Penzance and Newlyn (Part 2)

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.

Pedestrian access:

 The “pedestrian connections on to Polmennor Road” called for in the Allocations DPD create an unacceptable level of danger to pedestrians. The road is in places not wide enough for two cars to pass (as shown in the photographs on the previous page), and has a number of blind bends. There is no scope for building a pavement without further narrowing the road. It would not be possible for the residents of 290 homes (including pupils on their way to school at Heamoor Junior or Mounts Bay, or families with young children in buggies) could safely use this as a pedestrian route.  The extreme steepness of the Trannack site would make pedestrian movement within any development problematic, especially for the disabled and elderly. This topography suggests that delivering “extra care housing”, as called for in the Allocations DPD, would in practice be very difficult to achieve.

– 9 November 2016 Page 7 Objections to Allocations DPD policy PZ-H4 - Trannack

4. Planning criteria

Threat to the separate identity of Heamoor village

According to paragraph 3.16 of the Allocations DPD, in most instances greenfield sites allocated for housing “should represent extensions to existing communities.”

This stipulation is referred to in the assessment of PZ-H4 in the Allocations DPD, which asserts that the proposed residential development “should be seen as an extension of the Heamoor area”.

But in fact the development as proposed cannot be seen as an extension of Heamoor village. It is actually a pure greenfield site which at no point adjoins any existing built-up area. The site is bounded to the west by Trannack allotments; to the north by Polmennor Road, beyond which lie fields and woodland; to the east by fields; and to the south by the Chyandour Brook.

The entire site therefore lies beyond the existing eastern “hard edge” of Heamoor village, as constituted by the relatively small number of houses on Polmennor Road and Treneere Lane.

Finally, paragraph 3.16 of the Allocations DPD confirms “the principle of maintaining the separate identities of the communities of Penzance, Newlyn, Heamoor, Gulval and Long Rock”, which has been a guiding principle throughout the preparation of the Local Plan.

For example, the Council’s landscape characterisation study for the West Penwith Community Network area (dated 20 April 2011) identifies the following under “Threats” to the character of the area: “Development around Penzance – infilling outlying areas, and creeping into adjoining villages”5.

However, this is precisely what is proposed with the PZ-H4 allocation. By creating a large block of housing on a greenfield site between Heamoor and Treneere, it would effectively blur the boundary between Heamoor and Penzance, and shift the boundary of the existing built-up area eastwards almost to the fringes of Gulval. This would be seriously detrimental to the “separate identity” of Heamoor village, and to the whole character of West Penwith.

Land use

The proposed PZ-H4 site is prime agricultural land. Indeed, this is some of the most productive land in the entire United Kingdom due to the south facing slopes, fertile soil and mild climate. At a time of potential future food insecurity, land of this quality should be retained in its existing use rather than allocated to housing.

5 See www.cornwall.gov.uk/media/3641163/west.penwith.pdf

– 9 November 2016 Page 8

Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

1. Flood risk

Photos 1 & 2: Trannack site (PZ-H4)

Photo 3 : Polmennor road (PZ-H5)

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 PZ-H4 site, and adjacent to the PZ-H5 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”.

The PZ-H5 site includes a number of springs feeding into the brook and the allocations case 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 sites:

o The steep slopes of these sites 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.

10 November 2016 Page 1 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

o Developing these sites 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. o 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.

Trannack site

Figure 1: Flood risk – River flooding (source: Environment Agency website)2

1 “Stemming the flow – the role of trees and woodland in flood protection”, Woodland Trust; May 2014) 2 https://flood-warning-information.service.gov.uk/long-term-flood- risk/map?easting=146564&northing=31604&address=100040113837

10 November 2016 Page 2

Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

It would appear therefore that in choosing PZ-H4 and PZ-H5 as preferred options 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.

2. Landscape value

As with the flood risk issue, the PZ-H4 and PZ-H5 options conflict 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.”

Pz-H5 is within an area of Great Historic Value- the Bone Valley .

The choice of PZ-H5 conflicts with Policy 11 of the Council’s structure plan in respect of protecting the borough’s heritage

“The Council will seek to conserve and enhance the landscapes, features and habitats of heritage importance within the Borough”

And conflicts with the National Planning Guidelines- paragraph 13-

“When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation.”

Also the Penwith saved local plan (CC 16 ) stated that in respect of encroachment upon an area of Great Historic Value, development will not be permitted where there is significant adverse impact. Clearly 33 homes on PZ-H5, north of Polmennor road and inside this area will provide this significant adverse impact upon the Bone Valley, which has a well defined boundary to the north of Polmennor Road.

10 November 2016 Page 5 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

https://map.cornwall.gov.uk/website/ccmap/?zoomlevel=8&xcoord=146756&ycoord=31677&wsName=ccmap& layerName=Strategic%20Housing%20Land%20Availability%20Assessment%20drafts:Areas%20of%20Great%20Hi storic%20Value

Figure 5-Bone Valley AHV

Paragraphs 6.3.79 and 6.3.80 of the “saved” old Penwith Local Plan (Policy CC-16):

“Areas of Great Historic Value (AGHV) are designated by the County Council where there are concentrations of Ancient Monuments or where the landscape has changed little from previous historical periods and where many sites can still be seen in their original settings. Two such areas are identified in the Structure Plan within the District (Proposal ENV B), the extensive Penwith Moors and Coast, covering much of the Land's End peninsula, and the Upton Towans-Godrevy area. The Penwith Moors and Coast designation contains a host of archaeological remains and forms one of the greatest concentrations of Scheduled Monuments in Britain. Moreover much of the prehistoric landscape still remains intact since agricultural activity over the centuries has tended to maintain and reuse the ancient field systems.

Within the Areas of Great Historic Value and where remains of county importance are affected proposals will not be permitted unless there is no significant adverse impact. “

10 November 2016 Page 6 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

These allocations reflect 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 6 and 7).

Figure 6: Areas in PZ/Newlyn allocated for housing in the Allocations DPD

10 November 2016 Page 7 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

Figure 7: Landscape Character Assessment Results (high landscape value areas in red) o In addition to the specific issue of conflict with the Council’s own landscape value assessment as described above, there are a number of specific landscape features at the Polmennor Road and Trannack sites which if lost would result in a significant loss of amenity not only to local residents but also to visitors to Penzance and the surrounding area: o Polmennor Road and Trannack are greenfields site with hundreds of mature trees and long- established hedgerows, which together with the Chyandour brook make this a valuable wildlife habitat. o The sites are highly visible from much of the built-up area of Penzance, especially the Treneere and Lescudjack communities, as well as from many homes on the eastern side of Heamoor village. Developing them would therefore have a serious adverse impact on the visual amenity of hundreds of local residents. o The Trannack site is also very prominent from the A30, which at this point constitutes a “West Penwith gateway” for tourists visiting the beautiful coastline and the historic mining area around St Just, classified as a UNESCO World Heritage Site. o Polmennor Road, the road forming the northern boundary of the PZ-H4 site, is a traditional Cornish lane featuring a number of “tree tunnels”, identified as “distinctive landscape/ historic features” in Cornwall Council’s own Landscape Character Assessment of “Cell 6” (now PZ-H4). This road is also of historical interest in that it is believed to form part of the ancient trackway known as “Vounder Gogglas” or the “Old Land’s End Road”. This historic lane would be severely impacted by large-scale development on the adjacent fields.

10 November 2016 Page 8 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

Photos 4 & 5: distinctive “tree tunnels” on Polmennor Road

o The sites are 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 8: 1908 Ordnance Survey map (western section of PZ-H4 site outlined in red)

Based on all these considerations, the “ PZ-H5 & PZ-H4” housing allocations are 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.

10 November 2016 Page 9 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

3. Vehicle and pedestrian access

According to the Allocations DPD, “vehicular access to the Trannack site should be via the A30, with only pedestrian connections on to Polmennor Road”, whilst the 33 properties proposed for PZ-H5 will exit directly onto Polmennor Road.

This fails to address a number of significant access-related issues.

Vehicle access:

o Congestion on the A30. All the vehicles exiting and entering the PZ-H4 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. o 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. o Increased congestion and 33 additional dwellings are 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.

Pedestrian access:

o The “pedestrian connections on to Polmennor Road” called for in the Allocations DPD create an unacceptable level of danger to pedestrians. The road is in places not wide enough for two cars to pass (as shown in the photographs on the previous page), and has a number of blind bends. There is no scope for building a pavement without further narrowing the road. It would not be possible for the residents of 290 homes (including pupils on their way to school at Heamoor Junior or Mounts Bay, or families with young children in buggies) to safely use this as a pedestrian route. o The current pavement to the west of Trannack Vale up to Mounts Bay Academy is very narrow in places and unsuitable for additional pedestrian use by schoolchildren at peak times . o The traffic calming measures promised are a wholly inadequate remedy to these inherent difficulties in expanding greatly the pedestrian use of Polmennor road by the allocation of both PZ-H4 and PZ-H5 o The extreme steepness of both the Polmennor Road and the Trannack site would make pedestrian movement within any development problematic, especially for the disabled and elderly. This topography suggests that delivering “extra care housing”, as called for in the Allocations DPD, would in practice be very difficult to achieve.

10 November 2016 Page 10 Objections to Allocations DPD policy PZ- H5 Polmennor Rd & PZ-H4 - Trannack

4. Planning criteria

Threat to the separate identity of Heamoor village

According to paragraph 3.16 of the Allocations DPD, in most instances greenfield sites allocated for housing “should represent extensions to existing communities.”

This stipulation is referred to in the assessment of PZ-H4 and PZ- H5 in the Allocations DPD, which asserts that the proposed residential development “should be seen as an extension of the Heamoor area”.

But in fact neither of developments as proposed can be seen as an extension of Heamoor village. They are actually pure greenfield sites which at no point adjoin any existing built-up area. The PZ-H4 site is bounded to the west by Trannack allotments; to the north by Polmennor Road, beyond which lie fields and woodland; to the east by fields; and to the south by the Chyandour Brook.

The PZ-H5 site adjoins an existing isolated dwelling to the west on the access road to historic Bone Valley, and elsewhere to green fields.

The entire sites therefore lie beyond the existing northern and eastern “hard edge” of Heamoor village, as constituted by the relatively small number of houses on Polmennor Road and Treneere Lane.

However, this is precisely what is proposed with the PZ-H4 allocation. By creating large blocks of housing on a greenfield sites adjacent to both Heamoor and Treneere, it would effectively blur the boundary between Heamoor and Penzance, and shift the boundary of the existing built-up area eastwards almost to the fringes of Gulval. This would be seriously detrimental to the “separate identity” of Heamoor village, and to the whole character of West Penwith.

PZ-H5 allocation would infill an outlying area to the north of Heamoor village, which would be detrimental to the current identity of Heamoor village, which is bounded almost wholly to the south of Polmennor road.

Land use

The proposed PZ-H4 and PZ-H5 sites are potentially prime agricultural land. Indeed, this is some of the most productive land in the entire United Kingdom due to the south facing slopes, fertile soil and mild climate. At a time of potential future food insecurity, land of this quality should be retained in its existing use rather than allocated to housing.

6 See www.cornwall.gov.uk/media/3641163/west.penwith.pdf

10 November 2016 Page 11

If No, please indicate which PZ-H9 St Clare. We support the general principle of the redevelopment allocation(s) you would like of this site, and as owners of part of the site, confirm that the land is amended, highlighting the site’s available for development. Please note that the land under our clients reference code, and set out what you ownership extends to more than is shown under this allocation and dislike about the site and/or its would recommend that it is all included as the small area of additional related policy (If you would like to land may be useful and necessary to successfully deliver a suitable make comments on more than one mixed use development including green infrastructure and amenities site, please ensure you clearly required. A plan of the full area of land that is able to be included in the indicate which comments relate to site allocation is attached. which site).

7. Is there an alternative site (or sites) that you would like to propose? If so, please complete the following questions: a) the location of the site that you Nancealverne - circa 9.5 hectares/23 acres would like to propose b) the type and scale of development to be delivered on the Residential led scheme, likely to be in the region of 200-250 units site(s) c) the site(s) within the Site Allocations DPD that you believe PZ-H8 - Heamoor Section A and E. your site(s) should replace(please state the site allocation reference) The PZ-H8 Section A and E site is a greenfield development on the periphery of a suburb to the town of Penzance and development of this would significantly extend the town boundary out into open countryside d) the reasons why you believe your in the form of ribbon development. Development of the proposed proposed site(s) is better than the alternative site would have a similar impact in terms of land use change site(s) you wish to replace it with as this is also greenfield site but importantly it is located much closer to the centre of Penzance, and as such, all suitable amenities. It is also located and could be accessed directly from the A39 main road as it passes through and around the town.

8. Please rank the following sites 1 to 5 in order of preference to provide student accommodation

FP-St1: Quarry Car park FP-St2: Falmouth Road FP-St3: Arwenack Street FP-St4: Ocean Bowl FP-St5: Treleiver Direction of Growth Do you know of any reasons why one or more of the student accommodation site options should not be brought forward? Are there any other appropriate alternative sites?

9. Feel free to make any additional comments with regard to the document or its evidence base.

N/A

REP 0147

Our Ref RAB/PCL/9851 Date 14th November 2016

PCL Planning Ltd 1st Floor 3 Silverdown Office Park, Strategic Planning Fair Oak Close, Cornwall Council Clyst Honiton, Dolcoath Avenue Exeter, Devon, EX5 2UX Camborne United Kingdom TR14 8SX

Dear Sir/Madam,

SITE ALLOCATIONS DPD – PREFERRED OPTIONS CONSULTATION

I write on behalf of our client DCH Group in relation to the current preferred options consultation on the Site Allocations DPD.

This representation is made in respect of two sites that are located within two of the towns covered by the Site Allocations DPD. These are:

 Foxes Field, Gulval, Penzance; and

 Bickland Water Road, Falmouth

Penzance

We agree with the vision and objectives set out in the draft version of the DPD for Penzance and Newlyn. We also understand and support the overarching strategy and housing strategy for the town.

Specifically, we wish to lodge our support for proposed allocation of land at Foxes Field, Gulval (Reference PZ-H3).

This site is well located to contribute to meeting overall housing requirements for the urban area of Penzance and Gulval. The site has the opportunity to improve pedestrian connectivity with various parts of Gulval, which will provide safer routes (such as to the school) for prospective residents and the wider community.

We feel that the site has the ability to deliver more than the approximate 68 dwellings indicated in the DPD and suggest that to ensure the efficient and effective use of land this should be increased to approximately 75 units (which would involve a development of approximately 33 dwellings per hectare).

PCL Planning Ltd, Registered Office: 1A Parliament Square, Parliament Street, Crediton, Devon, EX17 2AW Registered in England and Wales No. 8300933 VAT No. 923955793

REP 0147

Our Ref RAB/PCL/9851 Date 14th November 2016

PCL Planning Ltd 1st Floor 3 Silverdown Office Park, Strategic Planning Fair Oak Close, Cornwall Council Clyst Honiton, Dolcoath Avenue Exeter, Devon, EX5 2UX Camborne United Kingdom TR14 8SX

Dear Sir/Madam,

SITE ALLOCATIONS DPD – PREFERRED OPTIONS CONSULTATION

I write on behalf of our client Inox Group in relation to the current preferred options consultation on the Site Allocations DPD. Specifically, this representation is made in respect of Pezance and Newlyn.

We agree with the vision and objectives set out in the draft version of the DPD for Penzance and Newlyn. We also understand and support the overarching strategy and housing strategy for the town.

Specifically, we wish to lodge our general support for proposed allocation of land at Heamoor (Reference PZ-H8) as this site is well placed to contribute to meeting overall housing requirements for the urban area of Penzance. However, we object to the detail of the draft allocation set out in the consultation document.

Firstly, we are concerned by the amount by which the extent of this allocation has been reduced. We acknowledge that the heritage work undertaken has identified sensitivities regarding the development of this land, particularly in relation to Trengwainton, and accept that certain parts so of the original site do need to remain undeveloped, however, we consider that some land has been unnecessarily removed from the allocation.

It is our view that all of the land indicated (by the red line) on the enclosed site plan can and should be included within the allocation. The area that has been removed (as indicated by black diagonal lines on the plan) is well screened by an existing dense belt of trees and vegetation along its western boundary and with some further planting along the northern boundary (adjacent to the reservoir) could be developed without any discernible impact on the setting of Trengwaiton and any important views associated with it.

In terms of overall number of dwellings for the allocation this should be higher than indicated, especially if the land referred to above is included. Even with the reduced site area proposed in the draft dcoument we consider that the site has the ability to deliver more than the approximate 435 dwellings indicated in the DPD and suggest that to ensure the efficient and effective use of land (in

PCL Planning Ltd, Registered Office: 1A Parliament Square, Parliament Street, Crediton, Devon, EX17 2AW Registered in England and Wales No. 8300933 VAT No. 923955793

line with national guidance) this should be increased to approximately 485 units (which would involve a development with an average density of 39 dwellings per hectare).

We understand that the heritage constraints present affect the level for development achievable here but this should not be at the expense of ensuring that there is an efficient and effective use of land to deliver housing. A considered and sensitive design approach to the development of the site could deliver this level of development without having unacceptable impacts on the designated heritage assets.

Increasing the supply at this allocation would mean that the total number of dwellings that could be provided by the proposed allocations for the town is increased from 1,245 dwellings to the residual requirement of 1,295 dwellings. Taking this action will provide greater certainty that the minimum housing requirement for Penzance & Newlyn can be achieved.

We do not agree that all the site should be accessed solely via Roscadgill Road, with just a bus-only access on to Boscathnoe Lane (as per requirement b] of the allocation). It is our opinion that the site should have an unrestricted vehicular access on to Bostcathnoe Lane as well but that the number of dwellings served from this access should be limited. Based on the work we have undertaken it is suggested that a limit in the region of 110 units would be appropriate.

