2. Tremaine Pegasus Mr Keith 283 1096040 PMM4 Planning A&M Trust Please see attached. Fenwick Group We do not agree with the conclusion of the SEA based on current wording of this new policy. We advise that you strengthen the policy as done for TTV6, by referring to the South Hams 71 1014005 SEA (MM30) Carol Reeder Natural England SAC, the fact that the site is located within the Landscape Connectivity Zone as identified in the emerging South SAC SPD and that the location, layout and design of the new development should support the connectivity of the landscape for Greater Horseshoe Bats. 73 1014005 SEA (MM51) Carol Reeder Natural England The final column refers to historical assets but should refer to ecological assets instead.

70 1014005 SEA (Para 1.5) Carol Reeder Natural England Para 1.5: Minor point – typo: “affect” should be “effect”.

84 APPENDIX ONE: JLP COUNCILS SUMMARY ANALYSIS OF REPRESENTATIONS

Over-arching comments

1. A total of 1,337 representations were received on the Main Modifications to the Joint local Plan. 55 of these representations were expressing support for the Main Modifications.

2. It should be noted that a very large proportion of the representations were received from residents of Dartington, and of Woolwell, following the circulation of material around these communities encouraging people to make representations on specific Main Modifications. In total, around 1000 of the total numbers of representations were received from residents of Dartington, with nearly 100 received from residents of Woolwell. All of these representations raise essentially identical matters

3. It should also be noted that some representations relate to the fact that the JLP is using the NPPF 2012. It is worth noting that the JLP is being examined under the transitional arrangement provisions of paragraph 214 set out in Annex 1 to the revised NPPF, which makes clear that plans caught by the transition arrangements should be assessed against the previous 2012 NPPF. The Government’s NPPG website makes clear that this includes the application of the previous Planning Practice Guidance.

4. The sections below provide a breakdown by Main Modification of all the comments received, the main points raised and the Councils’ brief response to those points. It is hoped that this analysis will assist the Inspectors in their consideration. In summary:  Several Main Modifications received no representations at all, or only received comments in support. These were MM6, MM9, MM10, MM12, MM13, MM16, MM17, MM18, MM19, MM20, MM25, MM28, MM29, MM32, MM37, MM43, MM44, MM45, MM47, MM49, MM53.

 The Dartington representations raise 5 points summarised below:, o the overall level and distribution of housing across the whole plan area (not the subject of a Main Modification), o concerns about the new Dartington Policy, o the removal of sustainable villages in the AONB from Fig 5.2, o comments on DEV2 (concerning air quality) and o comments on DEV28 (concerning biodiversity).

 The Woolwell representations concern two matters; o the change to clause 2 of PLY44 concerning the timing of the commencement of development in relation to the Woolwell to the George highways scheme, and o the removal of the Local Greenspace Designation from Pinewood Drive.

 Other matters of note in the representations include: o Concern over the removal of sustainable villages in the AONB from Figure 5.2, o Concern over the removal of Local Greenspace Designations o Some concern from the development industry over the new urban fringe policy and greenspace designations replacing Local Green Space Designation.

o Some concerns over the changes to TTV1, TTV30 and TTV31, and the introduction of the new rural exceptions policy and how these policies will work together.

5. The Councils do not consider that any of these representations raise any matters which were not the subject of discussions at the Hearings or made previously through written representations and were therefore, fully explored in evidence presented to the Examination. They do not consider that any matters related to the soundness of the plan have been raised in representations.

6. In a small number of cases, the Councils would be happy to agree to some minor changes to the Main Modifications, as further Additional Modifications if this was considered appropriate. These potential changes are collated in APPENDIX TWO to this paper.

7. We would also like to draw to the Inspectors attention para 5.27, 8th bullet point, of the PINS Procedural Practice in the Examination of Local Plans sets out that Inspectors may be able to recommend Main Modifications without further consultation, if for example the scope of the consultation already undertaken on related MMs has adequately addressed the point. The Councils do not, however, consider that any changes suggested in representations fall into this category. Analysis of the Representations

Representations not related to any Main Modification:

8. There are 3 representations in this category, none of which directly concern the Main Modifications as published.  One is from Highways England which does not raise any new matters, and restates a matter that HE brought to the hearing session which was not in its original representations on the plan.  Another alleges a policy omission whilst another restates representations previously made about green space boundaries.

9. As none are representations on the Main Modifications themselves they are not considered to be valid objections at this part of the process.

MM1 Spatial Strategy – Policy SPT1

10. There are 5 representations in this category, 3 of which are from representatives of the development industry. Two representations do not directly concern the Main Modifications as published and are therefore not valid representations.  The changes to the plan set out in MM1 were discussed at the hearings and agreement was reached with 3 of the 4 participants that raised concerns with this part of SPT1, as set out in HM2 (see EXD5i & 5ii)

 The other objections do not raise new issues that were not heard at the hearing, other than the Sutton Harbour Holding’s response seeks additional narrative which in the view of the Councils is excessive detail for a policy which is about establishing overarching principles from which the more detailed site allocations and development policies are derived (as explained in EXD44).

Councils’ Overall Response

11. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM2 Spatial Strategy – Policy SPT2 narrative

12. There are 4 representations to this modification, 3 of which support the changes.  The single objection does not agree with the additional clarity that the changes were intended to bring, and which were the outcome of discussions at the hearings – see HM5 and HM6 (EXD5i).

Councils’ Overall Response

13. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM3 Spatial Strategy – Policy SPT3 and related amendments to narrative and Annex 2

14. A total of 223 representations were received to Main Modification MM3. However, 211 of these representations have been made by residents of Dartington following a circular that was passed around the settlement. A total of 216 of the representations to MM3, including all of the representations from Dartington, did not raise matters concerned with the actual Main Modification. 8 representations were received from representatives of the development industry, 4 of which raised issues that were not concerned with the Main Modification being consulted on.  The 211 representations from Dartington objected to the addendum to the Housing Topic Paper (TP3(rev2)). They raised the point that the Housing Topic Paper explained that the distribution of development across the JLP area showed that some housing need arising in West Devon was being distributed to Plymouth and South Hams, and also raised concerns about the overall level of housing need being set out in the plan and the amount of housing being allocated on sites in Dartington. All of these matters were set out in evidence presented alongside the submitted JLP and in evidence prepared for the hearings. The matters raised were discussed in depth during the hearings. The changes to MM3 do not change the distribution of housing as set out in the submitted plan or in the evidence presented to the Examination – the figures presented in the JLP and in the addendum to the Housing Topic Paper (TP3(rev2)) simply update the housing position to the 2017 monitoring point, and include consequential amendments to the figures as requested by the Inspectors. Therefore, the Councils consider that the matters raised in these representations do not concern the Main Modifications set out under MM3.

