Submission to North Devon and Torridge Joint Core Strategy Land

Submission to North Devon and Torridge Joint Core Strategy

Land to the north of North Road, Witheridge

Client: Mrs D Benn

PREPARED BY:

Savills The Forum Barnfield Road Exeter EX1 1QR

Telephone: 01392 455700 Fax: 01392 455701

March 2010

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

1.0 INTRODUCTION

1.1 The North Devon and Torridge Council’s Joint Core Strategy Pre-Publication Development Plan Document was published for consultation purposes in January 2010. They previously published a Joint Core Strategy Issues and Options Development Plan Document for consultation purposes in November 2007 and although the original response date was 20th December 2007, this was extended to 31st January 2008. We submit representations to the Core Strategy as follows.

1.2 The Core Strategy is the key document within the Local Development Framework to which all other local development plan documents must conform. The Core Strategy sets out the long term spatial strategy for North Devon and Torridge District’s so as to ensure that the social, economic and environmental needs of the two Districts are met. It sets the local strategies for the distribution of future development and indicates broad areas for growth.

1.3 In accordance with National & Regional Policy these representations seek to support the proposition for development of an appropriate scale and proportion to a range of settlements in North Devon and Torridge Districts. The current classification of settlements in the Pre-Publication document has identified Witheridge as a ‘Rural Hub’ which we support. The focus on Barnstaple is acknowledged and understood as is the principle of the rural hubs. However, it is essential to acknowledge and support the role that settlements such as Witheridge will have in ensuring North Devon adequately plans for economic growth and housing delivery, particularly given the scale of the rural area within the District.

1.4 Witheridge is one of largest villages in North Devon with a population in the parish of around 1,200. It benefits from good access links to the towns of Tiverton and South Molton in addition to the City of Exeter. Witheridge benefits from an excellent range of services and facilities including a Primary Schools & Nursery, Post Office, range of Shops, Healthcare Services, Churches, Sports Club, restaurants and Public Houses. In consideration of the level of services offered it is sensible to plan to accommodate future growth which will support the role and function of the settlement sustaining the existing community. In fulfilling its function the village is capable of making a positive contribution towards the wider housing needs of North Devon.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

1.5 With this in mind, this Planning Statement has a twofold role; firstly, to confirm that Witheridge should be classified as a ‘Rural Hub’; and, secondly, to identify at this stage that there is a site suitable for development adjacent to the built-up area of the village that can come forward, with adjoining land.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

2.0 CONTEXT FOR THE CORE STRATEGY a) THE DEVELOPMENT PLAN

2.1 In order to place the Core Strategy in context it is important to understand the planning policy background for the local area. In particular it is important to understand how growth has occurred historically in North Devon. Certain objectives are identified which build upon identified directions for growth, for example, those contained in the existing Development Plan. It is sensible therefore to be aware of the extant Development Plan and the requirements it places on growth for the District.

The Devon Structure Plan

2.2 The Devon Structure Plan entitled 'Devon to 2016' (adopted October 2004) is the current Structure Plan for Devon, including Plymouth, Torbay and Dartmoor National Park, but excluding Exmoor National Park. It covers the period 2001 to 2016. It has been produced having regard to relevant Regional Planning Guidance.

2.3 The 'Devon Structure Plan 2001 to 2016 Explanatory Memorandum and Written Statement (adopted October 2004)' sets out strategic planning policies for development and other land uses in respect of: housing; employment; conservation; minerals; waste; transportation; shopping; tourism; leisure; and recreation, over a 15 year period. It provides a framework for detailed decisions by local authorities, other organisations and individuals in the preparation of their forward Plans (e.g. Local Plans, Local Development Frameworks and Community Strategies). It is therefore relevant to be aware of the requirements of this Plan as the Core Strategy is prepared.

2.4 These policies were expected to expire on the 8 October 2007. However in September 2007 the Secretary of State issued a Direction to save the policies, specified in the Schedule of the Direction for an extended period of time and a Second Direction to correct an error in the 'Schedule of the Direction'. These save all the policies in the Plan.

2.5 A letter from the Government Office to the South West Regional Assembly sets out further information about the saved policies. In due course the policies will be

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

superseded by policies in Regional Spatial Strategy (due for adoption in 2010 and/or Local Development Documents (when they are adopted).

2.6 The key objective for the Structure Plan as far as development is concerned has been to plan and create sustainable patterns of development. This lies at the heart of the Plan. Policy ST5 sets out the distribution of development in a range of Devon settlements. Whilst the principle focus is on the Principle Urban Areas and Sub- Regional Centre the plan recognises that development should not be prevented in other settlements where the community needs are met and rural regeneration is promoted.