In terms of requirement J of the draft allocation (need for any planning application to be in accordance with a masterplan/concept plan), there is currently a lack of certainty and clarity over what is required here. Is the concept plan to be included in the Site Allocations DPD or is it something that is to be agreed with the LPA in advance of applications being lodged? It is our opinion that the site allocations DPD should include a high level concept plan for the development of the site so that upon adoption the DPD will provide the necessary clarity and certainty (on the general form of development that is required by the allocation) for those involved in bringing forward the site for development. It should though not be overly prescriptive.

Finally, in respect of the allocation plan included in the consultation document and in connection with a potential concept plan, the size of the area E/ tree planting along northern boundary on the site allocation plan is excessive and unnecessary. A spinney of trees half the size would achieve the outcome required to adequately mask the development from this approach to Trengwaiton. A concept plan/allocation plan should be produced that shows a more appropriately sized area of buffer planting.

If you have any questions regarding the above or would like any further information please contact me.

PCL Planning Ltd, Registered Office: 1A Parliament Square, Parliament Street, Crediton, Devon, EX17 2AW Registered in England and Wales No. 8300933 VAT No. 923955793

Cornwall Site Allocations DPD consultation

1. Please state the town / conurbation that the following answers relate to:

Penzance

2. Do you support the Vision/Aims/Objectives that are set in the report?

Yes / No

If No, please indicate what elements you disagree with including paragraph numbers where possible) and how you would like it amended.

The vision is supported and it is noted that the strategic objectives for the West Penwith Community Area in which Penzance and Newlyn are located are set out within the Cornwall Local Plan SP document; consequently, for the purposes of the SADPD a set of specific strategic aims have been prepared. These 11 aims are supported and are consistent with the Cornwall LP and the NPPF, however, they do not reflect the natural environment including the landscape and setting of the settlements. In parallel with Strategic Aim 8 which references the historic environment a similar aim should be included to reflect the natural environment. In accordance with the NPPF paragraph 109 the planning system should contribute to and enhance the natural and local environment by “protecting and enhancing valued landscapes. Geological conservation interests and soils…”

3. Do you agree with the strategy text relating to the sections Overarching Strategy, Economic Growth, Retail and Housing?

Yes / No

If No, please indicate what elements you disagree with (including paragraph numbers where possible) and how you would like it amended.

The strategy of supporting the town centre and reconnecting the towns to the water front is supported in principle although there are some details comments in respect of the proposed sites for residential development.

4. Do you agree with the proposals set out within the infrastructure section?

Yes / No

If No, please indicate what elements you disagree with (including paragraph numbers where possible) and how you would like it amended.

No comments.

B.0273/SHF 09/11/2016 Page | 2 5. Do you support the proposed allocations, and their policy wording, that are set out for the town / conurbation in question?

Yes / No

Some of the proposed allocations are supported whereas objections are made to other proposed allocations in the SADPD. Detailed comments are set out below.

If No, please indicate which allocation(s) you would like amended, highlighting the site’s reference code, and set out what you dislike about the site and/or its related policy (If you would like to make comments on more than one site, please ensure you clearly indicate which comments relate to which site)

Pegasus on behalf of our client Bolitho Estates welcome the inclusion of PZ H4 and PZ H7 i.e. Trannack and Poltair respectively. We have promoted these sites through the SHLAA and have also prepared a high level indicative site layout for Trannack. We continue to maintain our objection to PZ-H8 Heamoor.

PZ H4 Trannack The site has been promoted in the SHLAA and in response to consultation on the Cornwall Local Plan and an indicative figure of 290 dwellings was proposed. The site is not within or in proximity to a designated AONB or AGLV. The Council’s SA Appendix 1 states that: “The landscape assessment concluded that some of the site has an intermediate overall landscape assessment. Part of the site to the west has a high overall landscape assessment. Although the site is in proximity from the coast at its nearest point, the site is not visible from offshore, so seascape will not be affected.” A Landscape and Visual Impact Assessment will be prepared to support any future planning application. As illustrated in the Accessibility Assessment for the Urban Extension in December 2010, the area is well related to existing facilities and services and employment areas. It is accessible to the town centre and neighbourhood centres - Appendix B of the Urban Extension Assessment shows the area to be within 400 m of the neighbourhood centre and within 800m of the primary and secondary schools. The attached Facilities Plan {Appendix 1} prepared by PFA Consulting demonstrates the sustainability credentials of the site at Trannack. Land at Trannack can assist in meeting the development needs of Penzance. It is located within the overall envelope for Penzance. The area could be brought forward in a phased development. Development of the area would not destroy views from the rural areas due to the topography, neither would it increase urban sprawl nor link the town to outlying villages. The development can be contained with the boundaries of the site promoted in the SHLAA. Pegasus have prepared a concept layout plan {Appendix 2} based on a landscape assessment of the area which is included with these representations. PFA

B.0273/SHF 09/11/2016 Page | 3 Consulting have prepared Plans showing a potential access proposed from the A30 roundabout {Appendix 3}.

Comments on the Additional Requirements and Considerations: - a) The total number of approximately 290 dwellings is supported.

b) The additional requirements and considerations indicates that a requirement of 25% of the dwellings should be provided as accessible homes plus some of the dwellings should be specialised housing (including extra care housing).

Whilst affordable housing is supported in principle, this must be subject to viability testing. It is not clear what the need is for specialised housing including extra care in the Penzance area, and if this is required in addition to the amount of affordable housing this could undermine the viability of the site. {this would apply to all sites}. It is noted that A Housing Mix Supplementary Planning Document will be prepared to give further guidance on how Policy 6 of the Cornwall Local Plan should be addressed.

c) Public Open Space – it is noted that the additional requirements states that “At least 69.4sqm of public open space per dwelling should be provided, in line with the Penzance & Newlyn Green Infrastructure Strategy and the minimum size thresholds within Table 1. Some of this open space can be provided on adjacent land to the east of the allocation. Delivery of this space will also act as the mitigation necessary to address recreational impacts upon the Marazion Marsh Special Protection Area (SPA).”

The concept plan attached at Appendix 2 sets out the design principles and opportunities and constraints that underlie the concept. The main access is from the A30; a secondary vehicle access is shown from Polmennor Road, which can be an emergency access. Whilst a site of this scale does not necessary require secondary access, an emergency access would be appropraiate for the number of dwellings. The concept plan shows a potential footbridge across the A30 to link to the footpaths. There will be additional pedestrian access into the site, the concept plan shows a proposed recreational walk and /or a trail linking to the viewing area at the top of the hill. A new linear park to the south can be included in the scheme along the stream and along the steeper parts of the site. The Council state that the open space can act as mitigation for recreational impacts on Marazion Marsh which is some distance away, it is not clear how the Council have come to this conclusion.

d) Properties should be located away from the southern extremity of the site along the A30 ensuring that properties are not built in the flood zone.

This is supported, in accordance with the NPPF residential development will not be located in the flood zone. The concept plan illustrates a linear park to the south along the stream and along steeper parts of the site.

B.0273/SHF 09/11/2016 Page | 4 The Environment Agency Mapping indicates that the site is not within flood zone 2 or 3 and therefore is acceptable for development. Cell 6 which covers the wider area than the proposed allocation in Table 7 of Appendix A of the Council’s Environmental Constraints Assessment indicates that there are water courses along the north western and southern boundaries of the Cell which are liable to flood and are within zone 2/3b. Appendix 1 SA Review states that “Flood risk assessment demonstrates the proposed use is compatible with the Flood Zone status of the majority of the site.” The evidence base goes on to state that although the development will have potential negative impacts on water related issues, appropriate implementation of SUDS can mitigate these issues. A Flood Risk Assessment will be provided as part of the supporting documentation for the planning application.

e) Vehicular access to the site should be via the A30, with only pedestrian connections on to Polmennor Road.

This is supported and a potential access scheme has been prepared by PFA Consulting (Appendix 3), however, for a development of that scale it would be appropriate to have an emergency vehicular access which would also provide access for cyclists and pedestrians. A Transport Assessment including a Travel Plan will be prepared as part of the supporting evidence for any planning application.

f) It is expected that appropriate pedestrian connections are created to the south and west of the site. The development should seek to provide pedestrian linkages towards Heamoor. Furthermore, pedestrian crossing point(s) should be delivered on the A30, as well as other design / landscape measures to promote traffic calming; in doing so ensuring an appropriate capacity for the road is maintained.

The concept plan attached at Appendix 2 illustrates that public open space can be provided in accordance with the emerging plan. Up to 290 dwellings proposed at a density of 33 dwellings per hectare. The main routes run along the contours, short lengths of secondary street run down the slope to limit engineering and enable inclusive access and manoeuvrability for people. The Concept Plan limits development to the south of the site where levels are a constraint and a setback to the stream can then be created. The creation of linear park along the southern site opens up access for the rest of Penzance to access the existing Public Rights of Way. Limit development to the east of the site where it would be visible when viewed from the east. Access to the site is proposed from the A30 at the Treneere roundabout, Plans have been prepared which show a preliminary horizontal and vertical alignment for the access road off the roundabout. There is a short length of access road which then splits east and west in order to work with the contours of the site. Given the topography, retaining walls will be common

B.0273/SHF 09/11/2016 Page | 5 place across the site, as will embankments/cuttings. In order to reduce the visual impact of the wall at the entrance, it could be clad in local stone or be constructed in a modular form that allows planting within the structural elements. g) Planning permission for the development of only part of the site will not be granted, unless it is in accordance with a masterplan / concept plan for the entire site.

The area is in single land ownership and therefore a concept plan has been prepared for the entire site. In order for the necessary infrastructure requirements to be addressed the land should come forward in its entirety.

PZ H7 Poltair Additional Requirements & Considerations a) A residential development delivering approximately 30 dwellings. At least 25% of the dwellings should be provided as ‘accessible homes’.

In principle the proposed allocation of the site is supported, although it is considered that a higher number of dwellings could be accommodated on the site whist still respecting the setting of the listed building of Poltair House. Pegasus has promoted the land at Poltair through the SHLAA and in response to previous consultations. An opportunities and constraints plan was prepared in July 2014 and submitted to the Council. The plan indicated that the potential development area of 2.5 hectares could accommodate approximately 100 dwellings. The plan took into account the Grade II listed building, the trees covered by Tree Preservation Order and illustrated a potential vehicular access from the B3312 and various links for pedestrian access using existing access points. The concept included areas of public open space, potential new planting to mitigate views from the listed building and recognised that the existing tree belts visually contained the site.

b) The design solution for the site must ensure the appropriate consideration is given to the protection of the setting of the Grade II listed Poltair House to the north of the site.

In order to refine the concept plan and further support the development of the site a heritage impact assessment was undertaken by Pegasus in November 2015 and submitted to the Council (See Appendix 4) This assessment concluded that notwithstanding the considerable weight given to the protection of the setting of the Listed Building as required by the Planning (Listed Buildings and Conservation Areas) Act 1990, and therefore the existing relationship between the Potential Development Site, there is scope for the addition of residential development within the Potential Development Site so long as it respects the setting of the hospital building in a sympathetic and considered manner (the Potential Development Site comprises 5.57 hectares gross) and but in terms of developable area approximately 2 hectares could be brought forward for up to 80 dwellings (

B.0273/SHF 09/11/2016 Page | 6 see Appendix 5). This is a larger area than currently proposed in the SADPD which is only 1.3 hectares on land to the west of the site. As set out in the Heritage Impact Assessment, the Listed Building is set within its own distinct curtilage and its significance is on the whole focused around the building itself, although it should be noted that the significance of the building has been compromised both internally and externally by the various alterations made to it through its institutionalisation. However, there is a historical association with the fields to the south which form the Potential Development Site due to the retained gap in the tree belt and the views across the current agricultural land which contribute to the setting of the Listed Building, although this is restricted to the northern part of the Potential Development site, adjacent to the Listed Building. The western part of the Potential Development site is much less sensitive to change, and would be suitable for development which would not impact upon the significance of the Listed Building. Similarly, due to the establish landscape belt which runs across the site, there is also scope for the redevelopment of the southern parcel of the Potential Development Site. A key consideration will be the access into the site which will need to be carefully considered to balance highway safety requirements whist ensuring that the tree belt which surrounds the Potential Development Site will be protected. The additional requirements and considerations indicates that a requirement of 25% of the dwellings should be provided as accessible homes plus some of the dwellings should be specialised housing (including extra care housing). Whilst affordable housing is supported in principle, this must be subject to viability testing. It is not clear what the need is for specialised housing including extra care, and if this is required in addition to the amount of affordable housing this could undermine the viability of the site. {this would apply to all sites}

c) A contribution equivalent to the delivery of 69.4sqm of public open space per dwelling should be provided, in line with the Penzance & Newlyn Green Infrastructure Strategy. This money should be used to upgrade the lawned area to the east of the site, in front of the listed Poltair House. The open space should be enhanced to provide a formal park area, which will act as an enhancement to the setting of the historic asset.

The Heritage Impact Assessment considered that whilst the Potential Development Site (as proposed by Pegasus on behalf of our client) is not integral to the historic significance of the Grade II Poltair Hospital building, it does contribute to its setting, as the gap in the tree belt has been retained over the past 150 years to allow for an outlook south across the fields to the trees to the south. The significance of the Listed Building lies within the fabric and design of the building as well as its direct setting and designed curtilage, although this has been compromised by the institutionalisation of the building and the various unsympathetic extensions. In addition, the original plot which the building sat within has been variously divided, with the walled garden and associated outbuildings to the west being severed from the main building. As set out above, part of the Potential Development Site, does contribute to the setting of the Grade II Listed Building due to the long established gap in the northern tree boundary which has historically afforded views from the

B.0273/SHF 09/11/2016 Page | 7 property across the agricultural fields to the south. These views are currently truncated by the central miscanthus belt which runs across the centre of the field. The building itself is well contained within its own boundaries, with public views towards the building being limited to long distance glimpsed views across the long established tree cover which surrounds the property. There are a number of options available for the development of the Potential Development Site, however, due to the considerable statutory weight that is attached to the protection of the setting of any Listed Building, it is important that this is the key consideration of any proposals for the development of the adjacent site. The most sensitive section of the Potential Development Site is the northern section which is in closest proximity to the Grade II Listed Building to the north. It will be important that the gap in the tree line is retained, albeit the boundary landscaping could be enhanced. A sense of openness should also be retained within the area of the gap in the northern tree boundary to allow the existing sense of connectivity between the two sites to be retained. This area could be the focus for the associated open space which would be required in association with the development of the site. The western section of the Potential Development Site is less sensitive to change in terms of the relationship with the Listed Building as there is no direct relationship between this and the Listed Building, therefore this should be the focus for any new development. Similarly, subject to the strengthening of central landscaping belt which runs east west across the centre of the site, there is scope for development in the southern sector of the Potential Development Site, without a significant impact upon the historic interest of the Listed Building. (see attached Opportunities and Constraints Plan). A further key consideration will be the access into the site. The existing access is through a field gate in the south west corner of the site from the single track road which runs along the sites boundary and serves the properties to the north of the site. Any new access into the site would need to seek to minimise the loss of any of the established trees along the boundary of the site, and the impact this would have upon the character of the site. Additionally, any new access would need to be kept away from the northern boundary of the site, so as to not impact upon the more rural setting of the Listed Building d) Vehicular access should be provided via the B3312

As illustrated in the initial Concept Plan access can be taken from the B3312.

e) Planning permission for the development of only part of the site will not be granted, unless it is in accordance with a masterplan / concept plan for the entire site.

The site is in single land ownership so a concept plan would be prepared for the entire site.

