Penzance and Newlyn (part 2) Responses received during the Cornwall Site Allocations Development Plan Document public consultation – 3 October to 14 November 2016 REP 035 The gurnick estate proposal is not a sensible one in our opinion. Any development at the top of the hill would only increase the problem of access to all amenities. Therefore we foresee the Long Rock area to be ripe for development and to re home the residents from Gwavas who wish to down size. We badly need to protect our few green spaces and to protect our wild life habitats and to guard against noise and air pollution, especially as the infrastructure in Newlyn is sadly lacking any potential for this proposal. Mr W G Hoare & Mrs B A Cobb Objections to Allocations DPD policy PZ-H4 - Trannack 1. Flood risk Photos 1 & 2: Trannack site (PZ-H4) If the land were to be developed in accordance with the application, there would be a serious increase in the risk of flooding. As can be seen from the photographs above, the land slopes very steeply, and is bounded by many mature trees and established hedgerows. All along the southern boundary of the site runs the Chyandour brook, the valley of which is classified as High Flood Risk (category 3) by the Environment Agency, for both river and surface water flooding (see figures 1 and 2 on following page). The Allocations DPD case for PZ-H4 states that “dwellings should be drawn away from the southern extremity of the site along the A30, ensuring that the properties sit outside the flood zone”. However, this does not address the potential for increased flood risk to existing properties and infrastructure along the valley of the Chyandour brook both upstream and downstream of the proposed site: The steep slopes on this site massively increase the risk of run-off flooding compared to other more level potential sites within the Penzance/Newlyn area, and there is nowhere for the water to go other than into the brook. There is already a flooding problem in this area: many homes and businesses in Heamoor village suffered repeated flooding from the Chyandour brook and surface water run-off in the winter of 2012/13. Developing this site would also potentially threaten hundreds of mature trees, which perform a crucial role in alleviating flood risk by absorbing water and binding the soil. According to the Woodland Trust, “interception by trees can be critical in reducing the pressure on the drainage system and lowering the risk of surface water flooding. Research has shown that trees can reduce surface water runoff by up to 80% compared to asphalt”1. Based on the Environment Agency maps, the increased flood risk would potentially affect not only properties within Heamoor village and further downstream, but also the A30 at the Treneere roundabout and the main road/rail route into Penzance in Chyandour where the brook meets the sea, especially if heavy rain coincided with a high spring tide. Flooding of this essential transport infrastructure could have serious implications for the whole of the town of Penzance. 1 “Stemming the flow – the role of trees and woodland in flood protection”, Woodland Trust; May 2014) – 9 November 2016 Page 1 Objections to Allocations DPD policy PZ-H4 - Trannack Trannack site Figure 1: Flood risk – River flooding (source: Environment Agency website)2 Trannack site Figure 2 – Flood risk – Surface water flooding (source: Environment Agency website)1 2 https://flood-warning-information.service.gov.uk/long-term-flood- risk/map?easting=146564&northing=31604&address=100040113837 – 9 November 2016 Page 2 Objections to Allocations DPD policy PZ-H4 - Trannack Finally, the proposed allocation at Trannack conflicts both with national policy planning guidelines and with Cornwall Council’s own policy on flood risk. The National Planning Policy Framework (NPPF) and Planning Practice Guidelines (PPG) provide for a “sequential test”. This is “designed to ensure that areas at little or no risk of flooding are developed in preference to areas at higher risk… Only where there are no reasonably available sites in Flood Zones 1 or 2 should the suitability of sites in Flood Zone 3 be considered”3. This approach is replicated in Cornwall Council’s own “Strategic Flood Risk Assessment Level 1” of November 2009, which states that the location of housing growth in Cornwall will be “based on the sequential test” and that “it should be possible to deliver growth outside Flood Zones 2 and 3… Greenfield development should avoid areas shown to be susceptible to surface water flooding”4. In addition, the NPPF states that for any exception to the sequential test rule, there must be a site- specific assessment that must “demonstrate that the development will be safe for its lifetime… without increasing flood risk elsewhere”. In the case of PZ-H4, even though