2.7 Policy ST16 sets out the proposals for Local Centres and Rural Areas. This policy supports appropriate scale development which meets local regeneration needs whilst balancing constraints and overall spatial strategy.

The North Devon Local Plan

2.8 The North Devon Local Plan was formally adopted on 20 July 2006 and forms part of the development plan for North Devon. In June 2009, the Secretary of State issued a direction confirming that the Local Plan policies identified in the schedule should be saved for an extended period beyond 6 July 2009. Other Local Plan policies will no longer form part of the development plan.

2.9 The Local Plan in translating Structure Plan Policy has identified settlements which function as Local Centre’s together with specified Large Villages which have a similar role within their respective Rural Areas. The Local Plan identifies Witheridge as a Local Centre.

2.10 In recognising the importance of settlements such as Witheridge the Local Plan accepts that a moderate level of growth could prevent the decline of the services which exist. In providing further guidance for this settlement the adopted North Devon Local Plan contains an Action Plan which identifies key issues to be considered whilst seeking to maintain the future of a viable well balanced community.

The Emerging Regional Spatial Strategy

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

2.11 The Regional Spatial Strategy (RSS) is a key policy document in guiding growth for development. The Secretary of State's Proposed Changes to draft Regional Spatial Strategy were published in July 2008. Public consultation took place until 24 October 2008 and over 30,000 responses were received.

2.12 The Secretary of State sought to publish the final Regional Spatial Strategy at the end of June 2009. However, in May 2009, the High Court issued a judgement that the previously issued Regional Spatial Strategy for the East of England had failed to meet certain requirements of the Strategic Environmental Assessment Directive. With that in mind, the Department of Communities and Local Government and the Government Office for the South West considered the implications for the Regional Spatial Strategy for the South West. The Government announced in September 2009 that it will carry out a further appraisal of whether the Regional Spatial Strategy for South West England and the proposals/policies contained within it are the most sustainable way forward for the region.

2.13 The Government wishes to be satisfied that the Sustainability Appraisal of last year's Proposed Changes to the South West tested reasonable alternatives to those Areas of Search for strategic housing, business and other development which were added or amended following consideration of the Panel's report. In the light of the Appraisal's findings, the Government will then decide what action to take to complete the SW Strategy to provide the clarity and certainty about the future framework for growth in the region.

2.14 Therefore whilst in a draft form it is clearly at a very advanced stage. The RSS has set a series of targets for the provision of development relating to a wide range of land use types in the region. Supporting economic growth in accordance with the Regional Economic Strategy is key and lies at the heart of the RSS. If this is to be achieved there must be a balance between employment growth and housing growth with actual housing provision linked to forecasts.

2.15 The current RSS (previously RPG10) remains part of the Development Plan until such a time as the emerging RSS is formally published. The existing regional guidance contains relevant direction in relation to growth of rural areas. Policy SS19 indicates that market towns should be the focus of rural development. However, the Policy does go on to state that outside of market towns “development should be small scale and take place primarily within or adjacent to existing settlements, avoiding

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

scattered forms of development”. In support of housing distribution in rural settlements Policy HO4 states that Local Authorities “should make provision for limited additional housing within or adjacent to settlements in rural areas…in circumstances where it will support local services which could become unviable without some modest growth [or where] it is required to meet the needs of rural communities.”

2.16 The emerging RSS in relation to housing and employment provision indicates that in quantitative terms having regard to Policy HMA 10, North Devon and Torridge are expected to accommodate 21,600 units between them with the majority of development being targeted to North Devon (10,900). Whilst the North Devon figure will be primarily allocated in and around Barnstaple it will be crucial not to underplay the importance of growth in rural areas.

2.17 In meeting these aims and objectives, it is clear that development will have to be targeted predominantly to Strategically Significant Cities and Towns (SSCT’s). However, Development Policy C does recognise that limited development will be permitted in villages in order to support strong communities and promote self containment, a position which is supported.

2.18 It is clear from assessing how development has been planned over the past few decades that Barnstaple has and should continue to be a focus for growth in North Devon. However, outside of Barnstaple it is important that a wide range of settlements are adequately considered in order to meet the needs of local communities throughout North Devon. It is the role of the Core Strategy to do this. However in meeting identified targets it is important that the growth is achievable and that housing is deliverable in line with not only regional planning policy but also national planning policy guidance. There is much guidance particularly in PPS3: Housing; PPS12: Local Spatial Planning and PPG13: Transport that advises how growth should occur. It is imperative that in preparing a strategy for distributing development it is those sites in settlements that can meet regional and national planning policy guidance that should be released. Furthermore in determining which sites should be allocated careful consideration should be given to ensuring that the existing positive aspects and qualities of the area are maintained.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

b) OTHER MATERIAL GUIDANCE

2.19 The report to the Government by Matthew Taylor MP entitled “Living Working Countryside: The Taylor Review of Rural Economy and affordable Housing” (July, 2008) is particularly apposite. It will inevitably guide future central government policy, much as the recent Barker Reviews have done.