B.0273/SHF 09/11/2016 Page | 8 PZ-H8 Heamoor

Pegasus on behalf of our client, object to the inclusion of Heamoor as a proposed allocation for residential development of 435 dwellings. We have previously made representations when the Cornwall Local Plan Strategic Policies was being prepared, in particular when the consultation took place on the Community Network Areas which included the Urban Extension Assessment in February /March 2012. At that time, we considered that the site at Heamoor conflicted with the objective for the Environment and detailed objections were submitted. We are also aware of the representations submitted then and more recently by the National Trust. Although the proposed additional requirements and considerations now recognise the proximity of the site to the various heritage assets, our objection in principle to this site being allocated in the SADPD remains. The ability of the site to deliver the development anticipated, and associated infrastructure, without causing unacceptable levels of harm to heritage assets, i.e. the setting of Trengwainton, remains unproven. The site is also within an area assessed as of highest landscape value (Landscape Assessment Maps – Cell 9) and the whole site is Grade 2 Agricultural Land, so it will result in a loss of the best and most versatile agricultural land. The Council’s latest evidence base for the Community Network Area has been reviewed in particular the Penzance and Newlyn Housing evidence report of September 2016, it is noted that the Appendices A – I do not include the Heritage Impact Assessment. The Council have set out a 13 Step assessment process. Step 3 is an assessment of the Environmental Constraints, this involved an assessment to record the relationship of different Cells with significant and less significant environmental features. However, there is no reference to any Heritage Assets apart from the heritage coast. Step 12 outlines the sites to be submitted to the Core Strategy Strategic Sites consultation (this is the same text as in January 2012 consultation on the Community Network Areas). The results of the consultation in 2012 are then set out and the options refined further in 2015. Step 13 finalises the options to be included in the SADPD. It is noted that reference is made to Step 13c which is a site review and at this stage a further Heritage Assessment was undertaken of Heamoor. The Trengwainton Impact Assessment was prepared for the Council by Parsons Brinkerhoff in April 2015 this was in part prepared in response to the National Trust Trengwainton Setting Study produced in January 2015 prepared by the Nicholas Pearson Partnership LLP. The Housing Evidence Report (page 42) indicates that in response to the National Trust’s Trengwainton Setting Study (Jan 2015), “The Trengwainton Impact Assessment was prepared for the Council by Parsons Brinkerhoff in April 2015”, and that as a result of this study the site boundary was amended to mitigate against the issues raised. However, no mention is made in the Housing Evidence Report of the further evidence prepared by the National Trust, which includes the following reports previously submitted to the Council as evidence:

B.0273/SHF 09/11/2016 Page | 9  White Young Green, Trengwainton House and Garden: Heritage Impact Review; Feb 2016  White Young Green, Trengwainton Park: Landscape & Visual Appraisal; Feb 2016.  Symbiosis Consulting, Report on the Overall Condition and Vulnerability of Trees: Trengwainton Garden; Feb 2016 Nor is mention made in the report of the Council’s latest evidence; The Heamoor Heritage Impact Assessment (Jan 2016) and the further site mitigation and boundary revisions which lead to the current site allocation proposal. https://www.cornwall.gov.uk/media/19391527/j243-historic-assessment-for- site-allocations-heamoor-january-2016.pdfallocations-heamoor-january- 2016.pdf In fact, the proposed site as set out on page 32 of the SADPD consultation does not reflect the findings of the Council’s latest evidence referred to above. The January 2016 report clearly concluded on the extent of the buffer zones and the tree planting, these have not been included in the proposed allocation. The report recommended: “The reduced area of land can appropriately be allocated for housing development within the Cornwall Site Allocations DPD subject to the measures identified within this paper and within the WSP Parsons Brinkerhoff - Heamoor Heritage Impact Assessment – Revised October 2015. Such heritage mitigation measures will be fully referenced within the planning policy that will accompany the allocation within the Allocations DPD, and development will thereafter be assessed and considered based upon the level of compliance with the identified requirements of the policy. Appendix 3 illustrates how the protection of the historic environment has influenced the potential allocation of land at Heamoor through a series of plans illustrating the chronology of changes to the extent of land being brought forward.” In Step 13d (Appendix I; Sustainability Appraisal) – For Heamoor, the SA Results Table, under the SA Historic Environment objective, identifies a potential for ‘substantial harm’ to heritage assets. The NPPF para 132 states that: “As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional” Para 133 of the NPPF states: “Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss…” As mitigation the Council’s SA only suggests that assessments need to be done at the appropriate masterplan stage – which is necessary to “inform extent of development site and design solutions.” This does not address the issue of substantial harm. The Cornwall Site Allocations DPD Heritage Assessments (September 2016) is even more misleading where it concludes that the site is subject to minor impact

B.0273/SHF 09/11/2016 Page | 10 once the DPD policy mitigation is taken into account. The impact appraisal for the Trannack site is also subject to minor impact with DPD policy mitigation, but the two sites are not comparable given the proximity of Heamoor to Trengwainton which is a Grade II* Registered Park and Garden. Step 13e: Site Priority Assessment. For Heamoor, in relation to the ‘Historic Environment’, the summary results in Table 11 indicates a ‘Red’ traffic light score, meaning that development is likely to undermine the SA objective, and that; “Development of the site is unlikely to positively contribute to the wider town strategy.” However, the site is mistakenly given a ‘+’ for Historic Environment. The National Trust has subsequently commissioned a review of the Council’s Heamoor Heritage Impact Assessment (Jan 2016), which has recently been published:  Response to Heritage Impact Assessment: Heamoor, Penzance (Bidwells; October 2016). The National Trust are submitting this report as new evidence in support of their representations the SADPD. The conclusion of this new evidence is that there are a number of areas where harm remains unresolved and that there is limited scope to address that potential harm based on the current scale of the site allocation. That opinion is reinforced in part by the comments from Historic England in their letter dated 13 May 2016, where they point to remaining areas of concern associated with the Heamoor site allocation. Indeed, issues surrounding the proposed approach road from Roscadghill are deemed by Historic England to be ‘critical’ with the potential for ‘substantial’ harm. Historic England have also made clear that the current capacity of the site should be clarified once regard is had to all the necessary mitigation, including an increased buffer to Boscathnoe Lane. It is concluded that the Council’s allocation of 435 dwellings for PZ-H8 (Heamoor) is not a robustly evidenced figure of the sites capacity without causing unacceptable levels of harm to heritage assets and their setting. Therefore, it remains uncertain how far such a proposal would meet both the Local Plan Spatial Strategy objective to “protect, conserve and enhance” the historic landscape and heritage (Policy 2 [d]), and the specific strategy aim for Penzance & Newlyn to “respect the historic environment.” As a Pegasus on behalf of Bolitho Estate continues to strongly object to the proposed allocation.

PZ -H9 St Clare We are aware that Bolitho School closed on 16th August 2016 and consequently there may be scope to increase the size of the allocation.

PZ -10 Mount Misery With regard to the two fields in Bolitho Estates ownership that part of the proposed allocation of PZ -10, Bolitho Estates have no plans to release the two fields at present.

B.0273/SHF 09/11/2016 Page | 11 6. Is there an alternative site (or sites) that you would like to propose? If so, please complete the following questions:

(If there is more than one site that you're proposing, please label each of your comments clearly)

a) The location of the site that you would like to propose b) The type and scale of development to be delivered on the site(s) c) The site(s) within the Site Allocations DPD that you believe your site(s) should replace (please state the site allocation reference) d) The reasons why you believe your proposed site(s) is better than the site(s) you wish to replace it with

No further comments.

7. This question only relates to Falmouth and Penryn

B.0273/SHF 09/11/2016 Page | 12 REP 0155

From: McKenna Jim CC Sent: 14 November 2016 11:08 To: Brown Matthew (Planning) Subject: MOUNT MISERY

Dear Matthew,

Following our recent discussion and your subsequent conversation with Edward Bolitho, can you confirm that the Mount Misery proposal has been removed from the indicative housing sites document please?

A response today would be appreciated if possible.

Regards,

Jim

Jim McKenna Cabinet Member for Adult Care Independent Cornwall Councillor for Penzance Promenade Ward

From: Brown Matthew (Planning) Sent: 14 November 2016 11:47 To: McKenna Jim CC Subject: RE: MOUNT MISERY

Hi Jim

Not yet – we will be reviewing the representations following the conclusion of the consultation and recommending amendments to the document to local members in December.

However, the Pegasus Planning’s representation on behalf of Bolitho Estates indicates that they do not intend to release the two fields in their ownership. As these fields are considered fundamental to the delivery of the Mount Misery allocation, to reprovide important open space for the community, then I will be recommending that this site allocation is removed from the document

Regards

Matthew REP 0160 a) the location of the site that you would like to propose b) the type and scale of development to be delivered on the site(s) c) the site(s) within the Site Allocations DPD that you believe your site(s) should replace(please state the site allocation reference) d) the reasons why you believe your proposed site(s) is better than the site(s) you wish to replace it with

8. Please rank the following sites 1 to 5 in order of preference to provide student accommodation

9. Feel free to make any additional comments with regard to the document or its evidence base.

10. Equality Monitoring

Please enter your postcode Please give your age How do you describe your sex? How do you describe your ethnic origin? (Please read carefully before selecting the ethnic group that you feel most closely reflects your background). Do you consider yourself to have a disability? Is there anything we can do or put in place which would make it easier for us to offer you an equal service? (For example documents in large print, hearing loop etc). Do you need someone to help you understand information? (For example someone to read documents with you or an interpreter). It would help the Council to know of any barriers you have faced when dealing with us. Cornwall Site Allocations DPD – Questionnaire November 2016

Gulval Village Community Association

Part 2 Q1 Town – Penzance with surrounding villages

Q2 Vision Aims Objectives para. 2.24 SUPPORT reference to GI corridors that can provide green links, offering biodiversity and other benefits but also “a mechanism to maintain the separate identifies of the various communities that make up an area, where appropriate”.

Vision 3.6 – OBJECT to the narrow emphasis on becoming a premier tourism destination; where is the Vision for the local community?, opportunity and quality of life for residents? housing for all, including affordable? protection of the area’s high environmental and historic quality for its own sake as well as for residents and visitors? wider economic base beyond tourism driven industries? This compares poorly with the Visions of other major towns. para. 3.8 SUPPORT Aim 9 (to maintain individual and distinctive characters of Gulval and other villages)

OBJECT to the omission of a Strategic Aim to support and develop local food and farming - agricultural land around Gulval and Penzance is of the highest quality and should be safeguarded in line with Objectives 1 and 9 in the Strategic Policies (SP) document - to support both new and traditional businesses including farming. and to make the most of our environment including supporting local food. production.

OBJECT to the omission of a Strategic Aim on affordable housing given the significant need in the area.

Q3 Strategy text 3.16 SUPPORT the principle of maintaining separate identities of Penzance and nearby villages 3.18 and 3.44 SUPPORT the acceptance of the A.30 being ‘permeable’ – this should be a priority for the Plan, to ensure urban scale housing sites are well integrated with the town and town centre. 3.20 OBJECT.to omission of farming as a traditional industry. 3.40 SUPPORT reference to maintaining distinct identities of different communities. 3.41 OBJECT to use of ‘incorporating’, AMEND to ‘with’. OBJECT to omission of definition of ‘accessible’’ homes OBJECTto omission of a clear emphasis/target for ‘affordable’ homes in every allocation..

Q4 Infrastructure Proposals Transportation 3.56 SUPPORT ‘permeability of A30’ strand.

Green Infrastructure – OBJECT to the omission of green infrastructure corridors that maintain the separate identifies of the various communities in the wider Penzance area. A strategic Aim of the plan is to ensure that the settlements of Penzance, Newlyn, Heamoor, Gulval and Long Rock maintain their individual and distinctive characters This is an important element of the plan coming from previous consultations and Community Network Area objectives. Para. 2.24 refers to GI corridors that can provide green links, offering biodiversity and other benefits but also “a mechanism to maintain the separate identifies of the various communities that make up an area, where appropriate”. AMEND the plan to - extend the green corridor in Newlyn Coombe to include the wider valley and Mount Misery (important to the separate identity of Newlyn as well as river corridor, Mount Misery footpaths, links to historic feature and open countryside including Trereife; trees and hedgerows); - include the green corridor of Chy an Dour stream with Ponsandane Farm and Ponsandane Field (important to the separate identity of Gulval and setting of Penzance, and strongly supported through local community consultation, as well as the two river corridors, footpaths linking coast with existing and proposed residential areas in Penzance and beyond to Heamoor village and open countryside including Trevaylor, Trengwainton). The opportunity exists, with appropriate safe A30 crossing points, to incorporate the southern edge of the proposed Trannack allocation in this corridor. ; - extend (and amend) the green corridor of Posses Lane to include the wetland habitat and fields north of Jelbert Way (important to the separate identity of Gulval Churchtown as well as biodiversity, potential for enhancing footpath/cycle links between coast, Gulval Churchtown and open countryside including Gulval Carn, Trevaylor, Tolver/Tremenheere Woods and St. Michael’s Way); - include the narrow but important green corridor of Tolverth/Tolver stream (important to the separate identity of Long Rock as well as river corridor, links to footpath / cycle route between coast and open countryside including Tolver/Tremenheere Woods and St Michael’s Way)

Figure PZ4 . Posses Lane to Trenow (Gulval) is shown as a new/enhanced cycle/pedestrian route connecting coast and countryside. OBJECT While the principle is supported the route shown involves a new route across privately owned land which is considered unnecessary and unrealistic; potential cycling use of the existing footpath between Churchtown and Branwell Lane, which is inadequate to serve both uses safely, and the use of a very dangerous stile/exit on to the B3311 (Gulval – St. Ives road). at Keneggy. AMEND figure PZ4 to show a more realistic, safer route via Churchtown using the alternative existing routes available.

Poniou to Gulval – safe cycle route on Poniou Lane and Gulval/Ludgvan road needed (not dual use of existing footpath).

Q5 Proposed Allocations and Policy wording

PZ-H2 Posses Lane OBJECT - increase in traffic on to Posses Lane, to and through Churchtown as well as to Jelbert Way, harmful impact on open break between Eastern Green and Gulval Churchtown, lack of integration with an existing residential area, a poor quality residential environment with adjacent commercial uses, security lighting, potential helicopter flight path etc

PZ-H3 Gulval Trevarrack SUPPORT requirement for pedestrian links to and through the site to Foxes Field, Pendrea Road, Trevarrack Noweth (wrongly identified as Chynoweth Gardens) and the footpath to the north of the site. This is a key objective of the Gulval community’s Plan for the village. OBJECT to the reference to off site contributions for open space. AMEND the text – provision should be made within the site for at least part of the open space provision for Gulval in line with the community’s Plan for the village and a long standing objective to provide a children’s play space on this central and accessible site. A play space to serve the village, not just the development, could be included with a minimal increase in density (which would be in keeping with adjacent terraced housing, characteristic of Gulval). Provision on the north west boundary would help retain the open and attractive character of the footpath to the north of the site and, with planting, safeguard the privacy of adjacent dwellings. There is also potential for dual use of the surface water management area in the south west of the site for a small community seating space.

PZ- H11 former Barn Club site SUPPORT in principle as a previously developed site. OBJECT to the inclusion of a requirement for a footpath on the western boundary UNLESS that is linked to better traffic management and pedestrian safety measures for Trevarrack Lane. There should be no expectation or encouragement for increased pedestrian use of the lane as it is which is narrow and hazardous.

PZ-H4 Trannack SUPPORT proposal in principle as an extension to the Penzance urban area. SUPPORT (e) vehicular access to the site to be from the A 30 and no vehicular links to Trannack Lane/Polmennor Road to the north... OBJECT to the additional requirements (a) that the site should be seen as an extension of Heamoor. Development of this scale is only justified by the housing requirement for Penzance. It should be seen as an extension of Penzance. The emphasis should be on linking it to the town and town centre, including primary schools (Pensans and St. Mary’s RC which are both closer than Heamoor Primary), Humphry Davy Secondary school which is closer than Mount’s Bay, proposed Health Centre at St Clare etc. AMEND to prioritise integration with the town and town centre. OBJECT to pedestrian links on to Polmennor Road/Trannack Lane. The lane is narrow in many places and is unsafe for pedestrians. Pedestrian routes to Heamoor village and Mounts Bay Academy should be from the south west of the site to Parc Mellan and/or to the existing footpath and footbridge west of the site, and so to Treneere Lane which provides a safe pedestrian route to Heamoor as well as to the existing crossing under the A 30 to Manor Way and on to the town centre.

PZ-H5 Polmennor Road, Heamoor OBJECT to the allocation – in view of the existing congestion in Heamoor village it is likely that traffic will increase on Polmennor Road/Trannack Lane to the east of the site and so to the A 30, adding to the traffic through Gulval, especially on to the B3311 (St Ives road) where it is narrow and unsafe for pedestrians. . REP 0184

Origin3 Ref: 16035

Cornwall Allocations DPD Strategic Planning Cornwall Council Dolcoath Avenue Camborne Cornwall TR14 8SX

14th November 2016

Dear Sir or Madam

Re: Representations to Cornwall Allocations Development Plan Document on behalf of Taylor Wimpey Strategic Land

On behalf of my clients, Taylor Wimpey Strategic Land, this letter provides representations to the preferred options consultation on the Cornwall Allocation Development Plan Document (September 2016). Taylor Wimpey Strategic Land support Cornwall Council’s progress with the site allocations component of the development plan. Notwithstanding that, for the reasons set out below these representations raise concern over the lack of certainty provided by the preferred option DPD. The representations also have specific regard to land north of A390 (Newquay) (see enclosed plan) and Longrock (Penzance).

General comments on the DPD in respect of the Development Plan

The approach taken by Cornwall Council to prepare a two tier Local Plan is supported but only on the basis that when the tiers are combined it provides the necessary minimum strategic guidance across both documents. The Local Plan currently identifies a numerical housing and employment requirement for each Community Network Area (CNA) but does not go any further. The DPD must therefore address, as a minimum, the policy gaps left by the higher tier plan. These gaps include necessary detailed guidance on housing and employment provision through the allocation of specific sites (discussed further below with regard to housing and employment).

The DPD seeks to address the necessary minimum requirements for some of the CNAs, but not others. When coupled with the limited scope of the Local Plan, it leaves an incomplete guidance document for Cornwall which is contrary to the National Planning Policy Framework (NPPF).

Origin3 is a limited company registered in England and Wales. Company Registration No. 6370231 Page 1 Registered Offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Paragraph 47 of the NPPF explains Local Planning Authorities (LPAs) must ensure Local Plans meet the full objectively assessed need (OAN) for market and affordable housing. Coupled with this, the Local Plan Making section of the NPPF (paras 150-182) make a clear distinction between local plans prepared by the LPA and neighbourhood plans prepared by community based neighbourhood forums. When read as a whole, the NPPF is clear that it is for the Local Plan to demonstrate that the full OAN is capable of being met through the identification of sufficient sites.

The adopted local plan only identifies the OAN as a numerical requirement it does not address how it will be met through allocated land and other accepted sources of supply such as planning permissions. To be consistent with paragraph 47 of NPPF, the SADPD must not leave large parts of the housing supply to be identified through neighbourhood plans.

The DPD should also demonstrate the following as set out in the NPPF given that the first part of the Local Plan does not:

- Identify what sites constitute 5 year land supply plus buffer.

- Identify specific developable site/ broad locations for years 6-10.

- Identify where possible specific developable site/ broad locations for years 11-15.

This information should be available for consultation and scrutiny when determining if sufficient land supply is likely to be made available. Without this information it is impossible to establish whether sufficient sites are being identified in the DPD to meet the minimum requirements of the NPPF. The DPD should also make clear that the local plan requirements for each CNA is an absolute minimum requirement.