 PCL Planning on behalf of Baker Estates comment that the changes to the plan set out in MM3 do not set out who will be responsible for monitoring development in the Policy Areas. It should be noted that this point regarding governance of the JLP was discussed as part of the Hearings and points were made in the Councils’ Matter Statement 3. Information was also presented in the Governance Topic Paper (TP6(rev)), setting out that a Joint Local Plan Team will be created as a joint team operating across all three Councils and that that team would be responsible for producing joint monitoring reports.

 Walsingham Planning on behalf of Land Value Alliance make comments in relation to the Policy Area approach, and also regarding the JLP 5 Year Land Supply at the point of adoption. It should be noted that neither of these elements of the JLP are subject in principle to Main Modifications, that the figures that have been used to update the JLP through MM3 were discussed at length during the Hearings including giving participants multiple opportunities to analyse the 5 Year Land Supply position, and that the new figures simply update the JLP to the 2017 monitoring point along with any consequential amendments as required by the Inspectors. It is not therefore considered that there points are valid.

 White Young Green on behalf of Bloor Homes set out a range of concerns with the Housing Topic Paper addendum and the changes to SPT3 and accompanying text and figures. However, all of these concerns, which deal with the OAN, the requirement for new homes in the TTVPA, and the supply of new homes in the TTVPA attempt to re-open discussions that were conducted at great length during the hearing sessions. It should be noted that the Housing Topic Paper addendum simply updates the original Housing Topic Paper to the 2017 monitoring point, using figures that were presented to and discussed at the hearings, and also incorporates consequential amendments required as a result of other Main Modification changes to the plan. The OAN is not subject to a Main Modification, nor is the housing requirement for the TTVPA, nor is the distribution of housing supply across the TTVPA. The representation also goes to great lengths regarding the soundness of the OAN calculation, the detailed nature of supply across the whole plan area and suggests a number of fundamental changes to the housing need and supply elements of SPT3. Again, it seems that WYG are attempting to re-open discussions that took place during the Hearings without presenting any new information, when the principle of these matters are not subject to Main Modifications. It is therefore considered that these representations are not valid.

 Place Land object to the lower target for the Sustainable Villages included in the land supply figures under MM3. It should be noted that the allowance has reduced as a result of the removal of sustainable villages in the AONB from the category, and the consequential lower assessment of the number of homes which may come forward from this source over the plan period, as required by the Inspectors in the Post Hearing Advice Note. It should also be noted that Place Land are mistaken in assuming that the Sustainable Villages allowance is a target. It is not – it is an informed assessment of the number of new homes which might come forward from this source. This calculation, along with the calculation of the windfall allowance, is set out in the Housing Topic Paper.

 Linden Homes make representations which set out a detailed critique of the Councils’ 5 Year Land Supply positions as set out in the Main Modifications updates to figures, and also attempt to apply elements of the revised NPPF and PPG to the Joint Local Plan. It should be noted that the figures used to update the JLP through MM3 were all available at the time of the hearings into the Joint Local Plan, and that hearings time was scheduled for all of these discussions to take place. The 5 year land supply and evidence underpinning it was thoroughly examined during the course of the examination hearings. The Inspectors gave developers/objectors a number of opportunities to challenge the 5 year land supply and the supporting evidence through discussion at the hearing sessions, and by requesting that developers/objectors submit to the examination an alternative 5 year land supply position to

be discussed at the final housing sessions to establish whether there were any areas of disagreement. No such challenges to the 5 year supply and its evidence were forthcoming from any objectors/developers at any point, and therefore the hearings closed in agreement on the supply contained in the 5 year supply. The 5 year supply figures contained in the MM consultation are merely the amendments to the 5 year supply positions as a direct result of the changes agreed during the hearings and as a result of the Inspector’s post hearing advice note (EXC15). The MM consultation does not represent another opportunity to re- examine the same evidence examined during the hearings. Furthermore, the JLP is being examined under the transitional arrangement provisions of paragraph 214 set out in Annex 1 to the revised NPPF, which makes clear that plans caught by the transition arrangements should be assessed against the previous 2012 NPPF. The Governments NPPG website makes clear that this includes the application of the previous Planning Practice Guidance. These representations are not therefore considered to be valid.

 Persimmon Homes comment that there should be a requirement for the Councils to discuss with Cornwall Council the possibility of bringing forward sites in Saltash to meet housing needs in the Plymouth HMA should delivery fall away. Persimmon suggest that the changes set out in MM3 show that the housing requirement for the TTVPA cannot be met – this is not the case and it is not clear how Persimmon have arrived at this conclusion. To be clear, the information accompanying SPT3 set out under MM3 show that the housing requirements can be met in full across the whole plan area. There is no need for the Councils to look to Saltash to meet needs. Any such discussions would be conducted through the Duty to Cooperate in the light of assessments undertaken at the first review of the plan. It should also be noted that Persimmon raised very similar points in their representations on the Reg 19 version of the JLP and these matters were discussed at the hearings into the plan. Therefore, it is not considered that these representations are valid.

 Emery Planning on behalf of Wain Homes make comments regarding the distribution of housing across the whole plan area and the basis of the Policy Area approach. They also suggest that the new provisions set out in the 2018 NPPF should be applied to the JLP. It should be noted that the geographical basis for the monitoring of 5 YLS was discussed at length during the Hearings, after which Wain Homes and the Council submitting additional evidence to the Inspectors. These matters have been fully considered in the Examination so far. The NPPF is clear that the JLP is in transition arrangements and therefore is being examined against the 2012 NPPF. The provisions of the revised NPPF do not therefore apply to the JLP. In any case, the revised PPG makes allowance for local authorities with joint plans, where it is not clear whether monitoring will be undertaken at whole plan or single LPA level, to make clear to MHCLG how they will monitor going forwards. MHCLG have confirmed to the Councils that this provision will apply to the PSWDJLP once it has been adopted. It is therefore considered that these representations are not valid.

 One representation has highlighted that Figure 5.1, which sets out summary housing and employment land figures for the TTVPA has not been updated in line with the figures set out under MM3. In particular, the allowance for development in the Sustainable Villages has not been updated. This representation appears to be correct It is considered that these changes can be made as consequential amendments as the revised figures are part of the modifications MM3 and MM5 that have been already been consulted on. It is therefore

considered that these consequential amendments could be picked up as minor (additional) modifications, if the Inspectors agree (see APPENDIX TWO)

Councils’ Overall Response

15. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM4 Spatial Strategy – housing trajectory information throughout plan, and consequential amendments to housing supply information throughout the plan

16. A total of 3 representations were received to this Main Modification, all from representatives of the development industry.  Rockspring Barwood comment that the number of dwellings to be provided at Woolwell during the plan period is not the total number of dwellings to be provided on the site, but represents the number assessed through the trajectories that will be built by 2034. They repeat the points made during hearings that they believe development will start earlier than assessed and therefore more homes will be built during the plan period. These matters were discussed during the hearings, including discussing why the Councils do not feel that they can rely upon the development starting within the first 5 years of the plan. It is clear that the trajectories are an assessment at a point in time, and will be updated each year as part of the monitoring of the plan – if Woolwell does indeed commence earlier than assessed this will be picked up through monitoring and through the first review of the plan.