the proposed development itself may be “drawn away from the flood zone” (as suggested in the Allocations DPD) such that the proposed dwellings themselves might be protected from flood risk, this does not address the potential for “increasing flood risk elsewhere” – specifically, along the valley of the Chyandour brook, which is classified by the Environment Agency as Flood Risk 3 and includes sections of functional flood plain. It would appear therefore that in choosing PZ-H4 as a preferred option for housing in the Allocations DPD, Cornwall Council is in conflict both with national policy guidelines and with its own stated flood risk policy, especially as other potential sites with much lower flood risk (for example in the Newlyn and Long Rock areas) have been overlooked in favour of PZ-H4. There is a possibility that if development were to go ahead on this site and local residents were to experience flooding as a result, they might have a valid claim against the Council for failing to adhere to national and local policy in determining the site allocation. 3 House of Commons Policy Paper no. 07517, “Planning and Flood Risk”, 29 February 2016 4 Cornwall Council Strategic Flood Risk Assessment Level 1, November 2009, page 45 – 9 November 2016 Page 3 Objections to Allocations DPD policy PZ-H4 - Trannack 2. Landscape value As with the flood risk issue, the PZ-H4 option conflicts with the Council’s own policy on landscape value, as stated for example in paragraph 3.40 of the Allocations DPD itself: “In delivering the housing growth targeted for the towns within the Cornwall LP:SP document, it is important that any impact upon the area’s most sensitive landscape, including historic landscape, is minimised.” The choice of the PZ-H4 option conflicts with this policy given that in Cornwall Council’s own “Landscape Character Assessment Results” document, which is part of the evidence base for the Allocations DPD, the Trannack/PZ-H4 site (then known as “Cell 6”) was assessed by the Council itself as being predominantly of “high” landscape value, apart from a small area on the southern edge of the site regarded as “medium” due to its proximity to the A30. This reflects a more general pattern in the housing allocations for the Penzance/Newlyn area in the Allocations DPD, whereby it is predominantly those areas assessed by the Council as having the highest landscape value that have been selected for housing development (see figures 3 and 4). Figure 3: Areas in PZ/Newlyn allocated for housing in the Allocations DPD – 9 November 2016 Page 4 Objections to Allocations DPD policy PZ-H4 - Trannack Photos 3 & 4: distinctive “tree tunnels” on Polmennor Road The Trannack site is also of historical landscape value. It has been in continuous agricultural use for centuries and in the 17th century was planted with vineyards, which led to the area being known as “Little France”. The current field patterns and hedgerows have remained largely unchanged over at least the last hundred years, as shown in the extract from the Ordnance Survey map of 1908 below. Figure 5: 1908 Ordnance Survey map (western section of PZ-H4 site outlined in red) Based on all these considerations, the “PZ-H4” housing allocation is wholly inappropriate, especially given that a number of areas assessed by the Council itself as being of lower landscape value, such as cells 3, 11, 12, 13 and 14 in the Landscape Character Assessment (Newlyn, Long Rock), have been overlooked in favour of this site. – 9 November 2016 Page 6 Objections to Allocations DPD policy PZ-H4 - Trannack 3. Vehicle and pedestrian access According to the Allocations DPD, “vehicular access to the site should be via the A30, with only pedestrian connections on to Polmennor Road”. This fails to address a number of significant access-related issues. Vehicle access: Congestion on the A30. All the vehicles exiting and entering the site would have to join the A30 Penzance by-pass at the Treneere roundabout. This road, which is a strategic artery for both local and tourist traffic, is already frequently gridlocked in the summer months. The additional vehicles generated by 290 new homes would inevitably have a serious impact on traffic flows on the A30. The A30 Penzance by-pass is a dangerous road for pedestrians, and the Treneere roundabout was the scene of a fatal accident involving a young boy in recent years. Although the Allocations DPD attempts to address this issue by saying that “pedestrian crossing point(s) should be delivered on the A30” as well as “measures to promote traffic calming”, such measures would clearly be inappropriate on a major arterial road. Increased congestion is also likely to result in heavier traffic flows on Polmennor Road (and consequently in Heamoor village) as drivers use it as a “rat-run” to avoid delays.