In a near identical manner to housing sites, the DPD only identifies employment sites in some CNAs and it is therefore impossible to establish whether sufficient employment provision is going to be capable of delivery.

Furthermore, the DPD appears to limit itself to the identification of B1a (office) and industrial land. This seems to be wholly at odds with the Government’s approach to a much broader assessment of economic need in order to build a strong and competitive economy.

Land north of A390, Newquay

It is clear that the DPD does not allocate sites in a manner which is consistent with those identified in the Newquay Growth Area and the Council’s masterplan for the Newquay Growth Area. Land north of the A390 should be allocated in the DPD to provide greater certainty for the identified growth area and to ensure its

Origin3, Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 2

REP 0196

Cornwall Site Allocations Document Response from Humphry Davy School, Penzance

Part 2 Q1 Town – Penzance with surrounding villages

Q2 Vision Aims Objectives Vision – OBJECT Too much emphasis on tourism destination and the visitor experience rather than that of the local community. The vision should be more balanced,.especially when compared with the Visions of other major towns – where is the emphasis on opportunity and quality of life for those who live in Penzance and the surrounding area? Where is the emphasis on broader, better paid future employment opportunities for our young people?

Q3 Strategy text 3.18 and 3.44 SUPPORT the acceptance of the A.30 being „permeable‟ – this should be a priority for the Plan, to ensure urban scale housing sites are well integrated with the town and town centre.

Q4 Infrastructure Proposals Education 3.46 OBJECT to wording “the location of the proposed growth is likely to put greater pressure on schools to the north of the town”. While the scale of housing being proposed west of Heamoor is likely to put pressure on that school the emphasis should be on integrating other large sites, such as Trannack, with the town and its primary schools. 3.47 OBJECT to reference to capacity for expansion only at Mounts Bay. Both schools have capacity to expand within the confines of their existing site to meet parental choice. No distinction should be made in the text.

Q5 Proposed Allocations and Policy wording PZ-H4 Trannack SUPPORT proposal in principle as an extension to the Penzance urban area. OBJECT to the additional requirements (a) that the site should be seen as an extension of Heamoor. Development of this scale is only justified by the housing requirement for Penzance. It should be seen as an extension of Penzance. There should be a high priority on linking it to the town and town centre, including primary schools (Pensans and St. Mary‟s RC which are both closer than Heamoor Primary), Humphry Davy Secondary School (which is closer than Mount‟s Bay Academy),the proposed Health Centre at St Clare and other facilities. AMEND text to prioritise physical integration with the town and town centre. OBJECT to pedestrian links on to Polmennor Road/Trannack Lane. The lane is narrow in many places and is unsafe for pedestrians. Pedestrian routes should be from the south west of the site to Parc Mellan and/or to the existing footpath and footbridge west of the site, and so to Treneere Lane which provides a safe pedestrian route directly to the existing crossing under the A30 to Manor Way or Coombe Lane and on to the College, schools and the town centre, as well as west to Heamoor. . REP 0209

Origin3 Ref. 161104.CD.01.UC

Cornwall Allocations DPD Strategic Planning Team Cornwall Council Dolcoath Avenue Cambourne Cornwall TR14 8SX

14th November 2016

Dear Sir/Madam,

Ref: Representations on behalf of Catesby Property Group Cornwall Site Allocations DPD Preferred Options Consultation, Sept 2016

Please accept this letter as a formal representation made on behalf of Catesby Property Group in response to the publication of the above referenced document. Overall, Catesby Property Group support Cornwall Council’s progress with the SADPD. It will in due course provide certainty to the development industry as well as establishing a more detailed framework within which development can be delivered. Similarly, support is given to the greater role that Neighbourhood plans are performing in Cornwall’s planning policy formulation. However, whilst this approach is intended to provide local communities with a greater input into the future growth of areas/ settlements, it does lead to somewhat sporadic development plan coverage which unfortunately is likely to be counterproductive for a number of reasons explained below.

With regard to Catesby Property Group, their specific interest relates to land at Gulval (see enclosed plan) which is located within the Penzance and Newlyn Community Network Area. This representation therefore focuses upon Chapter 3 of the SADPD as well as more general overarching comments. This letter concludes that the necessary planning assessment of sites leading to the production of Chapter 3 (Penzance and Newlyn) is not sufficiently rigorous enough to have selected sound sites in accordance with paragraph 182 of the NPPF. Furthermore, in arriving at the selection of sites, this has led to the discounting of reasonable alternatives such as land at West of Gulval. This representation provides the overarching case for the inclusion of land West of Gulval as a housing allocation.

Over-arching objections

 Incomplete Development Plan The approach taken by Cornwall Council to prepare a two tier Local Plan is supported but only on the basis that when the tiers are combined they provide the necessary minimum strategic guidance across both documents. The Local Plan currently identifies a numerical housing and employment requirement for each CNA but does not go any further. The SADPD must therefore address, as a minimum, the policy gaps left by the higher tier plan. These gaps include necessary detailed guidance on housing and employment provision and location through the allocation of specific sites (discussed further below with

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 1 Company Registration No.6370231 regard to housing and employment). It should also address the relationship between planned directions of growth at settlements and necessary infrastructure delivery.

The SADPD seeks to address the necessary minimum requirements for some of the CNAs such as Penzance and Newlyn, but not others. When coupled with the limited scope of the Local Plan, it leaves an incomplete guidance document for Cornwall which is contrary to NPPF (as set out below).

 Inconsistent with the NPPF requirements to address housing need Paragraph 47 of the NPPF explains that LPAs must ensure Local Plans meet the full objectively assessed need (OAN) for market and affordable housing. Coupled with this, the Local Plan Making section of the NPPF (paras 150-182) makes a clear distinction between Local Plans prepared by the local planning authority and neighbourhood plans prepared by community based neighbourhood forums. When read as a whole, the NPPF is clear that it is for the Local Plan to demonstrate that the full OAN is capable of being met through the identification of sufficient sites.

Cornwall Council’s Local Plan only identifies the OAN as a numerical requirement it does not address how need will be met through allocated land and other accepted sources of supply such as planning permissions. To be consistent with paragraph 47 of NPPF, the emerging draft SADPD must not leave parts of the housing supply to be identified through neighbourhood plans.

To demonstrate the scale of the concern, at present circa 25,000 dwellings of the 52,500 dwelling requirement are not currently planned for in the SADPD. Whilst a proportion of these sites may have planning permission already (as noted by the Local Plan Inspector in his Report), a significant number have not and will have no formal status in the development plan. Equally there is no guarantee that sites with planning permission will be started and in the short term the Council may find some permissions lapsing due to infrastructure and other economic burdens. Such sites could be left without the encouragement of an allocation in the SADPD which would result in uncertainty and concern about how they then form part of land supply.

The SADPD should also demonstrate the following, as set out in the NPPF, given that the first part of the Local Plan does not:

- Identify sites that provide the 5 year land supply plus buffer.

- Identify specific developable site/ broad locations for years 6-10.

- Identify where possible specific developable site/ broad locations for years 11-15.

This information should be available for consultation and scrutiny when determining if sufficient land supply is likely to be made available through the SADPD. Without this information it is impossible to establish whether sufficient sites are being identified in the SADPD to meet the minimum requirements of the NPPF.

 In consistent with the NPPF requirement to address economic need In a near identical manner to housing sites, the SADPD only identifies employment sites in some CNAs and it is therefore impossible to establish whether sufficient is going to be capable of delivery.

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 2 Company Registration No.6370231 Furthermore, the SADPD appears to limit itself to the identification of B1a (office) and industrial land. This seems to be wholly at odds with the Government’s approach to a much broader assessment of economic need in order to build a strong and competitive economy.

With regard to Penzance and Newlyn, the West Penwith CNA Employment Evidence Report (2016) is proactive in explaining the ambitions for reinvigorating this local community, but it focuses solely upon meeting the requirement for office and industrial space as set out on page 6 of the report. It, like many of the other assessments for other CNAs is too narrowly focused and ignores the requirement of paragraph 21 of the NPPF, in particularly, looking at a much broader range of business sectors and formulating policies that are flexible to rapid change.

With regard to Penzance, the approach of the SADPD ignores the substantial growth in the tourism sector and its specific needs with the exception of a reference to the Penzance to Isles of Scilly ferry link and a note in paragraph 3.21 of the SADPD that indicates the tourism offer should be enhanced.

Specific objections relating to Chapter 3- Penzance and Newlyn

 Objection to the overall housing supply figures The Penzance and Newlyn Housing Evidence Report (September 2016) provides some detailed breakdown of the components of housing supply based upon the OAN requirement for the CNA set out in the Local Plan (2,150 dwellings).

At this point is must be made clear that the 2,150 figure should not be expressed in Table PZ.2 of the SADPD as a target, it is a minimum requirement. Such a change would then accord with the discussions during the Local Plan examination with Inspector Emerson around Main Modification 15 and the wording changes he sought expressing the overall OAN as a minimum.

No objection is raised in connection with the completions figure of 255 dwellings (2010-2016) as set out in the Housing Evidence (Table 1) at an annual delivery of 42 dwellings, but this does need to be compared with an annual requirement of 107 dwellings for the period 2010 to 2030. It is self-evident that there must be significant local housing pressure already due to such a large undersupply and affects the application of a 20% buffer in this CAN.

No objection is made at this point in time against the 125 (<10 dwellings) permitted or under construction in Table 1 of the Housing Evidence as a minimum discount has been applied of 10% for non-implementation. However, objection is raised as a result of the same discount not being applied to commitments >10 dwellings and sites awaiting planning permission.

Objection is also raised with regard to the likely double counting of net additional urban capacity sites (24 dwellings) and net urban SHLAA sites, 6 dwellings which have no apparent prospect of being delivered within the early part of the plan period and would therefore conflict with the application of the windfall allowance (through double counting).

Objection is also raised in connection with the lack of evidence to support the windfall allowance for this area. There is no detailed breakdown of the time period assessed, or the types of sites that were identified to support the allowance. Paragraph 48 of the NPPF explains that LPAs must have compelling evidence that such sites have consistently become available in a local area and will continue as such. In the case of Penzance the work now completed, including the SHLAA, urban capacity, all help to identify

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 3 Company Registration No.6370231 the full range of development opportunities for allocation. Furthermore, the overall lack of planned growth in the past will have resulted in a heavy reliance upon windfall sites and is highly unlikely to be replicated in future years to the same degree.

Whilst there may be a case for a limited windfall allowance, the compelling evidence has yet to be presented to support the 306 dwelling figure in Table PZ.2 of the SADPD for this CNA.

 Objection to the selection of sites methodology Overarching concerns exist in connection with the way that the evidence base has been developed in order to consider reasonable alternative sites. Unfortunately, the flaws in the methodology have become sufficiently ingrained so as to affect the final SA for individual sites, which is unhelpful and misleading.

The principal concern regarding the methodology is the selection of Cells and particularly their scale and broad area coverage. Some Cells are closely aligned with the eventual proposed allocations, but others are much broader and encompass very different land character areas which then distort the way that some sites have been assessed in the subsequent SA work.

Catesby Property Group’s site at Gulval West for example, falls within Cell 6 of the Housing Evidence Report (September 2016), which appears by far the largest and encompasses land close to sea level then sweeps up and across the northern edge of Penzance. This large area incorporates very different landscape areas, neighbourhood patterns and planning designations such as AONB resulting in a diverse area. Unfortunately due to the way in which these diverse Cells are summarised, the conclusions that are then used to inform the SA become distorted at a site specific level and in the case of Gulval there has been no process of correction.

Before the SADPD is advanced any further it is therefore suggested that the SA is reviewed with the promoters of individual sites and any necessary corrections are made in order to address the original flaw of examining Cells that cover such large areas. Without this work, the SA would be unjustified and therefore adversely affect the soundness of the SADPD. Some of the detailed SA concerns in relation to Gulval West are set out below. The list is neither exhaustive nor detailed but it helps to understand the breadth of correction needed.

Objection to the selection of the following sites on grounds of soundness Notwithstanding the concerns raised about the methodology employed to select sites, the Housing Evidence Report SA Tables (Appendix i) raise significant areas of concerns where material planning matters do not appear to have been fully considered in the process of site selection.

Whilst this representation does not analyse all sites and all criteria at this stage of the consultation process, it highlights those matters of greatest concern and soundness. It appears that although some areas of concern have been raised in the SA, the level of materiality of these has not been clearly stated and in some cases is misleadingly understated. The impact of this has been to propose unsound allocations and ignore sound potential allocations such as land at West Gulval (also known as PNE4 in some documentation).

The areas of most concern and objection are as follows:

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 4 Company Registration No.6370231  PZ-H2 (Posses Lane) Land at Posses Lane appears to be a small field located to the east of Gulval which bears little relationship to the adjacent urban area. Being situated on the east of the settlement, it, like Gulval Central (below) is reliant upon a narrow and complex road network for access to the secondary school which is closer to West Gulval (our client’s land).

Examining the SA further, there are a number of unreasonably diverse judgements made when scoring this site and West Gulval against the SA objectives. A proper re-assessment of this site would demonstrate that:

- Climate factors for Posses Lane Gulval Central and West Gulval should all be the same. - Landscape factors for Posses Lane and West Gulval should all be the same. - Historic Environment factors for Gulval West should be at least the same as Posses Lane and Gulval Central or better.

A correct re-assessment of the Posses Lane SA summary would result in Gulval West supporting more of the SA objectives of the SADPD. For these reasons Cornwall Council should re-consider the reasonableness of selecting Posses Lane above West Gulval.

 PZ-H3 (Gulval Central) Land at Gulval Central is located to the east of the Gulval urban area which is reliant on a narrow and complex road network and there does not appear to be any detailed assessment to determine at a local level whether a severe highways impact would arise?

The whole site is Grade 2 agricultural land and as such is Best and Most Versatile. Given that reasonable alternative sites exist in the local area which would have a lesser impact upon BMV land (such as West Gulval), there is no economic argument to justify its loss as set out in paragraph 112 of the NPPF.

 PZ-H4 (Trannack) Land at Trannack lies to the north and west of Gulval West and relies upon Heamoor and Penzance for its services and facilities. Gulval West however relies upon Gulval for much of its local services and facilities. The importance of this distinction is that Gulval West benefits from easy access to local schools and services with good safe walking routes whereas future Trannack residents would need to cross the A30 bypass in order to access the same levels of services and facilities. Notwithstanding the facts, Trannack is proposed to be allocated as a sustainable site and Gulval West is unreasonably criticised with regard to school accessibility. Two conclusions follow from this:

- A site located on the outside of a dual carriageway will suffer from severance which severely limits its ability to promote social inclusion, thus affecting its sustainability credentials and therefore soundness.

- The SA is unjustly incorrect in its conclusions for Gulval West with regard to accessibility and social inclusion and should be recognised as sound in this and accessibility regards.

In addition to this key soundness matter, there are numerous inconsistencies in the way that Gulval West is incorrectly marked down in many of the SA objectives when compared with Trannack (and other sites).

 PZ-H8 (Heamoor)

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 5 Company Registration No.6370231 Whilst there are many inconsistencies in the way that some sites are scored and the impacts described across the whole of the SA, the most significant issue for this site is the impact upon the historic environment and particularly the adjacent Grade II* Trengwainton House and Gardens. The SA confirms substantial harm to this important National Trust visitor attraction but suggests this impact could be avoided through mitigation. Paragraph 132 of the NPPF makes it abundantly clear that substantial harm to assets with the highest significance (including Grade II* listed assets) should be wholly exceptional. In this case there is no need to allocate PZ-H8 and the approach should be to exhaust all reasonable alternatives first before considering whether to explore the option of trying to mitigate substantial harm.

The SA significantly underplays the statutory tests associated with the protection of assets with the highest heritage significance and the site should be removed from the plan.

Sat alongside the statutory NPPF test is the legal requirement of S.66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 which does not allow LPAs to treat the desirability of preserving the setting of listed heritage assets as a mere material consideration which can be weighted as the authority sees fit. The Barnwell [2014 EWCA 137 (civ)], Forge Field [2014 EWHC 1895 (Admin)] and Forest of Dean [2016 EWHC 421 (Admin)] Court judgements set legal precedent in this regard.

In the case of the SADPD, the accepted substantial harm at Heamoor cannot simply be weighted and balanced against other material considerations (as per the above judgements). With a range of reasonable alternative sites available such as West Gulval, that meet the spatial requirements of the Core Strategy for this CNA, the legal test cannot be met by Heamoor.

This matter was raised at the Local Plan examination by the National Trust and others and that Inspector was satisfied that reasonable alternatives existed that could accommodate development without detriment to the delivery of the OAN in this CNA. Again, land at West Gulval is one such site that can deliver development in a sustainable location (as evidenced by the SA) without offending the necessary requirement of S66 of the Planning (Listed Building and Conservation Areas) Act 1990.

The case for the allocation of land at Gulval West contrary to the SA Council officers have been aware of many technical details for Gulval West for some considerable time. Catesby Property Group has previously asked to be given the opportunity to present information to the relevant CNA working group but the request was declined (unlike for other promoters). As a result, the SA can only be described as substantially inaccurate and in some cases unnecessarily dismissive of what is a sound and sustainable location for housing. The areas of greatest concern within the SA are as follows:

- The negative score against climate change due to accessibility when compared with the more neural score of the less accessible Trannack site. - The negative soil score when only a very small portion of the site is Grade 2 agricultural land and development could avoid this area unlike almost every other proposed allocation. - The negative landscape score which suggests that proximity to the AONB is an issue when Trannack is closer and yet is not scored negatively. - The negative landscape score as a result of the site forming part of a larger assessment Cell which included substantial tracts of land to the north and AONB (which unreasonably distorts the true assessment).