 Linden Homes have also objected to MM4 as part of their objections to the OAN and housing supply presented in the plan. The Councils’ response to their points is set out above under MM3.

 Baker Estates question whether the Inspectors identified the correct site to be deleted from the JLP allocations, and request that site TTV15.1 be re-instated to the plan. However, it is clear that the Inspectors were requiring that allocations within the AONB should be removed. TTV15.1 was correctly identified in Policy TTV15 of the JLP, is within the AONB, and has planning consent. The inspectors are examining the JLP, not the Policies Map, and therefore the references in the Post Hearing Advice note refer to the plan itself. It therefore seems clear that the Inspectors intended TTV15.1 West Alvington Hill to be removed. It is clearer still given that the Post Hearing Advice Note makes clear that sites with planning permission (such as West Alvington Hill) could be retained in the land supply. It is not considered that TTV15.1 should be reinstated to the plan. Baker Estates also commented that the Councils were required to produce further evidence on the suitability of sites in the AONB. This is incorrect – the Post Hearing Advice Note sets out the Inspectors requirement that the allocations be removed from the JLP with the exceptions as set out in paragraph 5 of the Note. The Councils have made these modifications.

MM5 Spatial Strategy – Policy SPT4, para 3.38, fig 3.6, and consequential amendments

17. A total of 3 representations were received to this Main Modification, one of which was in support.  Highways England’s representation relates to modifications that were published as M325- 329 (EXC10Ai), in January 2018 before the hearing sessions. They confirm that they “do not consider it necessary that the transport evidence base is revisited.” HE focus is on the

OAN, but the plan’s actual provision for employment land is summarised, and that is a significant reduction in supply. No soundness issues are raised by HE.

 The other representation highlights a consequential amendment needed to para 5.122 of the JLP as a result of the deletion of TTV29.10 (MM30). The Councils believe that this amendment can be made as an additional modification as it is purely a matter of mathematics and concerns matters that have been consulted upon under other Main Modifications. (See APPENDIX TWO)

Councils’ Overall Response

18. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required, other than the addition of the consequential amendment described above.

MM6 Spatial Strategy –para 3.34 (SPT4) and Annex 2

19. No representations received

MM7 Spatial Strategy – Policy SPT6 and figure 3.9

20. One representation received regarding this Main Modification.  The representation supports the modification but seeks a boundary adjustment for the proposed new Dartington policy to include The Shops car parks. MM7 does not consider the boundaries of the Dartington policy therefore no soundness issues raised.

Councils’ Overall Response

21. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM8 Spatial Strategy – Policy SPT11 and associated narrative

22. A total of 24 representations were received regarding this Main Modification, 6 of which supported the changes.  The majority of representations are from Woolwell community members, relating to the simplification of the narrative in para 3.91 where the list of parks is removed, and in particular Woolwell Community Park. The representations seem to suggest that the requirement for the Woolwell Community Park has been removed by the Main Modification, which is clearly not the case as the provisions remain within Policy PLY44.

 The RSPB raise issues around the provisions of SPT11 dealing with the mitigation of impacts. In response, the Councils believe that the modifications to SPT11 reflect the discussions that took place at the hearings that the RSPB attended. The policy provides a strategic framework for the consideration of the natural environment, and many of the matters picked up by the RSPB deal with the detailed mitigation of proposals which cannot be captured in a strategic policy. It should also be noted that all of the Main Modifications were subject to HRA, which the RSPB have not commented on. It is not considered that their representation raises any soundness issues.

 One representation also comments on the use of the words “conserving and enhancing” in point 4 of SPT11. In response, it should be noted that these changes were discussed at the hearings and the precise wording agreed with the Inspectors during the Hearings and with Natural England. It is not considered that these representations raise any soundness issues.

Councils’ Overall Response

23. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM9 Strategy for Plymouth Policy Area – Policy PLY5 and associated narrative

24. There were no representations received on this Main Modification.

MM10 Strategy for Plymouth Policy Area – Strategy for Plymouth Policy Area – Policy PLY6

25. One representation was received from the Environment Agency, supporting the changes to the JLP.

MM11 Strategy for Plymouth Policy Area – Policy PLY15, PLY27, PLY28, PLY30, PLY31, PLY36.2, PLY36.3; Strategy for TTV Policy Area – Policy TTV11.1, TTV18, TTV21

26. One representation was received, which raises issues already aired at the hearings and is not an objection to the actual modification proposed.

Councils’ Overall Response

27. The Councils do not consider that the representation raises any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM12 Strategy for Plymouth Policy Area – Policy PLY25

28. No representations received

MM13 Strategy for Plymouth Policy Area – Policy PLY40

29. No representations received

MM14 Strategy for Plymouth Policy Area – Policy PLY44

30. A total of 42 representations were received regarding this Main Modification, 41 of which were from the Woolwell local community and concerned with the change that relates to development before implementation of A386 Woolwell to the George Junction Transport Scheme.  It should be noted that these modifications were published before the hearings –see M84 modified (EXC10Ai); M85 (EXC10A); M86 (EXC10A); M87 (EXC10A), and were discussed at length with the developers and others present at the hearings. These representations do not raise any issues that were not discussed at the hearings. It should also be noted that the change to PLY44 simply enables the consideration of traffic impact to be undertaken at the point an application is submitted, using the most up to date information available. It does not allow development to take place ahead of completion of the Woolwell to the George highway scheme, and development would only take place if supported by a detailed

transport assessment.

 Rockspring Barwood support the changes to PLY44, but note that one element of the Statement of Common Ground, concerning maximising opportunities for on-site energy generation, has not been followed through. Barwood ask for PLY44(9) to be deleted. This matter was discussed at the Hearings during those sessions dealing with PLY44. Although this was an oversight, it clearly does not raise soundness issues, was discussed at the hearings, and was not pursued by the Councils through the modifications set out in EXC10A and EXC10Ai which were available at the time PLY44 was discussed at the hearings. Barwood did not choose to raise the matter during the hearings despite having had these opportunities. It is the view of the Councils that the provisions dealing with on-site energy generation are setting out a position that attempts to ensure that such matters are discussed as part of a planning application process.

Councils’ Overall Response

31. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM15 Strategy for Plymouth Policy Area – Policy PLY46.13

32. A total of 5 representations were received to this Main Modification, of which 2 were in support.  3 representations set out concerns that re-provision of the sports pitches may not be suitable. The Councils consider, however, there is sufficient safeguard in the policy and Policy DEV3.