2.20 The introduction to the report states that “this country’s rural communities cannot stand still. Change is inevitable whether development takes place or not, and the choices we make today will shape tomorrow’s character of the market town’s, villages and hamlets that make up our countryside”. The introduction also makes reference to the previous policy approach of ‘protecting’ (his emphasis) villages from development and the unfortunate, and unintended, consequences of this policy approach; the loss of services and facilities, increased affordability problems etc.

2.21 Chapter 3 is entitled “Living Working Villages”. Paragraph 1 refers to an “overly narrow interpretation of policies designed to protect the countryside which mistakenly (my emphasis) brands small settlements as ‘unsustainable’ (his emphasis)”. One of the housing challenges facing villages is identified as a “restrictive planning regimes and shortfall of planned provision of new homes creating an especially constrained supply of both (my emphasis) market and affordable homes”.

2.22 Paragraph 38 states that “as Local Planning Authorities prepare their Core Strategies and Development Plan Documents, they should be considering sites in and around villages where appropriate (reflecting local needs, and the importance of maintaining and improving environmental, economic and social sustainability) for schemes that will provide a mix of private and affordable housing”.

2.23 Paragraph 42 states that “simply ruling out whole categories of villages as unsustainable, as too many local plans currently do, ignores the potential for enhancing the sustainability of many smaller rural communities, and the real needs of those who live and work there. The process of allocating sites for mixed development should be implemented in a wider range of communities than is typical today”.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

2.24 The approach put forward in this brief report of allowing some market housing in certain villages, in this case Witheridge, is backed up by the recognition that “the scale and pace of increased house prices over recent years has created severe housing need among working people on average incomes, not just those traditionally needing social housing”. This is part of a wider view that housing need encompasses all forms of housing, i.e. open market housing for those who can afford market prices need to be catered for, as do those who require social rented and intermediate housing.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

3.0 THE STRATEGY FOR GROWTH IN THE CORE STRATEGY

General Directions for Growth

3.1 In terms of the overall strategy for growth, the relevant proposed policy which looks at how development, in terms of the provision of housing, should occur across the two Districts is contained in proposed Policy COR3: Main Towns Growth Strategy.

3.2 It is interesting to note in para. 4, that the Council’s anticipate that 80% of growth will occur in the Main Towns. Reservations are expressed at this stage that with the levels of growth that are identified (which are substantial) it is unlikely that the existing urban areas themselves are going to be able to accommodate the levels of growth that are expected. This is partly due to environmental considerations but also questions must be raised as to whether certain sites within towns are capable of delivering development particularly having regard to feasibility/viability issues and infrastructure issues.

3.3 In relation to the rural areas the contents of para. 3.31 are supported whereby the Council recognises the need for development in rural areas to secure sustainable communities. However, in relation to Table 2 it is important to recognise the contribution that development in rural areas has made to North Devon housing delivery accounting for 34% of achieved development between 2006 and 2009 and 32% of committed development at April 2009. In light of this analysis the 20% allocation in para. 3.31 of the overall housing requirement for rural areas is questionable. If development in rural areas is scaled back from current and historic levels there is a danger that housing supply targets in North Devon could suffer to the detriment of the region.

3.4 It is recognised that the Councils have identified rates of delivery for development which replicate the net dwelling requirements as set out in the RSS. In relation to rural areas Table 2 demonstrates that development achieved in such locations between 2006 and 2009 has been significantly ahead of that in both North Devon Locally Important Centre’s and is deemed to have greater commitments as at April 2009. Based on the above it will be important for the Council’s to adopt a flexible approach which can respond to the challenges to delivery.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

3.5 In reality it is those sites that are relatively straightforward to develop, constraint free and which prove to be attractive to the developer that should be considered. In many cases such sites can be identified in a range of settlements throughout North Devon and provided they meet acknowledged and accepted sustainability criteria in a sensitive manner then there is no reason as to why such sites cannot come forward.

3.6 It is imperative that the growth levels identified are achieved and the identification of deliverable sites throughout the area will be required to ensure that delivery objectives (at a national, regional and local level) are met in order to minimise the risk of failure attached to the whole delivery strategy.

Meeting the Needs of Rural Areas

3.7 In acknowledging the RSS obligation to provide 7,200 dwellings in Barnstaple there remains a significant (3,700 dwellings) requirement to be distributed in the remaining North Devon settlements. The current hierarchy of settlements suggests that the ‘Locally Important Centres’ of South Molton and Ilfracombe should support appropriate levels of growth ahead of rural hubs and other villages. In meeting the requirements of the RSS the Council recognise in para. 3.32 that attaining the required development rates will be challenging. Therefore, in consideration of this perceived difficulty there is a question over the proportion allocated to, and reliance placed on these two settlements to deliver a substantial contribution to the North Devon RSS target.