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 6 k Company Registration No.6370231 - The negative landscape score referencing impact upon seascape when the site sits within an urban setting and visual information has been provided to demonstrate any development would be imperceptible from the coast. - The neutral/ negative score against maritime impact when the site is not on the coast and is half way up a hill and it does not in any way impact upon any of the SA objectives stated. - The negative historic environment score because there are modest (locally recorded) features on the periphery of the site, which does not equate to the same score for Heamoor where a substantial harm to a Grade II* asset has been acknowledged. - The negative/ neutral education and skill score when there is a safe and direct walking route to the primary school and reasonable access (within 1200m) of a secondary school. - The negative score for highways impact when there is no evidence that a modest development in this location would cause a severe highway impact, unlike the potential impacts from Gulval Central upon the narrow local roads that surround the site and its access to the wider highway network adjacent Gulval West.

A proper and reasonable assessment of Gulval West in accordance with the SEA Regulations would show a site that performs as well as the most sustainable sites in Penzance/ Newlyn and in large measure, significantly better than those in its immediate vicinity, some of which are, without question, unsound proposals.

Our concerns do not raise issue with the legal requirement to produce an SA, but with its soundness as a credible document upon which to understand the impacts of potential development sites for inclusion in the SADPD. It is particularly surprising that Heamoor and Tranneck have been chosen as proposed allocations when paragraph 3.40 of the emerging plan seeks to minimise the impacts on the area’s most sensitive landscape and historic landscape. Again this demonstrates the inconsistent approach and the impact of flaws during the assessment work that has fed into the SA.

Summary With regard to the structure of the SADPD there are some significant matters that remain outstanding and for reasons of soundness will need to be reconsidered before progressing to the next stage of production. On behalf of Catesby Property Group, Origin3 has highlighted the following main soundness issues:

1. The SADPD in its current form is incapable of demonstrating alongside the Local Plan, how the OAN will be met in full (in accordance with paragraph 47 of NPPF). 2. Similarly the same can be said for employment land provision and the need to consider a wider range of economic development opportunities as well as B1a and industrial land as current described. 3. The SA should be reviewed and revised to correct errors as a result of methodological flaws in early assessments. The SA should be significantly more consistent in its conclusions for each objective to provide a robust assessment of reasonable alternatives. 4. The housing figure must be expressed as a minimum requirement of at least 2,150 dwellings during the plan period. It should not be interpreted as a celling figure either. 5. The inclusion of at least two sites (Heamoor and Tranneck) are currently unsound. Heamoor in particular causes substantial harm to an important Grade II* listed asset and is incompatible with Section 66 of the Planning (Listed Buildings and Conservation Areas) Act 1990 as determined by recent court judgements described above (Barnwell, Forge Field and Forest of Dean).

Registered offices: Tyndall House, 17 Whiteladies Road, Clifton, Bristol, BS8 1PB Page 7 Company Registration No.6370231

REP 0212

Cornwall Site Allocations DPD Preferred Options Consultation

Land west of B3311/Polemennor Road, Gulval, Penzance

This representation has been produced by DLP Planning Ltd on behalf of DLC Property, to support the promotion of land it has interests to the west of the B3311 and Polemennor Road, Gulval, Penzance. The site proposed is being put forward as a housing allocation within the Cornwall Site Allocations DPD.

The site was previously considered as a neighbourhood extension option as part of the preparation of the previous Core Strategy (site reference PNE4 - Gulval West).

The site is known as Land to the west of the B3311 and Polemennor Road, Gulval, Penzance and the proposed boundary can be found in Appendix 1 of this report.

Site Description

The site proposed is located adjacent to the existing settlement of Gulval, Penzance. The northern and eastern boundaries are defined by Polemennor Road and the B3311. The remaining boundaries of the site are defined by existing field boundaries.

The site comprises a number of agricultural fields which are divided by existing hedgerows, some of which contain mature trees. The majority of the site is relatively flat, although the land does slope steeply along the northern and eastern boundaries. The site area is approximately 11 hectares in area.

For the avoidance of doubt, the site does not sit within the Cornwall AONB. There are no scheduled monuments or listed buildings within or adjacent to the site.

The whole of the site is within Flood Zone 1, meaning that it is considered to be land with the lowest probability of flooding.

Development Summary

The site represents a sustainable location for new residential development in terms of access to public transport, nearby employment opportunities and a wide variety of local amenities.

The size of the site is sufficient to make an important contribution to the required housing provision, with up to 150-170 homes (depending on the detailed masterplanning). There are no known constraints that would prevent this site from being developed within the plan period. Any development would also be supported by a range of developer contributions, including the provision of local affordable housing. The site is available and can be delivered during the early plan period.

Proposed Penzance and Newlyn Housing Target and Allocations

The Penzance and Newlyn area includes Penzance, Newlyn, Heamoor, Gulval and Long Rock. The Cornwall Local Plan sets the area a target of developing 2,150 dwellings between 2010-2030. Page 21 of the Site Allocations Plan outlines the residual target for the area, correct at March 2016. The Council has here subtracted the following from the housing target: net completions 2010-2016; extant permissions at March 2016; planning permissions granted since March 2016; net urban SHLAA; net windfall projection; and net additional urban capacity. The residual target for the area is 1,295.

The proposed allocations PZ-H1 – PZ-H12 provide approximately 1,245 dwellings. Allocations PZ-M1 Harbour Carpark, PZ-M2 Coinagehall Street and PZ-M3 Wherry Town are allocated as mixed use sites. The Site Allocations DPD does not state how many dwellings each of these three sites is expected to deliver. As such, there is no guarantee that these three sites combined will deliver the additional 50 dwellings needed for the area to reach the residual 1,295 target by 2030.

In addition, there is no guarantee that any of the allocated sites will come forward or that if they do come forward, they will provide the amount of dwellings that they have been allocated. We would therefore argue that the Council should either be over-allocating more residential sites to allow for such under-deliverability, or identifying sites that to be brought forward in the event of other sites failing to deliver.

Cornwall, as a whole, has a history of failing to meet their housing figures. It is therefore important that the Council allocates additional housing sites to ensure it can meet its housing targets.

Conclusion

Based on the sustainable location of the site and its lack of significant constraints and its deliverability within the plan period, we feel this site should be considered a suitable site for a housing allocation within the Cornwall Site Allocations DPD.

REP 0213

REPRESENTATION

ON BEHALF OF CHURCHILL RETIREMENT LIVING LIMITED

CORNWALL SITE ALLOCATIONS DEVELOPMENT PLAN DOCUMENT: PREFERRED OPTIONS CONSULTATION

NOVEMBER 2016 Representation – November 2016 Cornwall Site Allocation Development Plan Document Preferred Options Consultation

REPRESENTATION BY: CHURCHILL RETIREMENT LIVING LIMITED

CORNWALL SITE ALLOCATION DEVELOPMENT PLAN DOCUMENT PEFERRED OPTIONS CONSULTATION

LOCAL PLANNING AUTHORITY: CORNWALL COUNCIL

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Contents

1. Introduction 4

2. The Town/Conurbation this representation relates to. 5

3. Do you support the Vision/Aims/Objectives that are set in the report? 6

4. Do you agree with the strategy text relating to the sections 11 Overarching Strategy, Economic Growth, Retail and Housing?

5. Do you agree with the proposals set out in the infrastructure section? 15

6. Do you support the proposed allocations, their policy wording, that are 16 set out for the town/conurbation in question?

7. Is there an alternative site (or sites) that you would like to propose? 25

8. Other Matters 26

9. Conclusion 28

APPENDIX 1 – Transport Review prepared by Mott Macdonald

APPENDIX 2 – Flood Risk Review prepared by Peter Brett Associates

APPENDIX 3 – Commercial Viability Report prepared by Sturt & Company

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1. Introduction

1.1 This representation has been prepared by Planning Issues Limited acting on behalf of Churchill Retirement Living Limited.

1.2 Planning Issues Limited is a subsidiary company of Churchill Retirement Living (Group) Limited and has been engaged to provide professional planning advice in respect of this representation.

1.3 Churchill Retirement Living has specialised in the provision of purpose built apartments specifically designed for the elderly, since 1998 and have similar new developments located throughout England.

1.4 Churchill Retirement Living Limited is an active developer within Cornwall and currently has a number of developments within the County, including sites at Penzance, Truro and Newquay.

1.5 This representation relates to the Local Planning Authority, Cornwall Council’s consultation on the Cornwall Site Allocation Development Plan Document Preferred Options (Site Allocation DPD).

1.6 This representation is structured in line with the Site Allocations DPD consultation questionnaire as set out below:

 ‘The town/conurbation this representation relates to.

 Do you support the Vision/Aims/Objectives that are set in the report?

 Do you agree with the strategy text relating to the sections Overarching Strategy, Economic Growth, Retail and Housing?

 Do you agree with the proposals set out within the infrastructure section?

 Do you support the proposed allocations, and their policy wording, that are set out for the town/conurbation in question?

 Is there an alternative site (or sites) that you would like to propose?’

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2. The Town/Conurbation this representation relates to.

2.1 This representation is made in relation to Penzance and Newlyn, Chapter 3 of the Site Allocation DPD.

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3. Do you support the Vision/Aims/Objectives that are set in the report?

3.1 Although Churchill Retirement Living are in support of the plan led system that the Council is looking to progress, Churchill Retirement Living do have significant concerns in relation to the proposed vision, aims and objectives set within Chapter 3 of the Penzance and Newlyn section.

Vision

3.2 The vision is set out within paragraph 3.6 on Page 2 and states:

‘To celebrate the setting of Mount’s Bay, maximising its economic potential and in doing so becoming West Cornwall’s premiere tourism destination, whilst a thriving economy in the marine, creative and leisure industries.’

3.3 The vision identifies Mount’s Bay and should refer to Penzance and Newlyn as set out in the Cornwall Local Plan Strategic Policies 2010-2030.

3.4 The above vision only looks at the economic potential and has full disregard to protecting or enhancing the environmental and the social role of Penzance and Newlyn.

3.5 The planning system is to contribute to the achievement of sustainable development; the vision should therefore reflect the three dimensions to sustainable development, economic, social and environmental as identified in Paragraph 7 of the National Planning Policy Framework (the Framework).

3.6 Paragraph 8 of the Framework is clear that these roles should not be undertaken in isolation, because they are mutually dependent. This is extremely important as the vision sets out the future strategic objectives for the West Penwith Community Network Area.

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3.7 It is therefore suggested that the vision is amended to reflect the three dimensions, social, economic and environmental as defined in the Framework and to make it consistent with national policy.

Aims

3.8 Paragraph 3.8 on page 3 sets out 11 specific strategic aims for the Penzance and Newlyn conurbation which are listed below:

 To broaden and diversify the local economy by stimulating and promoting ICT and artisan industries, and an entrepreneurial culture;  To promote and expand Penzance and Newlyn’s cultural and arts based creative industries and support the existing high number of “self-employed” workers;  To strengthen Penzance Town Centre as a thriving retail, leisure and economic hub;  To enhance Penzance and Newlyn as a the key service centre and economic hub for Penwith peninsula;  To support the harbours of Penzance and Newlyn, protecting their role for traditional industries, whilst offering opportunities for other marine related industry;  To utilise the setting of Mount’s Bay to promote and develop the leisure, recreation and business opportunities, to stimulate the economy;  To maintain and improve the area’s strategic transport connections with the Isles of Scilly, develop high end tourism and promote Penzance as West Cornwall’s Tourism Hub and destination in its own right;  To respect the historic environment, whilst promoting, developing and maintaining the town’s natural and man-made green and blue infrastructure;  To ensure the settlements of Penzance, Newlyn, Heamorr, Gulval and Long Rock maintain their individual and distinctive characters;

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 To develop, enhance and promote the existing public transport, cycle route and footpath network within the town and develop the coastal cycle route around Mount’s Bay and its links into the wider heritage and garden landscapes as a tourism attraction;  To improve the entrance to the conurbation, through improvements to infrastructure, public realm and quality of architecture.

3.9 Churchill Retirement Living is in general agreement with the aims however; they have concerns that the natural environment has not been considered within the aims and feels this should be included to allow the aims to be consistent with national policy.

Objectives

3.10 There is limited information on the objectives, with the only section in Chapter 3 of the Site Allocation DPD is at paragraph 3.9 on page 3 which states:

‘The Cornwall LP: SP has set out the following targets for Penzance and Newlyn:

 To develop 2,150 dwellings between 2010 and 2030  To support the provision of around 16,083sqm of B1a office accommodation and 16,083sqm of B1c/B2/B8 Industrial space’

3.11 The objective fails to mention or relate to the key elements of the Cornwall Local Plan Strategic Polices 2010 – 2030 which are:

 Objective 1 – Remove unnecessary barriers to jobs, business and investment through a positive policy;

 Objective 2 – Enhance the cultural and tourist offer in Cornwall;

 Objective 3 – Provide and enhance retail provision within the towns and City;

 Objective 4 – Meet housing need by providing new homes over the plan period;

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 Objective 5 – Allow people and communities to provide for jobs and deliver new homes locally to meet the need;

 Objective 6 – Ensure the infrastructure is provided to benefit the local community;

 Objective 7 – Meet the wide range of local needs including housing and for community, cultural, social, retail, health, education, religious, and recreational facilities;

 Objective 8 – Promote development that contributes to a healthy and safe population by providing for opportunities for walking and cycling and ensuring appropriate levels of open space and the protection and improvement of air quality;

 Objective 9 – Make the best use of the resources by; reducing energy consumption while increasing renewable and low carbon energy production, maximising the use of previously used land, supporting local food production and increasing resilience to climate change; and

 Objective 10 – Enhance and reinforce local natural, landscape and historic character and distinctiveness and raise the quality of development;

3.12 The objective within the paragraph 3.9 on page 3 of the Chapter 3, Site Allocation DPD also sets out that 16,083sqm of B1a use Class of the Town and Country Planning (Use Classes) Order 1987. However; the objective fails to identify that the 16,083sqm for both B1a and B1b office floor space as set out in the Cornwall Local Plan: Strategic Policies 2010 – 2030.

3.13 The Council confirmed that all references to offices in the Cornwall Local Plan: Strategic Policies 2010-2030 should be to B1(a) and (b) Use Class which was identified in the Inspectors Report of the Cornwall Local Plan : strategic Policies 2010 – 2030 under paragraph 79, Page 19. However; the Site Allocation DPD now only reflects B1a office accommodation.

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3.14 The figures within the objective should be set out as ‘minimum’ figures to be consistent with Policy 2a of the Cornwall Local Plan: Strategic Policies 2010-2030 minimum of 52,500 homes to be delivered across the County.

3.15 The Objectives should be amended to make this section consistent with national policy and the Cornwall Local Plan: Strategic Policies 2010-2030.

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4. Do you agree with the strategy text relating to the sections Overarching Strategy, Economic Growth, Retail and Housing?

The Strategy

4.1 The Overarching Strategy for Penzance and Newlyn looks to strengthen the town centre and reconnect the town to the waterfront.

4.2 In looking into the evidence base produced by the Council in support of the Cornwall Site Allocation DPD, it can be clearly seen that this work has not been undertaken.

4.3 The background evidence documents comprise the Strategic Flood Risk Assessment, Cornwall Local Plan: Site Allocations DPD – Sustainability Appraisal Report, Cornwall Retail Report and Cornwall Site Allocations DPD Heritage Assessments. Some of which are incomplete or missing key sections that need to be considered to conclude if the allocation sites put forward by this plan can be supported. This is addressed later in this representation.

4.4 There is no updated Statement of Community Involvement, updated Strategic Housing Land Assessment, Car Parking Review or Employment Land Review.

4.5 The Council has produced a Penzance and Newlyn Framework which according to the Councils website page on the Penezance and Newlyn Framework provides the evidence base for the Site Allocation DPD. However; this is not identified in the evidence base on the Site Allocation DPD website page. This document at the time it was produced for the evidence base of the emerging Core Strategy which never progressed to examination or adoption. This Framework plan produced is therefore now out of date and incorporates an out of date evidence base.

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4.6 Although the Cornwall Local Plan Strategic Polices 2010 to 2030 identified the principles of delivery for Cornwall, the Inspector to the Local Plan did not review the Community Network Areas. The Inspector relied upon the Site Allocation Plan to undertake this role and to be examined in the future by another Inspector through the plan making process and identified in paragraph 113 on page 26 of the Inspectors report to the Cornwall Local Plan Strategic Policies 2010-2030.

4.7 Table 1 (Appointment of Local Plan Housing Provision) of the Cornwall Local Plan: Strategic Policies 2010-2030 should be updated and included within the Overarching Strategy for Penzance and Newlyn.

4.8 The Strategy makes no mention of the need and fails to refer to the policy within the Cornwall Local Plan: Strategic Policies 2010 – 2030.

4.9 Further to this, the Strategy has not dealt with the assessment of the deliverability of those sites with planning permission during the plan period and an allowance made for the estimate of windfall development that is likely to come forward during the plan period.

4.10 From review the overarching strategy lacks reference to the background information, the evidence base and the community involvement. It is therefore questioned on how the overarching strategy has been concluded based on sound evidence.

4.11 Therefore it is necessary to revisit the Overarching Strategy setting out how the objectives of the Cornwall Local Plan: Strategic Policies 2010 – 2030 are going to be addressed within Penzance and Newlyn relying on a robust evidence base that is consistent with national policy.

Economic Growth

4.12 The Economic Growth looks at employment opportunities and identifies the strategic employment growth opportunities that revolve primarily around the waterfront (including the harbours), along with the town centre; however there is

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no evidence base supporting this approach.

4.13 Within the evidence base, a Cornwall Retail Report has been provided however; no updated tourism or employment study has been produced. National policy requires Local Plans to be based on an up to date evidence base and therefore until this is updated the Economic Growth cannot be supported.