Councils’ Overall Response

33. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM16 Strategy for Plymouth Policy Area – Policy PLY51 and associated narrative

34. No representations were received concerning this Main Modification.

MM17 Strategy for Plymouth Policy Area – Policy PLY58.2

35. No representations were received concerning this Main Modification.

MM18 Strategy for Plymouth Policy Area – Policy PLY58.18

36. No representations were received concerning this Main Modification.

MM19 Strategy for Plymouth Policy Area – Policy PLY59.12

37. 2 representations were received from landowners, both in support of the Main Modification

MM20 Strategy for Plymouth Policy Area – Policy PLY60.11

38. No representations were received concerning this Main Modification.

MM21 Strategy for TTV Policy Area – Policy TTV1 and consequential amendments

39. A total of 6 representations were received on this Main Modification, 3 of which supported the change to the JLP and generally welcoming the role of Neighbourhood Plans being identified and the use of the SPD to set the principles.  One representation from LVA relates to the relationship between TTV1 and Fig 5.1. The comments raised, however, do not relate to the changes actually made to the JLP by the Main Modification and therefore are not valid.

 One representation by Emery Planning on behalf of Wain Homes suggests that the wording of paragraph 5.5 is ambiguous and that it fails to recognise that settlement boundaries will be set out in a subsequent DPD. The Councils do not consider that the wording is ambiguous as it is clearly set out that TTV31 deals with development in the countryside. In addition, the reference to SPD in paragraph 5.5 refers to guidance to be set out for Neighbourhood Plans as to how they should go about defining settlement boundaries – it does not refer to the Settlement Boundaries that the Councils will set out in a DPD.

Councils’ Overall Response

40. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM22 Strategy for TTV Policy Area –Policies TTV4, TTV7, TTV12, TTV16, TTV20, TTV25 and consequential amendments

41. A total of 3 representations were received on this Main Modification, one of which was in support.  One representation relates to proposed Spatial Priority SP3 (Kingsbridge), and in particular the provision relating to road links. The reason for MM22 being a Main Modification was given the conversion of what were previously Policies (TTV4, 7, 12, 16, 20, 25) to Spatial Priorities. However, on the guidance of the inspectors, where the Councils would have otherwise been promoting an Additional Modification but there was also a Main Modification being proposed relating to the same policy, the Additional Modification was to be incorporated into the Main Modification for the sake of clarity. The reference to key road links, something requested in a representation from a local group, and modified in discussion with another local group, was such a modification. Were it not for the more fundamental change (converting a policy to Spatial Priority) it would have been consulted upon as an Additional Modification. Although not necessary for soundness the change was something the Councils were happy to do. This discussion is set out in EXD5v (HM27) and EXC10A (M146). The latest representation suggests a further amendment about listing all the relevant roads, which is considered too detailed. However, we would be happy to make the provision more generic by removing the words ‘the A381 link to Totnes’, if the Inspectors decide that it would constitute an additional modification (see APPENDIX TWO).

MM23 Strategy for TTV Policy Area – Policy TTV6 and associated narrative

42. A total of 5 representations were received on this Main Modification, 2 of which were in support.  Natural England has already signed a Statement of Common Ground (SCG6) about the changes to TTV6 that they were seeking. Its representation relates to the proposed modification to TTV6.9 which was put forward in response to the representations of South

Devon AONB and a local resident (EXC10A, M129). It seeks some additional terminology given an emerging SPD for the South Hams SAC. This is not a soundness issue, although we would be happy to make an additional modification if the Inspectors were to consider that the change was minor (see APPENDIX TWO).

 The landowner Premier Marinas broadly supports the modifications, albeit not the change to para 5.35 which refers to a design code. This was agreed in a Statement of Common Ground with Historic England (SCG4) and published in EXC10A (M133) before the hearings and not challenged during the hearing sessions where the policy and the then proposed modifications were discussed. Indeed a design code was submitted with the planning application and planning permission has been granted. Notwithstanding the planning status of the site, it remains a reasonable aspiration to incorporate in the narrative after the policy, it could become relevant if a new application is submitted, and does not raise soundness issues.

 Other concerns that Premier Marinas maintain are not considered to be soundness issues. These concerns were fully aired in the hearings and no new issues are raised.

 Other representations express support, one questioning some of the changes to the development numbers and uses (these were considered fully at the hearings and subject to HM34, EXD5vi).

Councils’ Overall Response

43. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM24 Strategy for TTV Policy Area – Policies TTV8 and associated narrative

44. A total of 3 representations were received, one in support  2 representations are concerned with removing the requirement for improved road and junction connections to the south of the A38. These issues were discussed at length at the hearing sessions and it was established that the key issue was addressing the AQMA in Ivybridge, and that there was no justification for additional road connections to the south of the A38.

 Concern is also expressed about changes to employment figures. These were also discussed at the hearing, and the Main Modification brings the policy into alignment with the consent for the site, as detailed in EXD5vi (HM35).

Councils’ Overall Response

45. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM25 Strategy for TTV Policy Area – Policies TTV9

46. One representation was received on the Main Modification, supporting the changes – although seeking an extension of the site.

Councils’ Overall Response

47. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM26 Strategy for TTV Policy Area – Policy TTV13 and associated narrative

48. A total of 4 representations were received on the Main Modification, one of which supports the changes.  This policy had extensive discussion at the hearings and the modifications came from those discussions. No new issues or soundness issues are raised.  Natural England’s comments are on provisions they themselves requested previously and which the JLP Councils agreed to. The changes were published in EXC10A before the hearings (see M147 and M149).

Councils’ Overall Response

49. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM27 Strategy for TTV Policy Area – Policy TTV22 and associated narrative

50. A total of 6 representations were received to this Main Modification, all objecting to the changes.  One of the landowners supports the increase in the housing allocation but not the changes to para 5.91. The para emerged directly from discussions at the hearing sessions to amplify the proactive approach the JLP Councils are seeking to secure an appropriate mix of uses. It is not part of the policy itself and raises no soundness issues, and the matters raised are not based on any new material that was not discussed during the hearing sessions

 Natural England raise some detailed points regarding the wording of the changes. In response the Councils would point out that Point 5 is exactly the wording that Natural England agreed in their SOCG. We do not agree that there is a lack of clarity in the revisions to point 1.