3.8 Policy COR4 sets out the Rural Areas Strategy and identifies Witheridge as a Rural Hub. Such Rural Hubs will be “enabled to grow as rural service centres to meet wider community needs”. This accords with Development Policy C in emerging RSS and we support this approach.

3.9 Paragraph 3.42 acknowledges that local people should be able to live and work within their communities. Paragraph 3.44 states that the village’s character, form and function should not be adversely affected by inappropriately scaled or designed proposals. Paragraph 3.47 sets out that development boundaries and growth for rural areas will be defined in a site allocations DPD.

3.10 In para. 3.40 the Council recognises that North Devon has ‘a substantial rural area’, which is populated with a considerable number of villages. This is an undisputed fact

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

which can be positively utilised to sustainably meet the development levels prescribed in the RSS. It is recognised that development in rural areas needs to sensitively address a number of environmental issues, but where it can be successfully demonstrated to contribute towards vital and viable rural communities this can assist the Council in meeting the RSS targets. However, this will only be possible following the adoption of a flexible policy which seeks to maximise the potential of key rural villages which themselves need to accommodate development to sustain their important existing role and function.

3.11 In relation to the above comments, it is felt that Witheridge is worthy of inclusion as a ‘Rural Hub’. This settlement is considered suitable for this classification due to the range of services currently offered and the fact that the village forms the centre of a thriving rural community. Particular attention should be drawn to para. 3.43 which identifies the importance that primary schools play in village life. The importance of these village assets is supported and is welcomed as part of explanatory context in support of COR4 when used to consider locations for sustainable rural development.

3.12 In consideration of the above it is sensible to support the existing role of the village throughout the plan period by permitting sustainable development in accordance with Policy COR4.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

4.0 THE SITE AT NORTH STREET, WITHERIDGE

4.1 As stated earlier, the aim with this submission is to firstly, confirm that we agree with the designation of Witheridge as a ‘Rural Hub’; and, secondly, to identify at this stage that there is a site suitable for development adjacent to the built-up area of the village that can come forward in conjunction with adjoining land.

4.2 The site comprises agricultural land adjoining the existing development boundary of the village and to the rear of the existing village hall. The site extends to approximately 1.83 hectares (4.52 acres). The site plan attached at Appendix 1 shows the precise location and extent of the site. The land falls gradually from south to north. The Two Moors Way passes to the east of the site.

4.3 The adopted Local Plan shows the site as subject to Proposal WIT2A, which states that;

“Land north of the Parish Hall is proposed for sports pitches and public open space, as shown on inset map 7, where the open character of the landscape is not harmed”

4.4 We question if this is an appropriate proposal for the Local Plan to have made, given the fact that we are now acting for one of the joint landowners in proposing development on the land. Notwithstanding this, paragraph 18.15 of the adopted Local Plan acknowledges the good level of provision for accessible open space in Witheridge. Any growth to the north of Witheridge including this site would have to provide an appropriate level of public open space. In our view, growth in this location would enable a reconfiguration of existing and proposed uses, including the parish hall and open space provision, to the benefit of the village. We are currently actively pursuing options for working with adjoining landowners.

4.5 The land slopes gently and development would not cause detrimental landscape and visual impact. Any development in this location would be capable of being appropriately screened. Taking access through the parish hall site from North Street would be acceptable in highway terms, although we reserve the right to produce further evidence on this issue, and others, at later stages in the LF process.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

4.6 We commend the site appended to this brief representation to the local planning authority as a suitable location, with adjoining land, for growth to Witheridge to help meet local needs and to sustain the existing role and function of the village.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

5. POLICY COR14

5.1 We would urge caution on concluding that an affordable housing target of at least 45% is favourable and viable on the basis of a study completed in October 2008, as paragraph 6.18 has done.

North Devon and Torridge Joint Core Strategy: Pre-Publication January 2010

6. CONCLUSION

6.1 In conclusion, this brief representation seeks to support the identification of Witheridge as a Rural Hub. There is a great deal of logic in identifying the village under Development Policy C in the emerging RSS and then translating this down into the LDF as it has. The village has a good level of services to meet the day to day needs of residents and good access to nearby Tiverton and South Molton for higher level needs.

6.2 We have highlighted an area of land which we consider could form part of the eventual growth of Witheridge, but accept that the Core Strategy will not allocate this land. We look forward to taking this site through the Site Allocations DPD as part of an area of growth for the village.

15 Area : 1.829 ha (4.520 acres)