4.14 The figures within the Cornwall Local Plan: Strategic Policies 2010-2030 have been considered on a pro rota basis and on the proportion of dwellings within the main town’s and adjusted in areas with environmental constraint.

4.15 Although the inspector to the Cornwall Local Plan: Strategic Policies 2010-2030 accepted the rationale of the pro rata basis, it was clear from the discussions on the Local Plan that development would be reduced in areas of environmental constraint. The proposed allocation PZ-M1 (Harbour Car Park) will have significant impact on the environment, which is identified in the Sustainability Appraisal produced and is expanded on below.

4.16 Churchill Retirement Living cannot agree with the economic growth strategy as there is limited supporting evidence to justify the growth strategy and is therefore not consistent with national policy.

Retail Growth

4.17 The Retail Growth looks to enhance the function of the town centre of Penzance. Although Churchill Retirement Living agrees that the main focus of the plan should be to assist in the vitality and vibrancy of the Town Centre, they believe that the allocation at PZ-M1 (Harbour Car Park) will detract visitors away from the historic town centre.

4.18 A Retail Report has been produced by Cornwall Council to form part of the evidence base to the Site Allocation Plan DPD Preferred Option consultation. Within the first paragraph of the report, it identifies that towns subject to the development of a Neighbourhood Development Plan are only referenced in the

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report but are not subject to further analysis. Penzance falls within this category.

4.19 It is therefore questioned how a Town Centre Strategy can be formed within Appendix 1: Town Descriptions for Penzance, when no analysis has been undertaken. However; referring to the last Cornwall Retail Study Update 2015, concluded:

‘The ability to provide further comparison goods floorspace can be enhanced by an increase in the area’s market share should a suitable town centre site come forwards. However, the ability to increase Penzance’s market share and provide new comparison goods floorspace will be significantly affected by the grant of planning permission for either of the two current large non-food proposals at Marsh Lane in Hayle.’

4.20 Therefore the evidence base is contrary or out of date to the Retail Growth section of the Cornwall Site Allocation Development Plan Document Preferred Approach and is not consistent with national policy.

Housing

4.21 Churchill Retirement Living supports the increase in housing within Penzance and only comments that development on the fringes of Penzance would result in impacts to the vibrancy and vitality of the town centre.

4.22 Development on the fringes will require car parks within the town centre for people visiting the town to commute or to shop. The main car park which is adjacent to the train station is the Harbour Car Park which forms one of the emerging allocations.

4.23 The housing strategy also suggests the larger sites will offer the opportunity to provide new/improved facilities that both the new and existing residents will be able to utilise; this will be more sustainable but will detract people visiting into the Town Centre and goes against the aim and vision by focusing on the town centre vitality unless appropriate transport infrastructure is proposed.

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5. Do you agree with the proposals set out in the infrastructure section?

Infrastructure

5.1 Churchill Retirement Living is pleased to see that the Infrastructure is being considered with the development proposals. However; a number of improvements have been identified and they have concerns that no timetable for improvements (i.e. for foul drainage improvements) are specified which will impact on when developments can come forward.

5.2 Further details on the improvements should be provided with timescales. Emerging allocations should be contributing towards these improvements.

Transportation Strategy

5.3 Churchill Retirement Living supports the Transportation Strategy as set out in the Site Allocation DPD.

Green Infrastructure Strategy

5.4 Churchill Retirement Living supports the Green Infrastructure Strategy as set out in the Site Allocation DPD.

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6. Do you support the proposed allocations, and their policy wording, that are set out for the town/conurbation in question?

6.1 Policy PZ-M1 the allocation at Harbour Car Park is not supported as the site is not consistent with national policy, the reasons for this conclusion are set out below.

Strategic Housing Land Availability Assessment

6.2 The site has not been party to the Strategic Housing Land Availability Assessment and therefore it is unknown if the land is suitable, available or achievable. The assessment of land availability is an important step in the preparation of Local Plans as set out in the Framework and the National Planning Practice Guidance.

Sustainability Assessment

6.3 The Sustainability Assessment (SA) for the site has identified that the site is likely to significantly undermine the SA objective under Water and likely to undermine the SA objective under Maritime.

6.4 The SA fails to deal with the adverse effects and measures envisaged to prevent, reduce and, as fully possible, offset them as required by national policy.

6.5 The proposed allocations, especially PZ-M1 (Harbour Car Park) has not been revised to take into account the identified adverse impacts. It fails to acknowledge that the allocation can only come forward once the wider Shoreline Management Strategy has been implemented. The allocation has also failed to acknowledge improved sea defenses are required.

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6.6 The funding for the coastal sea defense is European funded and it is questioned if this funding has been secured or will result in being lost due to Britain leaving the European Union.

6.7 The Penzance and Newlyn Town Framework Plan December 2011 was consulted on and highlighted within the Informal Sustainability Assessment that formed part of the evidence base, there were issues with the development of the car park, in relation to ‘water, maritime due to flooding issues, historic environment and design as the site falls within the Conservation Area and the adjacent harbour being an important heritage asset, the adjoining pier being listed structure and these considerations will be of importance....’ These concerns have not been reflected in the latest SA assessment and there is an inconsistency between the new SA and the previous informal SA.

Flood Risk and Drainage

6.8 Peter Brett Associates who specialize in flood risk and drainage maters have reviewed the Site Allocation DPD and a copy of their technical note can be found appended to this report.

6.9 The Peter Brett Associates technical note concludes:

“The allocation of this site for residential or commercial development would be contrary to the principles of the NPPF unless it can be demonstrated that there are insufficient sites at lower risk of flooding which could accommodate the proposed development.

Whilst the SFRA suggests that the policy objectives of the NPPF can be accommodated on the site, this is contingent on a demonstration that the proposals can meet part two of the Exception Test i.e. that it will be safe without increasing risk to others. The SFRA references current studies into the potential to defend the area against tidal flooding. However, these options are likely to be difficult and expensive. Any proposal will need to maintain access to the outer harbour for boaters and proposals to raise access routes across the roads to reach higher land could be problematic due to the potential depths of

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water. Further confidence in the deliverability and viability of a comprehensive flooding solution should be sought before the site is allocated for potentially vulnerable development.”

6.10 Further to this the Strategic Flood Risk Assessment identifies that there are no other sites for development in the area. However as set out below in Section 8, the Neighbourhood Development Plan group have identified a number of sites for redevelopment around the Town of Penzance, these have not been considered in the Sequential Test. It is clear in national policy that development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a low probability of flooding.

6.11 Polices should be developed to manage flood risk and should not rely upon the Cornwall and the Isles of Scilly Shoreline Management Plan which is a European funded scheme and at present it is questioned if this funding is available. Therefore any allocation should not rely on this Management Plan and provide its own mitigation against flood resistance.

6.12 It is therefore uncertain if the allocation is achievable or viable and therefore is not consistent with national policy.

Built Heritage

6.13 Richard Young RIBA architect of Gilmore Hankey Kirke Limited has reviewed the Site Allocation DPD in regard to site allocation Policy PZ-M1.

6.14 The in filled harbour site is located on the eastern side of Wharf Road at the northern end of the town within ‘The Harbour and Railway’ character area of the Penzance Conservation Area.

6.15 Penzance was one of the towns selected for inclusion in the Objective One programme (2000 – 2006) to encourage investment to help grow and reshape the

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economy of Cornwall and the Isles of Scilly. This study resulted in a comprehensive report entitled Historic characterisation for regeneration together with maps that subdivided a number of the Conservation Area character areas into smaller units and identified the character and regeneration opportunities for each. The site lies within the Tidal Harbour Character Area (Area 2b) which is characterised thus:

‘The large expense of tidal water in the outer harbour and inner basin give this area an open, expansive character, framed on the landward side by buildings mounting the coastal slope.’

6.16 The town is located in the north-western angle of Mounts Bay and is dramatically situated on a north-south spur – the ‘pen sans’ or holy headland – which runs from higher ground north of the town to the Battery Rocks at its southern tip. The line of the ridge is dominant in the landscape and has resulted in a skyline which has been immortalised in numerous paintings with its twin markers of St Mary’s church tower and the dome of the old Market House.

6.17 This natural setting and use of local materials has resulted in a tiered townscape with terraces that generally follow the topography of the ground. This is characterised in distant views by a monochrome horizontality, interrupted at intervals by vertical elements, the most prominent of which are noted above.

6.18 Equally important are views out across the harbour, particularly the iconic views towards St Michael’s Mount.

6.19 The infilling of half of the harbour to create a large surface car park was undertaken in the 1950’s and is to be regretted although its current open nature does not impinge into long range views noted above and both the outer harbour and inner basin retain significant historic assets.

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6.20 Proposals under review in the draft Penzance and Newlyn Framework Plan envisage further major changes including building on the infilled harbour area and the creation of a marina in the remaining harbour, both of which will have a major impact on the open character and appearance of the area. The plan envisages significant new building on the site.

6.21 However saved polices from the Penwith District Local Plan take a contrary view and state inter alia:

‘TV23 – Control of Development of Harbour Car Park Penzance … proposals for development on any part of the harbour car park will be required to retain the open views from Wharf Road to the car park’

6.22 In views looking south across the harbour, buildings at the northern end of Wharf Road which curves to follow the harbour, frame views of the headland with its distinctive skyline.

6.23 The west side of Wharf Road still marks the historic urban edge of the built environment and any significant buildings on the in filled harbour should be resisted.

6.24 The proposed allocation would have an adverse impact against the built heritage that has not been addressed this impact in the evidence base or within the Site Allocation DPD. This goes against the principle set within national policy.

Highways/Transport

6.25 Mott MacDonald has provided a technical/review note which is appended to this document and expanded on below.

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6.26 The allocation requires “similar scale of parking provision” is retained within the site, and this will require a decked car park approach. However this does not define the level of new car parking that would be required to serve the proposed development.

6.27 This is clear when reviewed against the development concept plan produced by Churchill Retirement Living, which shows that with a 4 storey decked car park only 490 car parking spaces. This is a significant loss of parking from the current position (750 parking spaces). This excludes parking for the proposed new land use.

6.28 The Penzance and Newlyn Transport Evidence Base Report is supported by a Penzance Parking Model. The model clearly demonstrates that the town car parks would not be sufficient to cater for expected demand by the year 2030.

6.29 The parking model considers the implications of improvements to the St Erth and Sainsbury’s Park and Ride facilities. This would reduce the number of motorists wishing to park within the town. This would be a significant change to the town parking patterns, and a significant number of visitors would need to use improved Park and Ride facilities to overcome the expected demand by 2030.

6.30 The type of development proposed would generate a high number of vehicle movements outside of the traditional weekday AM and PM peak hours, and other peak periods (such as the Saturday morning peak) should be assessed to fully evaluate the potential impacts of the land use types included within the site allocation.

6.31 To link the proposed allocation to the Town Centre additional transport measures will be required including new pedestrian crossing facilities. There would also be a significant increase in the number of movements across Wharf Road and the Albert Road gyratory. To overcome the severance impacts of development

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need to be fully reviewed for the allocation as they may have a fundamental impact on the operation of the local highway network at this location.

6.32 Due to the limited/out of date studies undertaken it is suggested that the following work is undertaken before the allocation PZ-M1 is considered further:

 The feasibility and viability of a decked car park at this site should be determined;

 The existing parking model must clarify the impacts on different user types, including shoppers, tourists and commuters;

 The Parking Model should be modified to reflect the proposed allocation and extension to parking provision;

 The allocation should confirm that the provision of the Park & Ride site extensions are a prerequisite for any town centre development of this scale;

 The potential construction phase impacts on the town centre parking provision must be determined;

 The Traffic Model should be updated to reflect the increased parking provision at the proposed site, and also consider the potential impacts at peak retail times;

 The proposed modal shift assumptions should reflect the measures that are now included within the draft Transport Strategy for Penzance; and

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 The Transport Evidence Base Report should clarify how improved pedestrian facilities have been assessed within the modelling work, and the model should be amended to replicate the allocation aspirations.

6.33 From review the emerging allocation PZ-M1 is not viable in transport terms and therefore is not consistent with national policy.

Economic Viability

6.34 Development proposals should be economically viable to be delivered, as set out in national policy.

6.35 It is clear that the impact on town centre viability and vibrancy required by National Policy has not been considered on this emerging allocation. No impact review has been undertaken for the additional retail and the loss of parking that has been identified has not been considered and therefore goes against national policy requirements.

6.36 As discussed above the site has not been party to the Strategic Housing Land Availability Assessment to establish the realistic assumptions about the availability, suitability and the likely economic viability of the land. The economic viability of the emerging allocation PZ-M1 has been considered by Sturt and Company in their report which is appended. The report concludes:

‘The site is subject to significant abnormal costs including the retention of the existing car parking. The residential market in Penzance is not capable of supporting this quantum of costs and the Draft Allocation is unviable.

It is clear from our evidence together with the Local Authority’s research that the office and retail sectors are unviable. These uses are also not required and additional retail is not required until at least 2024.

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The proposed allocation creates a negative land value of over -£8 million. This appraisal does not take into account all the costs of the scheme and it could be worse.’

6.37 The site as set out previously relies on a number of flood prevention measures being funded to come forward including the Shoreline Management Plan. This requires European funding and if the funding is unavailable or doesn’t come forward then the site will need to deliver sea defenses which would add to the already unviable development proposal.

6.38 From review the emerging allocation is not economically viable and therefore is not consistent with national policy.

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7. Is there an alternative site (or sites) that you would like to propose?

7.1 Penzance Town Council are progressing a Neighbourhood Development Plan which is expanded on below in section 8. However there are a number of sites identified for redevelopment within the emerging Neighbourhood Plan: Initial Consultation that have not been considered.

7.2 The Penzance Neighbourhood Plan: Initial Consultation Questionnaire put forward 16 regeneration sites. Two of these sites were the Harbour Car Park redevelopment as proposed in allocation PZ-M1 and had the most disagreement for its development out of all of the 16 sites through the recent consultation.

7.3 The favoured regeneration site was the Headland Destination which allowed for development around the Jubilee Pool and a Wet Dock, with the Pensans Boulevard and Jubliee Pool and Promenade second favoured.

7.4 Jubliee Pool and Promenade looks to continue to focus development including new car parking. These sites have not been considered within the Site Allocations DPD or through the evidence base and the sequential test.

25 Representation – November 2016 Cornwall Site Allocation Development Plan Document Preferred Options Consultation

8. Other Matters

Neighbourhood Development Plan (NDP)

8.1 Penzance has an active emerging Neighbourhood Development Plan; under the Local Plan it identifies that where active Neighbourhood Development Plan is proposed it would allow two years for its production prior to including within the Site Allocations DPD. Therefore allocations with Penzance should be omitted from the Site Allocations DPD so it does not undermine the production of the Neighbourhood Development Plan.

8.2 The Sustainability Appraisal sets out explicitly that allocation will not be considered if they fall within an emerging Neighbourhood Development Plan Area.

8.3 The evidence base it has been identified a number of the studies have excluded the towns that are party to a Neighbourhood Development Plan, this includes Penzance.

8.4 The allocations are not the preferred strategy of the recent public consultation of the Neighbourhood Development Plan. The redevelopment of the PZ Marina, including the allocation site, came 11th out of 16 options put forward for consultation within the neighbourhood plan initial consultation.

8.5 The PZ Marina feedback showed 9.59% disagreed with the proposals. Compared with the most favoured site where only 3.8% disagreed with the site. Additionally, 8.33% had no opinion on the PZ Marina proposal.

8.6 Comments included within the feedback questionnaire provided explanation as to why it was one of the least favoured proposals. There seems to be an overwhelming feeling that the proposal would have a significant impact on the

26 Representation – November 2016 Cornwall Site Allocation Development Plan Document Preferred Options Consultation

tourism draw to Penzance by way of destroying what is currently a popular surfing destination for both tourists and the local and surrounding communities.

8.7 Further comments indicate that residents are concerned that the PZ Marina proposal redevelopment would provide very limited income potential with significant initial expense. There appears to be strong concern over the infrastructure that would be needed in order to facilitate the proposal.

8.8 The emerging Neighbourhood Plan also includes a proposal for the redevelopment of the allocation site where it includes a ground floor car park, the ‘Reception’ proposal. This came 9th out of the 16 proposal ideas with 15.32% either strongly disagreeing with the proposal or having no opinion on it.

8.9 The feedback comments included significant concerns over the increase in traffic and congestion that would result from the proposal. It is noted within a number of comments that a focus should be on enhancing sustainable alternative rather than increasing parking levels.

8.10 In summary, the allocation site is not favoured within the emerging Neighbourhood Plan which provides ten preferred alternative sites for redevelopment which received significantly more support.

8.11 The Site Allocations DPD undermines the Neighbourhood Development Plan process and allowing the local community to shape where they live which is strongly supported by national policy.

27 Representation – November 2016 Cornwall Site Allocation Development Plan Document Preferred Options Consultation

9. Conclusion

9.1 It is clear from the Cornwall Local Plan: Strategic Policies 2010-2030 that a two year period was given to allow emerging Neighbourhood Development Plans to be produced prior to including those towns within the Site Allocation DPD, it is therefore consider premature to include Penzance within the Site Allocation DPD.

9.2 Without removing Penzance from the Site Allocation DPD, it undermines the Neighbourhood Development Plan process, which in turns fundamentally undermines national policy and the Localism Act.

9.3 If we consider the Site Allocation DPD there are substantial changes required to the Vision, Aims and Objectives to overcome the concerns raised above, with the evidence base lacking substance to back up the proposed overriding strategy.

9.4 Review of the emerging allocation PZ-M1 it is concluded from our studies, that the emerging allocation is not economically viable and is considered to result in a substantive negative land value of £-8million. The allocation delivers adverse impacts to heritage and the environment whilst failing to address the flood risk test within national policy. In summary the allocation is contrary to national policy, is fundamentally flawed and should be removed from the Site Allocation DPD.