 There are objections also to the increase in housing numbers, on the basis of the expansion of the site of TTV22. It should be noted that no change to the site boundary is proposed in these Main Modifications, nor in the Policy Map Modifications consulted upon. The increase in numbers reflects the discussions that were had at the hearings, where the potential for housing to be delivered on both parts of the site was discussed. The supporting text to the policy now sets out there may be the potential for housing to be delivered on the northern part of the site (dependent upon the details of the scheme being acceptable under TTV22 and policies in the rest of the JLP) and the overall numbers have been increased slightly as a consequence. Concern is also raised about the housing being mainly on the southern part of the site. This, however, is no different to the submission stage and was not introduced through the MM, and therefore it is not considered that this point is valid. Mitigation provisions are supported but there is some concern over deliverability and removal of the 90m buffer requirement. The landscape buffer was discussed at length during the hearings, and it should be noted that the need for a landscape buffer will now be determined by the Landscape Value Impact Assessment. The landscape buffer will therefore be determined

based upon detailed evidence including the landform of the site, and therefore in some places could well be more than 90m. All of these matters were discussed during hearing sessions, and it is not considered that any points of soundness are raised.

Councils’ Overall Response

51. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM28 Strategy for TTV Policy Area – Policy TTV24.1; TTV24.2; TTV29.15

52. No representations were received on this Main Modification

MM29 Strategy for TTV Policy Area – Policies TTV24.5

53. No representations were received on this Main Modification

MM30 Strategy for TTV Policy Area – Policy TTV29.4, TTV29.5, TTV29.10 and associated narrative

54. A total of 219 representations were received on this Main Modification, 214 of which were from members of the community in Dartington following a circular that was passed around the settlement. Representation were also received from Dartington Hall Trust, Natural England, and Historic England.  The representations from members of the Dartington Community all object to the overall housing provision made in Dartington, including the allocations at Sawmills and Broom Park which are not subject to this Main Modification. Objections are also made regarding the 120 dwellings identified in the new Dartington Policy in the context of the overall amount of development being proposed. Some of these points do not relate to this Main Modification and are not therefore valid. Points relating to the amount of development identified through the new Dartington Policy do not raise any issues that were not discussed at length during the hearing sessions which looked at Dartington, and in addition it is considered that the new policy sets out a range of considerations which need to be addressed through the Estate Framework which will address many of the points raised.

 Natural England raise issues regarding the Dartington policy, and suggest that additional provisions are required with reference to Greater Horseshoe Bats, as are provided in TTV6. In response, it should be noted that the new Dartington policy is not a site allocation policy, as is TTV6. It is an area policy which sets out how development on the Estate should be considered with a clear link to the Estate Framework. It is considered that the provisions sought by Natural England could be brought forwards through the Estate Framework, as this will set out the amount and location of development and is therefore the correct place to look at how that development should relate to the habitats of the bats. Other policies in the JLP will also apply to these considerations. It is not therefore considered that this representation raises any soundness issues.

 Historic England have submitted representations objecting to the inclusion of the 120 dwellings figure in the new Dartington policy. They have gone on to suggest alterations to the policy which they say would be needed if the 120 dwelling figure is to remain. The Councils make the following responses to the points raised by Historic England:

o It is disappointing that Historic England have chosen to make these comments at this time. The new Dartington policy was discussed at length during the Hearings, with Historic England present, and the inclusion of the 120 dwellings figure was a key part of those discussions. o Moreover, in order to gain a sense of the Dartington Hall Estate and its sensitivities in relation to the potential for new housing development, the Inspectors conducted a site visit which Historic England also attended. o At no time during these discussions did Historic England suggest that amendments of the kind now being discussed would make the 120 dwelling figure acceptable to them. o Moreover, Historic England are signatories to a Statement of Common Ground with the Councils and the Dartington Hall Estate. The Statement of Common Ground contains two versions of the new Dartington policy – one which includes the 120 dwellings figure as agreed by the Councils and Dartington Hall Estate, and one which is identical in all respects except that the 120 dwelling figure is omitted. This version of the policy is the one endorsed by Historic England. It is therefore notable that at the time the Statement of Common Ground was signed in February 2018, Historic England were objecting to the inclusion of the 120 dwellings figure, but were fully aware of the alternative version of the policy including the figure. If Historic England are of the view that there are changes to the policy that would mean that they could accept the dwellings figure, it is disappointing that they did not suggest those amendments at the time the Statement of Common Ground was produced, enabling agreement of the changes with the Councils and the Estate and saving time in the Hearings. o It is not correct to state, as Historic England do in their email, that the “the informal view of the JLP Councils is that they do not fundamentally disagree with any of the points raised or modifications suggested”. The Councils do not accept that the changes are necessary to make the policy sound, and instead believe that the policy as presented in the Main Modification is sound and does not require any changes. The Councils have in fact suggested to Historic England, that an appropriate way for the extra detail on the application of the policy and the development of the Estate Framework to be provided could be through the SPD which is being prepared. In the SPD, these matters and in fact more detail could be provided to show precisely how the historic environment on the estate should be considered. o In addition, in recent dialogue with Historic England the Councils have suggested that the most appropriate vehicle to ensure that development on the Estate is planned in a sensitive manner is the Estate Framework, which Historic England will be asked to endorse. As set out in the new Dartington policy, the Estate Framework is identified as the tool by which development on the Estate will be planned, and against which proposals will be considered. Historic England, however, have not agreed to these suggestions. o The changes that have been suggested by Historic England are not considered to be required to make the policy sound. In many respects, the Councils do not believe they add anything to the policy and either repeat provisions already contained in the policy (for example adding the sentence which states that the quantum of development will be set out in the Estate Framework directly repeats the existing

policy preamble), or duplicate provisions already set out in other JLP policies (eg DEV22).

 Dartington Hall Estate have made comments which are largely supportive of the new Dartington policy. They have requested that the number of dwellings quoted in the policy is either increased to 150 dwellings or is expressed as a minimum. The Councils do not believe this alteration is necessary – the figure in the Dartington policy is expressed as ‘in the order of 120 dwellings’ which provides flexibility for the Estate Framework to determine a final figure which could be higher or lower. In addition, the phrasing of the policy and the number of dwellings was agreed with the Estate as part of the Statement of Common Ground. The Estate representation also objects to the new clause to the policy referring to ancient woodland. It is noted that this part of the policy refers to the considerations that the Estate Framework will take into account and not to decisions on planning applications. It is not therefore a soundness issue and is something that the Framework itself could clarify.

 Dartington Parish Council make a number of points requesting that the Framework be adopted as SPD, that the Parish Council should be an organisation which will endorse the Framework, and suggesting a number of amendments to the new paragraphs following the new policy. The status of the Estate Framework and the governance of its endorsement is not something that the JLP should influence, therefore these changes are not accepted. The content of the policy and the supporting text was available before the hearings and was discussed at length during the hearings. The points raised do not introduce any new material and are not required.

Councils’ Overall Response

55. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM31 Strategy for TTV Policy Area – Policies TTV15.1, TTV29.23 and associated narrative

56. A total of 4 representations were received on this Main Modification, one of which supports the change.  One supports the deletion of the allocation in Kingsbridge (TTV15.1) but objects to it being retained in the housing supply as a commitment site. It should be noted that the Inspectors, in the Post Hearing Advice Note set out that any AONB allocations that had permission should be retained as commitments. This is what has been done.