28 REP 0231

Paul Young

Thank you for the opportunity of commenting on the site allocations plan. Due to the deadline these are my personal observations, together with some of the society’s observations already made. We would like to discuss all observations since there has been no public exhibition. You will find detailed discussion and comments on the housing site allocations framework plan of a year or two ago, on www. penzancecivicsociety website and attached. The essence of our comment was that development be encouraged around the older Village centres Gulval and Heamoor and indeed Madron , to both give a high quality of Cornish life to the estates, and to support the villages themselves, the shops, pubs and other of the many community facilities they have inherited, some of which are closing down.

This last comment led us to comment that the proposed Western extension of Heamoor was well away from the centre of the community, and difficult to serve by a simple and direct public transport system. Your Elaboration of this proposal illustrates the difficulties, and will leave Madron, on a cul-de-sac difficult to serve by public transport. For these reasons, we supported substantial development from the East Heamoor, encouraging the extension of such sites as shown in the original framework plan.

The new Trennack Farm development is similarly isolated from any Centre [as was most Of Terrace Hill] and difficult to serve from existing bus routes Directly, whilst a small part of this site, and indeed the former Terrace Hill site could be described as walkable to an existing Centre, i.e. the Treneere Estate shopping centre, the remainder of the site has to be unsustainable.

There are some new sites which have had no discussion or public participation, and which the society would be concerned about, such as the Poltaire proposal and housing at Long Rock which is isolated. We have been concerned at the expansion East Green tin sheds, [and a possibility would be the use of the proposed helicopter site for residential development?]. The society will have further comments on all sites as a result of our next meeting in a few days, and I trust you will allow for this in reporting comments to the council.

We are aware that several new elements have been added to the original Housing framework plan, in effect producing a plan Penzance, with virtually no public consultation. The time given is quite inadequate to digest plans for transportation footpaths and cycleways ecology, open space and flood proposals all of which are new

Transportation.

Again you will see comments on www. Penzance Civic Society website. We would like to see a reduction of traffic, seasonally along the promenade and the encouragement of traffic onto the A30 Penzance bypass. There is little in the transportation plan, which seems simply to take the traffic generated by the proposed development and provide extensive Junction enlargement long the A30, with no consideration of demand management. [See 3.56.3] There is no consideration of 20 is plenty for this uniquely for CC walkable town.

Cycleways and footpath

There seem to be several omissions and contradictions between the transportation infrastructure plan and the green infrastructure Plan. The Society will make details suggestions for this,

Green proposals

Protection is needed for the skyline of Penzance. Ponsandane and other gateways are omitted, gateway signs are a society concern..p25 8. Greenbelt is needed to ensure that villages such as Gulval do not amalgamate with general suburban expansion of Penzance. Most streams should be ecological corridors.

Proposed developments are beginning to impinge on one of Penzance’s unique characteristics, it's ring of minor stately homes such as Trereife Rosehill Boskenwyn and we would like to see a specific policy for these precious houses and their landscape gardens.

Another major omission is a plan for allotments and for Civic facilities, schools etc. Penzance has been a gently declining town with wonderful facilities, and the plan seems to take no special notice of this situation. There is virtually no mention of CAs or PZ architectural character.

Regarding aims

We are concerned that there will be confusion not least for developers with three plans to consult. It is one thing to have the Allocation Document’s laudable vision of ‘celebrating the setting of Mounts Bay’, thereby overtaking St Ives as ‘West Cornwall’s Premiere’ Resort’ [which is supported]. It is another to sincerely implement that policy, when the Allocations Document proposes an industrial estate on the beach at Newlyn; further extending the tin sheds on East Green Towans; aim 5 makes no mention of tourism, and still directing through traffic along the Promenade..

Employment. Small enterprises and self employed are poorly paid. PZ needs good jobs to replace penwith LA, CC depot, Remploy, tax office etc

2nd email

Further to my recent representations for Public Participation , I very much welcome the excellent promotion of cycleways and Walkways shown in the Cornwall Council Allocations Plan Documents. As indicated in my observations on the allocations plan document, I would suggest two improvements to the Footpath and Cycleway networks proposed in the transportation and the green and blue infrastructure maps.

The essence of cycleways and of walkways is continuity. Otherwise the experience can be both unpleasant and dangerous where abrupt changes and a sudden increase in vigilance is required by the pedestrian or cyclist.

In particular there are 4 or 5 points nearly Coombe Lane A13 Underpass where no continuity is shown to the various paths proposed by CC. There appears to be a relatively simple way of obtaining continuity. I would suggest a route along Treneere Lane and the river here. This would give direct connection to Heamoor town centre, promoting it's economic development. To the south, the route shown through the St Clare cemetery could follow it's eastern boundary, join the lane to Treneere Manor briefly, and then take a route on the south and east side of this publicly owned garden to join Coombe Lane.

The second area where a great deal could be gained by providing a continuous route is at the south end of the path from St Clare to Bolitho School. It would be a relatively simple matter to delineate a route through the north end of Polwithen Road and down Kings Road, both very pleasant leafy suburban avenues with no through traffic. That route could join the access to Penlee Gardens, shown on the green infrastructure plan, and from there, several safe routes exist south and east to the town centre

Otherwise, a new Area of Opportunity might be considered through the chain of playing fields and open spaces on the south side of the Treneere Estate, through Coombe Road, Castle Road and down to Chyandour. There are possible routes southwards via Leskinnick Terrace, and this addition to the network would serve an area of need in Treneere Estate, and a densely developed area around St Mary's Street and St Michael's Street. I attach a plan which shows these suggestions diagramatically

3rd email

As indicated in my previous personal observations, I now attach detailed points regarding the housing Allocations. I am in communication with Mario Fonk, who agrees with most of this. You will note that much of your proposals are supported! I also attach a Plan Diagram which illustrates my suggestions. In particular, the green crescent of stately homes, the green belt walkway, skyline enhancement, and the proposed helicopter site for Residential. ALLOCATIONS DEVELOPMENT PLAN DOCUMENT PENZANCE AND NEWLYN

Poltair

The recognition of the importance of the setting of this Grade II listed house is very much welcomed, as is off site provision for a formal park area, presumably public, since the area is already extensively used by local people. However, the proposed housing site is exceptional in that it is detached from the main part of the town, breaches the natural boundary of Boscathnoe Lane, and appears to intrude into the original setting of the House and Gardens, being sited between the two original avenue accesses into the house.

It is suggested that the east west walk and cycle way shown for PZ H5 should extend eastwards through this site as part of public access around a new green belt. However, the offsite contribution to Poltair House would appear to conflict with the present owners declared intention of excluding local people who have previously used the site.

Joseph’s lane

The proposal is supported but the east west walk and cycle way shown for PZ H5 should extend westwards through this site as part of public access.

Trannack Farm development PZH4

A part of the western part of the site is supported, since it is close to the local shopping centre for Treneere estate on Treweath Road. However the major part of the site is isolated from the rest of the town and any facilities, particularly since the A30 forms a barrier.

The east-west path and Cycleway is very much welcomed, and should connect with the crossing facility shown to the east on the A30 within the transport strategy 2030 map. A Riverside walk could then be completedfrom Chyandour seafront westwards, beyond Heamoor, and the east -west path continued to Trengwainton. This would form a major recreational facility making use of the open countryside to the north and the attractive Chyandour Riverside.

Consideration should be given to retaining the older farm buildings, which are not mentioned.

It is hard to see how open space in this area will address recreational impacts at Marazion Marsh Special Protection Area. Given the location on the edge of very attractive countryside, so far as open space provision is concerned, it is important to improve path access to the open countryside and to provide new access.

Polmennor Rd PZH5

This proposal is strongly supported, since it will give economic support to the centre of Heamoor, which contains many useful clubs, churches, meeting rooms, and shops. There is potential for an attractive village centre on the river bridge. A Cycleway could also runs through the centre delivering further customers. The residents of the Polmennor Road proposed estate would then have good access to an attractive and traditional Cornish village centre, and the development could contribute to the improvements suggested. This proposed development could be extended to provide considerable further housing rather than the isolated and difficult west extension PZ H8 Boscathnoe Lane proposal

West Heamoor Policy PZ H8 Boscathnoe Lane Proposal

This development is the least accessible and sustainable of the allocations proposals. It is isolated from any traditional centre, difficult to service by direct and simple bus route, leaves Madron on a bus cul de sac, and intrudes into important areas which affect the listed buildings and the gardens in the vicinity. The recommendation to create a Community Hub is beyond the ability of the Council, since the small shop suggested is unlikely to be viable in this peripheral location. The development also requires substantial road building which will reduce the amount of affordable housing that could be provided.

Area A impinges significantly on Trengwainton and it's Gardens, and Area B impinges directly on the attractive buildings of Roscadgill and Nancealverne. If open space is to be provided it should be in this area of exceptionally attractive buildings and mature gardens and parkland. Should the proposal proceed there must be a clear analysis of this Area B commensurate with the consideration given to the representations by the National Trust.

St Clare policy PZH9

This development is strongly supported, but it is noted that a proposal for a health centre has already been made, in contradiction to Paragraph H. The proposals, made purely for housing, conflict with the requirements in paragraph A&E for employment in addition to the health centre. There is no provision for the footpath and cycle way shown in the green infrastructure plan, and this is indicative of the poor integration and coordination of this incomplete Allocations plan as a whole.

The housing proposal made at a public exhibition takes no account of the proposal made in paragraph D for a vehicular connection, and that area is in danger of sterilisation or the provision of a very expensive access from the A30, once again reducing the possibility of affordable housing in this area.

Paragraph A requires a setback from York House and is supported. As with the minor stately homes in the PZ suburbs, the ‘Lost Garden’ remains, particularly to the east of York House, and the general setting, should be treated with the same respect as the Trengwainton proposals. In particular the overgrown Victorian garden with its avenues and lawns should be restored. This area should be protected by moving the health centre proposal slightly northwards.

Mount Misery Policy PZ 10

This seems to be a remarkably hazardous proposal for relatively small housing gain. The site has historic remains, and important associations with the trawlerman's wives of Newlyn. The mention of views in Paragraph B omits the vital importance of views into the site from the surrounding town which are of great significance. The area is part of an important skyline viewed from the promenade area, which must be preserved and improved to reinforce the view of a town backed by greenery. In addition, there is potential for a new park extending down to the Newlyn Coombe, which could be particularly attractive and important given the development proposed to the north along the A30. This is an opportunity to provide a new Newlyn Park.

Barncuse Estate Policy PZ 12

This estate proposal should take care to preserve the skyline above Newlyn, so that it gives the appearance of Newlyn nestling below a green and wooded area

Harbour car park policy PZ M1

The development of this area is strongly supported. It is vital to replace the high quality jobs lost at for example St Clare. The development process should start immediately, perhaps through an architectural competition. An iconic modern development is possible here.

The emphasis here should be on employment, and residential use is not essential. The suggestion in Paragraph B for ground floor retail uses seems strange when there is a viable connection which could be made direct into Wharfside and the centre of Market Jew Street, as a bridge over the existing road access. This would free up the ground floor area for hotel office and other uses, in addition to the multi-storey car park suggested.

Paragraph H is supported. Paragraphs I is strongly supported, although Branwell Mill and indeed the Penzance rail station terminus give an important area of dockside granite buildings in the northwest corner of the site.

Paragraph G should emphasize a completely integrated exchange, preferably undercover.

Paragraph I again suggests recreational mitigation for the Marazion Marsh special protection area, which is a little puzzling.

Paragraph J should also include the possibility of phasing, since this is likely to be a complex, major and capital intensive proposal which will need careful planning to accord with business cycles in the various sectors of the commercial property world.

The additional requirements and considerations once again include many acronyms and abbreviations such as D1 D2 and THI which will be baffling to the ordinary citizen.

CoinageHall Street

This development has an extraordinary history. The site itself does not include the Barbican Gardens area which the current Council planning brief suggests being included. In addition, the carpark should also be included, and might solve many of the difficult problems of developing this area. It is emphasized that this is a site absolutely central to the history and the architectural interest of Penzance. It is suggested that a conservation based scheme, with the development of the west side of Barbican Lane and the preservation of the Ship Inn as the entrance to a North-South link should be key elements. Modernist parts of the development if required should be sited on the car park and Barbican Gardens area mentioned above. There is no mention of the conservation area and all of the accounts of historic assets mentioned in paragraph s of the Harbour Car Park proposal.

Wherry town

Proposal is supported, although the reasons for requirements for mixed use are not clear

Stable Hobba extension PZ2

The requirements in Paragraph A and B for alternative accesses are opaque. It is suggested that this area could be extended along the A30, partly as a substitute for the proposed Industrial Estate on the beach at Sandy Cove.

Sandy Cove

The extent of this development is unacceptable giving the Primary Vision of the Allocation Plan to exploit the recreational and tourist potential of Mounts Bay. It is suggested that the industrial element be confined to the north of the site. The beach, with some rock armour protection should be restored on the south side.

Long Rock East P Z E4

This is a very isolated site, surrounded by busy roads and would appear in general unsuitable for residential development.

General Observations

The brief for several of the residential development site includes the suggestion of an offsite contribution to open space. It needs to be very clear that this is in addition to the normal budget for open space. There needs to be an analysis of the need for additional open space within the town, and an analysis of the short comings of existing open space, including play space and allotments for example, which cannot be overcome through the normal public open space budget. Since many of the housing proposals border open countryside, there should be an emphasis on existing and new footpaths and access into the extremely attractive surrounding countryside of Penzance, including new footpaths and footpath improvement.

In general it is felt that the Allocations Plan falls very well short of the consultation required for a Local Plan including consultation with important organisations such as the Penzance Civic Society, Transformation Penwith, Friends of the Earth etc.

The policy for affordable housing is mentioned only once, and it is not clear what is being required, or the general density requirements.

The explanations are full of condensed jargon and acronyms, and are not suitable as a consultation document.

There is extraordinarily little mention of the Penzance Conservation Area, historic buildings and listed buildings and the special character of Penzance or the architectural characteristics and vernacular buildings of this very special area, which depends on it character for it major tourist industry CIVIC SOCIETY COMMENTS ON PENZANCE AND NEWLYN FRAMEWORK PLAN