 One representation from a developer supports the removal of certain sites but attempts to re-open discussions regarding the deliverability of sites in the 5 Year Land Supply. It should be noted that the 5 Year Land Supply was discussed at length during the hearings after the Inspectors had provided several opportunities for developers to make their points at that time. No changes have been made to the JLP 5 Year Land Supplies apart from consequential amendments and updates, so these comments are not valid.

Councils’ Overall Response

57. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM32 Strategy for TTV Policy Area – Policy TTV29.11

58. A total of 3 representations were received on this Main Modification, one of which is in support and two of which do not relate to the Main Modifications. Therefore there are no valid representations to this Main Modifications.

MM33 Strategy for TTV Policy Area – Policy TTV29.20

59. A total of 2 representations were received on this Main Modification, one of which was a support.  The objection raises grounds that SUDS are not feasible on the site. No evidence is offered to justify this point, and it should be noted that the new point on water quality was sought by Natural England, and that no objection has been raised to this element of the policy by the Environment Agency. It is not considered to be a soundness issue.

Councils’ Overall Response

60. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM34 Strategy for TTV Policy Area – Policy TTV30 and associated narrative

61. A total of 9 representations were received on this Main modification, 3 of which were in support.  One representation by a developer objects to the Neighbourhood Plan allowance being reduced to 550 dwellings rather than 720; and 2 developers object to the policy referring to development ‘within’ settlements as they feel development should also be allowed on the edge of settlements. They therefore suggest that ‘and adjoining’ should be added to the policy. It should be noted that in the Post Hearing Advice Note, the Inspectors required that the Neighbourhood Plan allowance be adjusted to take account of the removal of

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villages in the AONB from the ‘Sustainable Village’ settlement category. It should be noted also that the original policy did not include any provisions for development to come forward adjoining settlements, and that the intention of the policy is that the main mechanism for such sites to be brought forward is through Neighbourhood Plans – ie that it would be for Neighbourhood Plans to identify appropriate sites for housing development to meet local needs. It should also be noted that a judgement around what constitutes a site ‘within’ a village will be influenced by settlement boundaries, and that therefore this point will also be considered through the Settlement Boundaries DPD.

 Some representations object to the reference to the South Hams & West Devon Village Sustainability Assessment Framework Feb 2017, or to some of its content. This evidence base document was consulted on alongside the Reg 19 version of the JLP and was available before and during the hearings – hence it is legitimate to refer to it in this paragraph. Additionally, it should be noted that Neighbourhood Plans will be able to do their own more detailed assessments.

 One representation objects to the removal of sustainable villages in the AONB from the category and wants them reinstated with additional policy protection to address AONB concern. It should be noted that the Inspectors Post Hearing Advice Note required this change to be made in response to discussions at the hearings.

Councils’ Overall Response

62. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM35 Strategy for TTV Policy Area – Fig 5.8 and associated narrative

63. A total of 205 representations were received on this Major Modification, of which 197 were from members of the community in Dartington in response to a circular that was passed around the village. There were also 2 comments in support. The modification addresses the need identified by the inspectors to remove Sustainable Villages in the AONBs from Fig 5.8.  Some representations disagree with the removal of the Sustainable Villages in the AONBs from Fig 5.8; other reps raise issues that have already heard at the hearings and are not specifically about the modification.  One representation from Emery Planning on behalf of Wain Homes says Brixton is wrongly removed as part of the settlement is not within the AONB (the AONB boundary bisects the village). However, if part of it is in the AONB, then it is considered correct to remove it from the list, on the basis that clearly part of the settlement is affected by the AONB restrictions, that development in the non AONB part of Brixton could still have an effect on the setting of the AONB in the same way, and that keeping the whole settlement classified as a sustainable settlement could lead to harm to the AONB as described in the Post Hearing Advice Note. The Councils would note that clearly Neighourhood Plans could look to find solutions to these matters to bring development forward in Brixton in due course, if they could produce evidence to show that no harm is caused to the AONB.

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 The representations from the Dartington community object to the removal of the Sustainable Villages in the AONB from Figure 5.8 on the grounds that smaller villages in the AONB need some growth in order to support services and maintain healthy population balances, and that by allowing growth in these villages pressure would be taken off settlements such as Dartington. It should be noted that the new local housing needs policy provides a mechanism for housing development in settlements to meet local needs. Additionally, paragraph 5.158 now provides a mechanism for Neighbourhood Plans to bring forward development in appropriate locations if an evidence base can be prepared to justify such allocations.

Councils’ Overall Response

64. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM36 Strategy for TTV Policy Area – Policy TTV31 and associated narrative

65. A total of 14 representations were received on this Main Modification, including 3 comments in support of the changes. It should be noted that MM36 includes the new approach to rural exception sites.  There is concern that the new exceptions policy allows developers to sidestep neighbourhood plan provisions, concern with provisions about the location of development or the percentage of affordable housing, or market housing allowed (developers believe more market housing should be allowed, neighbourhood plan groups or parish councils believe less), and that decisions should be made based on local circumstances. It should be noted that the basis of the rural exception sites policy comes from the NPPF, and that there is a key principle that although a proportion of market housing is permissible in order to facilitate affordable housing to meet local needs, the sites are in locations where development would not normally be allowed and the key driver is the delivery of affordable housing to meet local needs. The policy sets an upper limit for the amount of market housing to enable such sites to come forwards.

 There is concern from Bickleigh that the new exceptions policy results in weaker protection than offered by the original TTV31.1, in particular when it comes to non-housing developments. It should be noted that these changes were discussed at length in the hearings and the Main Modifications are the result of those discussions. In addition, other policies in the JLP will also apply to such development proposals providing a sufficient policy framework to inform decisions on inappropriate development.

 One objection from Cllr Blake makes general points about protection for areas of Bickleigh parish, but is not concerned with the changes being proposed through MM36 – it is not therefore a valid representation.

Councils’ Overall Response

66. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

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MM37 Strategy for TTV Policy Area – Policy TTV32

67. 2 representations were received on this Main Modification, both in support of the changes.

MM38 Development Policies – Policy DEV1

68. One representation was received on this Main Modification. It sets out support for the changes although expresses disappointment that light pollution matters have not been incorporated. It should be noted that light pollution is covered by DEV2.

Councils’ Overall Response

69. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM39 Development Policies – Policy DEV2 and associated narrative

70. A total of 212 representations were received, nearly all of which are from members of the Dartington community in response to a circular which was passed around the village. 2 representations were received in support of the changes, including from the Environment Agency, and one expressing general support but noting that light pollution can be avoided rather than mitigated. However, this point is not related to the modifications being consulted upon and is not therefore valid.  The points being made by the Dartington representations are that the AQMA provisions are weak and should include the ‘in combination’ effects of development that generate increased traffic. However, the changes to the policy explicitly refer to cumulative effects – the first element of the policy now contains the words either individually or cumulatively. The comments do not therefore seem to have regard to the actual modification being made. In addition, it is clear that the representations are referring to the quantum of development taking place at Dartington and inferring that development will cause air quality impacts. However, this was clearly discussed at the Hearings and is not something which is connected to the modifications being made under MM36. These elements of representations are therefore not valid.

Councils’ Overall Response

71. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM40 Development policies – Policy DEV7

72. A total of 2 representations were received on this Main Modification  One representation on behalf of the South West HARP consortium objects to the use of off-site requirements on sites of between 11 and 14 dwellings. The MM, however, is not introducing this principle – this provision was in the submission version of the JLP. The modification provides greater clarity to the wording in the policy. Therefore this representation is not commenting on the MM and is not considered to be valid.

 One representation objects to the deletion of the words ‘subject to viability’. However, this change was discussed at length at the hearings and was informed by guidance from the

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Inspectors who indicated that they considered that the words were not required and covered by policy DEL1.

Councils’ Overall Response

73. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM41 Development policies – Policy DEV8 and associated narrative

74. A total of 3 representations were received on this Main Modification, including one support which also wishes Heritage Coast to be included in the glossary. This is not a representation on the Main Modification so is not a valid objection. Another representation is a general comment about Okehampton and not a representation on the Main modification.

75. One representation is substantially supportive but seeks reference to viability as a consideration. However it was clear from the discussions on this at the hearings, and in particular the observations of the Inspectors that these words were not necessary and covered by Policy DEL1.

Councils’ Overall Response

76. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM42 Development policies – Policy DEV13

77. A total of 6 representations were received on this Main Modification.  5 representations make a specific point about Woolwell. These are not concerned at all with the changes proposed under the Main Modification and are not therefore valid representations.

 One representation supports the wording set out in the schedule of main mods, but notes that the track change plan that was made available on the website as an aid to consultees does not match the wording in the Schedule. The Schedule of Main Mods contains the correct wording and this is the wording that is being consulted upon.

Councils’ Overall Response

78. The Councils do not consider that the representations raise any issues that have not been considered during the Exa mination so far, and therefore no further changes to the JLP are required.

MM43 Development Policies – Policy DEV14

79. No representations were received on this Main Modification.

MM44 Development Policies – Policy DEV16

80. No representations were received on this Main Modification.

MM45 Development Policies – Policy DEV18

81. No representations were received on this Main Modifications.

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MM46 Development Policies – Policy DEV20

82. A total of 4 representations were received on this Main Modification.  3 representations set out concerns about how locally distinctive design might be interpreted. It should be noted that this is a matter which will be detailed in the forthcoming SPD.

 One representation supports the changes but suggests that biodiversity could also be added to the list. However, this is not commenting on the changes being proposed under the Main Modification and is not considered to be a valid representation.

Councils’ Overall Response

83. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM47 Development Policies – Policy DEV21 and consequential amendments

84. 2 representations were received, both in support of the changes.

MM48 Development Policies – Policy DEV22

85. A total of 6 representations were received on this Main Modification, of which 2 support the changes.  3 representations highlighted that the track change version of the JLP (that was produced as an aid to those wishing to comment on the Main Modifications) is not same as the Schedule of Main Modifications. However, it is the Schedule that we were consulting on, not the track change version. The Main Modification wording has been agreed with Historic England and is considered to be in compliance with the NPPF and PPG, and can be amplified through the SPD.

 Dartington Hall Trust (DHT) object to words that haven’t been changed as part of the Main Modifications. This representation is not therefore a representation on the Main Modification itself. DHT also object to the new point about excavation or recording – feeling this is too vague. However, this is considered appropriate detail for the policy itself, has been agreed with Historic England, and can be amplified through SPD

Councils’ Overall Response

86. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM49 Development Policies – Policy DEV23

87. One representation was received on this Main Modification, in support of the changes.

MM50 Development Policies – Policy DEV26, associated narrative and consequential amendments

88. A total of 31 representations were received on this Main Modification, of which 2 were in support of the changes.

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 23 representations welcome the new urban fringe policy PLY(NEW), and/or suggest that the Woolwell allocation (PLY44) is not consistent with the policy. Clearly the MM is not an amendment to PLY44 and therefore this aspect of the representations is not relevant to this consultation, and is not valid.

 One representation opposes the policy in that any building in the area will be harmful to wildlife.

 Tamerton Foliot Village Conservation Society make a number of comments in relation to the new policy. In response, it should be noted that the consideration of Conservation Areas is addressed in policies SPT NEW (formerly DEV21) and DEV22. Furthermore, the status of historic environment assets would be considered in a Landscape and Visual Impact Assessment for any proposed development in the Urban Fringe. For these reasons we do not consider it necessary to include specific reference to Conservation Areas in these policies. Comment is made that Conservation Area greenspaces should be classed as City Green Space. Green Spaces have been assessed against the methodology in the POSA, and consistently designated against tis methodology. It would not therefore be justified by the evidence to give greenspaces in Conservation Areas a designation against different criteria. Comment is also made regarding the treatment of public rights of way. We do not agree that the phrase ‘protect and improve’ implies stasis and it may not be possible or reasonable to extend public rights of way in every instance. We consider that the current proposed terminology is suitable to ensure Public Rights of Way are improved (which may include extension) where appropriate.

 Natural England advise that the need to promote the conservation, restoration and enhancement of ecological networks within the area be referred to within the Plan text. This is not an objection to the policy, and not necessary for soundness, but it could be agreed as an additional modification if the Inspectors agree (see APPENDIX TWO)

 3 landowner/developer interests oppose the MM. They question the reliance on the existing evidence, and two representations suggests that the policy does not comply with the NPPF. It should be noted that the evidence being referred to is no longer being used to promote a landscape designation, as discussed during the hearings. The policy now articulates clear issues that are common to the urban fringe and therefore justify a generic criteria based policy for this area (as set out in EXD66). The policy itself therefore represents a framework to be used to consider all development proposals in the urban fringe area, and will enable different elements of each criteria to be balanced in order to make a decision.

Councils’ Overall Response

 In response, it should be noted that the original policy in the submission JLP was materially different to what is now being proposed, as it was seeking a local landscape designation. The new policy does not seek to put a new landscape designation – instead it puts in place a general criteria based policy intended to provide a rational framework for the consideration of development proposals which will guide a decision maker to make an appropriate decision against a range of varying contexts and scenarios. The approach is consistent with the NPPF and is justified by evidence relating to the urban fringe’s characteristics and challenges. As

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we are not promoting a local landscape designation this does not need to be site specific evidence.

 Furthermore, it is clear that the representation by Pegasus on behalf of A&M is attempting to conflate the consideration of a specific development proposal with the general merits of the new policy, and thus has been taken out of context. The specific details of how general criteria based policy is implemented in the consideration of a specific development proposal is not a reasonable guide as to the merits of the policy. If the developer considers that the policy is being applied incorrectly, as appears to be the case here, then the appropriate response would be to appeal the refusal of the planning consent. It should be noted that the planning application in question has not been determined at the time of writing, and therefore it is not even clear whether the new urban fringe policy has been used in the determination let alone interpreted incorrectly.

 The new urban fringe policy is not a no development policy, it seeks properly planned development in an environmentally sensitive context by ensuring appropriate consideration of environmental issues, such as landscape, in reaching a decision.

 The Councils do not therefore consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM51 Development Policies – Policy DEV28 and associated narrative

89. A total of 214 representations were received on this Main Modification, including 3 in support of the changes. The remaining 211 representations are all from members of the community in Dartington, following the production of material that was circulated around the village.  Natural England suggest a minor wording change to new paragraph after paragraph 6.97. This is not a soundness issue, and could be accommodated as an additional modification if the Inspectors agreed (see APPENDIX TWO)

 One representation in support suggests some further tweaks to wording. However, it should be noted that this policy wording was agreed with Natural England in the SOCG.

 The representations from members of the community in Dartington do not concern the Main Modifications made under MM51, and instead concern their interpretation of the policy in respect of development in Dartington. These representations are not therefore concerned with the Main Modifications and are not valid.

MM52 Development Policies – Policy DEV29 and associated narrative

90. A total of 40 representations were received on this Main Modification, including a support from the Environment Agency.  Natural England seek minor wording changes, which are not considered to be a soundness issue but could be made as additional modifications if the Inspectors agree (see APPENDIX TWO)

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 A range of views were expressed by developers, community groups and residents:

 Suggesting that Main Modifications in DEV29.2 are not NPPF compliant. The Councils consider that the Main Modifications do comply with the NPPF. The changes distinguish open space used for recreational purposes (see para 74 of the NPPF) and the need to plan to protect a multi-functional network of green space (see para 109 and 114 of NPPF)  Seeking a more flexible and less onerous version of DEV29.2. In response, the Councils consider that the wording of DEV29.2 is consistent with the NPPF and is justified by the evidence.  Considering the new LGS policy unnecessary. In response, the Councils consider that there is a need for a policy. As discussed with the Inspectors, an LGS policy is important to provide a policy framework for Neighbourhood Plans and potentially future DPDs that may aim to introduce Local Green Space Designations. The policy provides that framework.  Questioning the evidence used to justify the city and neighbourhood green spaces, and suggesting that the POSA justifies a tiered approach. In response, the Councils believe that the evidence base was discussed at the hearings and was not significantly challenged. The Inspectors did not raise issues with the POSA, but clearly did have concerns about the evidence base which was used to justify the designation of Local Green Space site – hence these sites have been removed. The evidence base justifies the network of green spaces which is now set out in the changes to DEV29.  Many seek the reinstatement of LGS sites in the plan given that they arose out of significant community engagement – considering the change DEV29 does not offer enough protection. The Councils would simply note that the Post Hearing Advice Note clearly concludes that following the discussions at the Hearings the Inspectors have concerns around the soundness of the approach set out in the submitted JLP, and therefore required the LGS designations to be removed from the JLP. The level of protection now offered by the revised DEV29 is consistent with the submitted evidence base and with the NPPF.  A number of comments relate to the loss of LGS status for specific sites – esp Pinewood Drive, Woolwell (21 comments) – seeking reinstatement of the provisions. The Councils would simply note that the Post Hearing Advice Note clearly concludes that following the discussions at the Hearings the Inspectors have concerns around the soundness of the approach set out in the submitted JLP, and therefore required the LGS designations to be removed from the JLP.

Councils’ Overall Response

91. The Councils’ view is that this revised policy is carefully crafted, clearly justified by evidence base, and consistent with NPPF. The Councils do not consider that the representations raise any issues that have not been considered during the Examination so far, and therefore no further changes to the JLP are required.

MM53 Development Policies – Policy DEV33

92. No representations were received on this Main modification

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MM54 Development Policies – Policy DEV34 and associated narrative

93. One representation was received to this Main Modification, opposing the reference to requiring the ability to connect to a future network, given lack of clarity about delivery. This modification was suggested following discussion at the hearings (see HM57 in EXD5vii). The representation does not raise any new issues that were not discussed during the hearings and does not raise soundness issues. Further information regarding the implementation of the policy can be provided through SPD.

MM55 Development Policies – Policy DEV35

94. One representation, which supports the Main Modification in part, but opposes deletion of ‘heritage assets’ from point 2. However, the improved wording simply moves the reference to heritage assets to earlier in the policy, therefore giving it more weight.

109 APPENDIX TWO: FURTHER ADDITIONAL MODIFICATIONS

Main Rep from Ref Mod Suggested Additional Modification whom Ref. Consequential Update - Updated figures to go into Fig 5.1 to match SPT3, particularly to update the Sustainable Villages allowance to 550 dwellings:

Figure 5.1

Settlement Type New Homes New employment space 2014 – 2034 2014 ‐ 2034 Mrs Sally Challis MM3(Rev) MM3 (Comment Main Towns 4,471 4,417 110,870 103,070 ID8) sq m

Smaller towns 970 911 52,280 46,780 sq and key villages m

Sustainable 720 550 0 Villages

Dartington Parish Amend para 5.122 in the following way: “…254 new MM5(Rev) MM5 Council homes and 17,300 sqm 11,800 sqm of employment (Comment floorspace…” ID188) Kingsbridge Town Amend the new point added to SP3 to read “Recognising MM22(rev) MM22 Council the important role of key road links the A381 link to (Comment Totnes and the need…” ID10) Natural England In Policy TTV6(9), replace “bat consultation zone” with MM23(rev) MM23 (Comment “Landscape Connectivity Zone” ID64) Add the following sentence to the new paragraph following Natural the new Urban Fringe Policy. “…protected landscapes. It is England MM50(rev) MM50 also important to promote the conservation, restoration (Comment and enhancement of ecological networks within the urban ID67) fringe. This policy…” Natural In the new paragraph following para 6.97, replace “are England MM51(rev) MM51 priority habitats” in the first sentence with “(including (Comment priority habitats)” ID68) Amend the paragraph following the new Local Green Space Natural MM52(rev) MM52 policy in the following way: “…consistent with national England policy for Green Belts.”

110 Main Rep from Ref Mod Suggested Additional Modification whom Ref. (Comment ID69)

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