Planning Future Cornwall -Community Network Area Core Strategy Area Based Discussion Paper -West Cornwall. Comments to [email protected] The discussion paper seems largely based on housing proposals, presumably in response to the Countywide housing targets, and the need to have a plan in place before a presumption of permission without a plan is introduced nationally. There are major omissions e.g. landscape analysis and plan, and a transportation plan. The West Penwith Community Network Area Discussion Paper is therefore only acceptable as a temporary stopgap, and must include a commitment to provide a complete plan within a year. Otherwise, for example, there could be a major impact on the skyline, historic landscapes and the views around Mounts Bay, and a major growth in roads and car traffic, contrary to the green aims of the council, a further advance in car based retailing and road construction and a further decline in public transport. Policy 4.7.3 in the core strategy should be expanded and developed to include the following. Transport Through and access traffic should, in the medium term, be progressively placed on the bypass road, and through traffic should be progressively eliminated from the Promenade and Wharfside area. Access into the town should be from the bypass roundabouts and Chyandour. Market Jew Street should be for deliveries and public transport only, with no general traffic. Internal circulation can be from Saint Clare, Morrab Road, Alexandra Road, and Alverton Road. There should be judicious use of one way traffic, and in particular much more use of flexible timing for control of traffic-e.g. different arrangements in winter and summer, timing of deliveries outside peak shopping hours, and different controls at different times of day. From the Treneere estate southwards to the Lido, the densely populated old town, walkable to and from the town centre, should be protected from through traffic. Here the priorities should be traffic calming, high standards of environment and streetscape, and protection from traffic danger. Visitor access would be at the Harbour car park from the east and the promenade from the west. A direct and efficient public transport spine route would be established from Newlyn, through Morrab Road , Then Market Jew Street, and on too Long Rock, Crowlas Hayle and Redruth. Landscaping and the Natural Seashore A landscape plan should preserve green skylines and green links through the urban areas of Mounts Bay. Equally, the landscape plan could identify areas which could be developed for housing with a view of Mounts Bay, without causing damage to the key elements of the landscape. The Newlyn extensions as proposed would destroy the green skyline- a boundless urban sprawl rather than a nestling town. As towns expand, it also becomes more important to identify areas which lack access to playgrounds and small parks, as the countryside becomes less accessible. There should be a comprehensive plan for the seashore. This should emphasise the preservation and restoration of natural areas, such as the area at Battery Rocks which is so precious to the town. It should also include consideration of re-establishing a beach which would be a vital visitor draw. The seashore plan should take as its starting point the preservation, maximum access and use of Cornwall's major resource, it's seashore. Inappropriate seashore uses, such as anonymous retail parks and industrial estate which are proliferating outside Penzance, should be avoided. Commentary on Map2 The Penzance Civic Society regards neighbourhood planning as particularly important for Penzance. There is substantial reference to neighbourhoods and neighbourhood extensions, but limited analysis and little or no discussion of just what these should constitute, the history of neighbour planning elsewhere, and just how they can be achieved. Gulval Trevarrack, Heamoor and Alverton. The existing town centre of Penzance and the attractive 19th and early 20th century town which surrounds it should be celebrated as a green town of exceptional potential. Beyond this walkable town, several suburbs have grown up with a limited neighbourhood structure of their own. These include Gulval Trevarrack, Heamoor and Alverton. These neighbourhoods are in need of improvement and support. The urban extension of Penzance should be directed to supporting and expanding these areas [in a modest way]. Both Gulval Trevarrack and Heamoor are established communities, with substantial and attractive churches, schools and other buildings, but are unfocused and scattered. They are in need particularly of environmental improvement, to make them attractive neighbourhood centres in which to linger and socialise. Heamoor The neighbourhood extension PNE 5 would help to support the sparse shops and facilities in Heamoor, and would help finance the greening and neighbourhood improvement of the centre. There has already been a substantial suburban extension to west, in an anonymous and incoherent style. Further extension westwards as proposed in PNN 1 and PNE 6, is unlikely to provide walk in support for the existing centre and would continue an unfortunate tendency for car based suburban anonymity. Gulval Gulval Trevarrack has an attractive setting around the stream, and fine Victorian buildings. However it lacks some key features, such as a public house. Proposals PNE 4 and PNE 3 and PNE 2 would support improvement of the town centre, including greening, seats, good quality street furniture, traffic calming, rerouting the B road, and improved custom for the corner shop. However great care should be taken to avoid intruding on to the skyline on the west side, or the green surroundings which make Gulval Church Town distinct and of particularly high quality. A local community action plan is needed. Development east of Gulval church could reinforce a centre of the highest quality around Gulval church- and perhaps reopen its corner shop. Newlyn Newlyn Town community, within a deep valley and surrounded by steep hills, would be difficult to integrate with major expansion, such as PNN 3, as the history of the Gwavas estate has demonstrated. Here, it would be wise to limit expansion to PNE 8 and PNE 9, but hopefully achieving a Chiwoon hill bypass, so that Town centre can be improved, and through traffic eliminated. These extensions would also support the existing Penzance town centre, whereas peripheral development of such as PNE1, 11 would create a spread out town liable to centripetal forces, such as shopping and employment elsewhere. Should further housing areas be required, area PNN 2 could be a possibility. This area is a well-established public transport route and would maintain a compact shape for an enlarged Penzance town. However, many questions arise regarding impact on the landscape. Great care would have to be exercised to achieve a high quality design for the whole area. A new centre based to the northwest of the existing roundabout could serve both the new neighbourhoods and a wider catchment using the A30 bypass road. Saint Erth / Splattenridden ECO Village If the above is too restrictive, a further possibility for new housing could be the Saint Erth / Splattenridden ECO Town once suggested as a possible new centre. This site appears to have been dropped from consideration, although the reasoning is not altogether clear. This site has the advantage of existing employment and high quality transport infrastructure. In particular underused railways could be upgraded to provide a high quality commuter service for workers in a future centre. This centre could provide the variety of employment which is lacking in the Saint Ives and Carbis Bay Area. It could provide a focus for the whole Saint Ives and Mounts Bay Areas. The land rising to the north and west of the railway junction could provide high quality residential development overlooking the attractive marine environment of the Hayle estuary, and would attract both affordable housing and high quality private sector development. The railway network could be completed with a link from Saint Ives to Camborne, producing a centre of national quality which would attract high order employment, and provide an exceptional green village within a green countryside and seaside environment. Penzance Town Centre In the context of the compact area around Penzance town centre, site PE 3 [expanded west and south?] should be considered for housing, as well as employment, West Cornwall Hospital expansion and educational use. The site is in walking distance of Causewayhead and could add substantially to the core of the town, where residents might reasonably reduce or eliminate their car use, and assist the County in reaching its green targets. In general I would suggest an expansion of the town centre boundary, in the manner in which Falmouth and Penryn Town Centres appear to have been shown. Expansion should recognise the greater variety of uses now considered appropriate, as well as the safeguarding of retail uses. For example, the town centre should include Saint John's Hall as a community and occasionally retail facility. There are a great many small housing sites, which are indistinctly shown, and not listed elsewhere. These must be shown in more detail in order to comment. However, it is noted that several of the sites are in and around the town centre. In general, town centre uses should have priority within the town centre, not of course excluding residential use, particularly in the upper stories. Penzance Town Centre There is in general concern about vacant shops, loss of important retailers now and in the near future, charity shops, and the general decline in Penzance which has reduced its position in in the League Table of Retail Centres in Cornwall. There is also a general impression that the Unitary Authority has washed its hands regarding improvements to Penzance since it was unable to persuade the town that it's Harbour proposals were the best available option. Street Markets. The Portas Report emphasises the contribution markets can make to vitality and viability. There is a major opportunity in Penzance to create a lively, central, artisan, craft, town and country Street Market, aimed particularly at summertime visitors. The market should be sited in Market Jew Street, to be as visible, attractive and lively as possible. Creative use should be made of traffic management measures, diversion, variation in times of day and seasonal control, and parking and servicing. Pavement Cafe Culture A major opportunity is lost at present for the development of a pavement cafe culture in Penzance which could appeal strongly to visitors and to residents alike. I would like to see the council adopt a pavement cafe culture code of the kind which is commonplace elsewhere. It should start with an assumption of permission for businesses applying for tables. Refusals should be based on proven local difficulties, and not on standard national traffic regulations, which can be interpreted locally. Some permissions could be given on an experimental basis. Causewayhead Causewayhead, as a delightful Victorian street of independent shopkeepers, should be managed by its own existing shopkeeper’s organisation. They could improve substantially the management of servicing, help establish cafe tables, manage the flea market, and the car park. There is also potential for improving the gateways to Causewayhead, and other streetscape and improvements. Car parking In the medium term the car parks should be controlled more locally and development should be considered, retaining parking, as has been mooted for the Harbour car park site. Many of the car parks give the appearance of bomb sites, whilst, strangely, The Community Network Plan for Penzance laments the lack of possible development sites in the town centre. Improvement of the Public Realm There are many proposals which arose from Penzance townscape heritage initiative. and other schemes which remain unimplemented. I would like to see the council cooperate to improve the design of new fascias, shop fronts and facades. I would particularly welcome a scheme for the revival of shops around the damaging gyratory system at the east end of market Jew Street. Small Shops I would like to see the promotion of the many small shops in the Lanes adjacent to Market Jew Street-Chapel Street, Greenmarket, Causewayhead, Bread Street and The Arcade for example. Each has a special character and should be promoted to draw shoppers into the more specialized areas of the town centre. Town Centre Manager Proposals for markets and pavement cafes would benefit substantially by the appointment of a town centre manager with strong support from councillors, and the consequent ability to knock departmental heads together. The Society and The Chamber are anxious to see the reappointment of a town centre manager. This could be funded by the BID process, through the section 106 Sainsbury's funding, or through pooling of the existing council officers and police officers who currently patrol, administer and maintain the town centre in an uncoordinated manner. Penzance Harbour Car Park Development. The site is exceptionally prominent and attractive, and is at the commercial heart of the town. A planning brief is an urgent priority if the Town Centre is to compete. Operators such as Marks and Spencer or John Lewis/Waitrose who combine food and department stores/quality clothing should be encouraged. The following points, amongst others, to be considered · Mixed use, and particularly employment use should be the main element in the site- residential use should be secondary. · Car parking should be managed for the benefit of the town by the council or its agents. · The Harbour walls, where concealed by dumped rubble, should be exposed and restored and respected in development. · For practical and funding purposes the development should be phased. Possibilities include 1. Phase one-car park and retail; 2. Phase two- the interchange and a link to the Isles of Scilly; 3. Phase three -hotel and restaurant development on the south harbour frontage. · A ‘Victorian warehouse quarter’ should be included, -based on the railway station, Bramwell Mills, and the waterside mill c/o Wharf Rd and Albert St · Remove the gyratory system which blights Lower Market Jew Street and Albert Street, together with appropriate paving and uplift scheme. · Closer integration with the existing major primary shopping frontages, including using a high level link into a multi-storey development · Active frontages at ground level · Streetscape to be based on the existing and historic Harbour vocabulary, including large Harbour setts, the mooring posts, ironmongery, rail lines and granite · Reshaping the south Harbour frontage-a feasibility study into extending of the wharf frontage into the site, and creating a Harbour Beach as at Saint Ives and Mousehole. · Preserve important links down Albert Street and Street west of Wharfside Mall - a design panel to give close scrutiny to proposed design and massing of the buildings. Overall, the site is large and exceptionally attractive- it could attract a modern (in parts) design of international quality. · An immediate application for Convergence Funding, using the commercial capital to be invested as match funding, and to ensure that the public elements, including a Scilly link, improved interchange, employment provision, etc. 01736 786683 ------I append my personal comments on the Discussion Paper-P Young PLANNING FUTURE CORNWALL-COMMUNITY NETWORK AREA DISCUSSION PAPER-VOLUME ONE WEST CORNWALL. OBJECTIVES AND CONTEXT Oh dear! The Foreword and Introduction to this document seem unable to clarify where the documents sits within all the other planning documents being prepared. The proliferation of legislation without a clear direction has rendered the planning system (deliberately?) almost incoherent. So far as can be seen, the strategic Cornwall Core Strategy has not been completed, and yet the detailed documents, such as the Network Area Discussion Paper, have already been prepared. The Penzance and Newlyn Town Framework Plan is mentioned- but its status is very unclear. It is hard to criticise the document when its own objectives and context are not explained clearly. The clarity of the document is further compromised by innumerable examples of bad proof reading and poor expression, which adds to the impression of confusion. Map 2 is central to the framework, and yet is small and very poorly reproduced. The status of Penwith Council's Framework prepared only a year ago, and other consultative documents such as the MCTI proposals, should be clearly explained. Notwithstanding, the simultaneous consideration of the Core Strategy and the Discussion Paper gives a good opportunity to ensure that the Core Strategy contains documents which will support sound planning at the local level and modify some of the more startling unfounded proposals in the DISCUSSION PAPER. Presumably, this hurried document is produced in order to have the semblance of a plan, so Cornwall has some defence against the presumption for granting planning permission giving 'sustainable economic development '' contained in the current planning legislation. If this is so, it could reasonably be accepted so long as it was clearly an interim measure and better plans were to follow. If the Community Network Area Discussion Paper is intended as a coherent plan, it has admitted and glaring omissions, such as a landscape and environment section, Retail, and analysis of highways and transportation (Pedestrianisation/bypasses/Wharfside bus bollards?). In the Foreword the ''Councillor -Planning and Housing’'[- cabinet member?]-claims the document tackles issues such as climate change and safeguarding the environment, yet there is virtually no study analysis or plan for these subjects within what is a very slim document. HOUSING As a housing plan for the whole Penwith area it has glaring omissions. For example, fig. one omits Conservation Areas, let alone other environmental proposals. The St Just area, for which some housing is proposed, is not considered at all in detail. Its associated village of Pendeen has substantial areas allocated for housing, but no reference is made to these. Penlee Quarry housing is not marked. There are major issues for the inland Penwith area. Figure one points to one issue, which is the lack of protection for the Saint Buryan area, currently in the Wild Penwith study area. There are dramatic changes in farming appearing, and about to occur, with the change in subsidy for Environmentally Sensitive Areas. The number of farmsteads is dramatically falling. Immensely attractive small farming hamlets are falling out of use with no clear proposals. They are becoming a haven for second homes, derelict barns and other derelict listed buildings, and holiday homes. Former productive agricultural fields are changed into plastic show jumping courses and arenas accompanied by innumerable supposedly temporary buildings, and a cacophony of stables, oil tanks garages, awkward gardens and ‘Juliette’ balconies. Page Four, Objective One. The housing objectives contain little or no reference to quality. The emphasis on low cost housing must not imply low cost design and materials. Penzance has a proud history of modest good quality housing both in the public sector -e.g. Penalverne, and the private sector-e.g. western extension of Penzance. Recent low cost housing such as that near Sennen Primary School and on the south of Crowlas has consisted of tiny, chimneyless rendered boxes, with very little local material. The rendering is already stained and deteriorating in the rough climate of West Cornwall and is a sad comparison with the sturdy vernacular granite cottages which are the foundation of our attractive towns and villages. The plan should specifically require good design, recognise vernacular traditions, and give examples in Cornwall of low cost and affordable housing which is considered exemplary. Page five WW4. The growth factors summary table, whilst providing some analysis, is very thin and to an extent confusing. Throughout the document the housing, households and population estimates appear to vary. For example does the 2200 population accord with the almost 3000 figure for households-this would imply a remarkable number of new single households. Given a long, 20 year time span, the large housing proposals are startling. Little effort is made to put them in context by showing graphically previous housing growth, and the accelerated growth in percentage terms which is now required. A clear analysis of recent trends in housing, employment and retail would be useful. VISION P9, Paragraph 6.3. The “relatively self-contained” Penzance and Newlyn suggests perhaps, a more ambitious Vision for Penzance. The town is capable of being an exemplary Green Town, walkable, without a high car ownership, and served by long distance rail transport to higher order centres. It has a creative, potentially green population and organisations such as the Transition Penwith which would support such a vision. Its centre is walkable from virtually the whole town. It has a full complement of facilities, albeit that these are usually very modest in size. RETAIL AND MIXED USE SITES; TOWN CENTRE The reference to town centre boundary expansion in the rather spare map one, are welcome. For example, surface car parking is not included in the town centre area, nor the developing Bread Street area, or St John's Hall, used venue for markets. . The Portas Report emphasises the broad range of social uses appropriate to a town centre, the map should reflect this. In this spirit, the Wharfside car park (PM1 p11), which the framework paper acknowledges as the only substantial development site, should be included as a whole in the town centre area. The idea of a public event space is welcome, but may not be appropriate in this position. Food retailing could be included to support comparison shopping, since it is one of the few areas of strong investment at present. The size, drama and robust nature of the site gives scope and for high quality modern development, as well as “development in keeping". 6.4 Page 11. The last two themes appear contradictory, in that encouragement is given to all water users, and then restricted apparently to fishing related processes so far as Newlyn is concerned. Paragraph 6.5.1 there is virtually no study or analysis to support the proposed sites. PM2 p11. Coinagehall Street. The idea of a pedestrian circuit is welcome, but this area needs a fresh look considering that it has lain semi derelict, in a crucial area for visitor attraction, for many years. PM3. Penzance Harbour. The reference to redevelopment of the dry dock needs qualification, but the reference to visitor friendly attraction is welcome. A reference to the problems of through traffic should be included, as mentioned in Penwith Council's Framework PM4 Wherrytown. Whilst the references to leisure and gallery space are inviting, it is not clear, given the general decline in the Penzance Promenade closer to town, that this could be viable. This needs to be considered as part of the work of the Promenade Forum, which should be well informed by a study, analysis and good knowledge of the commercial potential of the area. P M5. Heliport. This is outdated, and poignant, but the reference to new pedestrian connections and high quality active frontage design must be followed through if the permission given by Cornwall Council for a supermarket is not to be even more disastrous. PM6 Penzance Harbour extension. While it is generally supported, the commercial viability of this proposal is obscure. EMPLOYMENT SITES 6.5.2 PE1 Newlyn harbour. Unlike Penzance Harbour, there is no acknowledgement of the quality of surrounding buildings and potential for the acknowledged major industry of the area, tourism. With care it should be possible to cater for both the fishing industry and visitors, to the benefit of the whole of Newlyn. The Keel Alley frontage is capable of restoration, the area to the north is in urgent need of repair and restoration, the central area of Newlyn is cut off from the sea by the present auction shed, and there is great scope for improved streetscape. A conservation led revitalisation of Newlyn is urgently needed. The requirement of any redevelopment to address highway problems seams exaggerated, since elsewhere Newlyn problems are regarded as insoluble. PE2. Sandy Cove. The destruction of this once attractive area is sad. There is an urgent need for an overall Coastal Plan, to include preservation of threatened natural areas, such as this and Battery Rocks, the enhancement of all natural areas left, the potential for nature and for tourism, including provision of a beach and sand dunes, and a connected Landscape Plan which examines the visible coastal area and preserves divisions between towns, the skyline area and the special landscapes such as wooded areas which make Mounts Bay so attractive. The Bay constitutes the major resource in revitalising tourism and realizing the economic vision for high end tourism [whatever that implies]. PE3. St. Clare. The reference to health and education uses is welcomed, but in view of the Special Schools and other requirements stated elsewhere, this could be much stronger. In addition, the site is capable of providing for proposed improvements to West Cornwall Hospital-e.g. car parking, and it is essential that land is reserved to secure the long-term future of West Cornwall Hospital which is so strongly supported by residents. Page 18 acknowledges that West Cornwall Hospital has a need to improve its ageing infrastructure. It is unclear why the 5000 square metres of additional office floor space is required. This is a relatively isolated site, and the Waterside Car Park would be a better, more sustainable, attractive and central site avoiding a car based edge-of-town office complex. Since demand for office space is limited, development of this site is likely to make any further development elsewhere not viable. The site is at the centre of a green network within the town which would be essential to realise the vision for a Green Penzance Town. It is already well used for casual walking. These routes should be preserved and enhanced, particularly as they serve many schools and colleges. PE4 Longrock. This proposal appears to imply new highway proposals, but in the absence of anything specific elsewhere in the plan, they remain unfortunately enigmatic. HOUSING- NEW NEIGHBOURHOODS Page 14 New Neighbourhoods The emphasis on new neighbourhoods is welcomed. Given the lack of council housing, this appears, in the current market, to be the only means of financing infrastructure and affordable housing. However, the history of neighbour planning has problems-not least the provision of the centres referred to, which depend on viable private sector shops. This concept needs far more careful analysis and implementation. As for new housing, there seems to be no analysis of the quality of proposed housing sites-for example in terms of views or woodland. The new neighbourhoods created must strive for the highest quality, informed by best and most viable practice in the private sector in order to be a success. PNN2 Trereife. This is a radical proposal. Potential employment site around the existing Stablehobba and A30 seems to have been ignored. The reference to the stream at Castle Horneck is very welcome but further emphasises the absence of a Landscape Plan. PNN3 West Newlyn. This this radical solution to the problems of Chywoone Hill and central Newlyn could be welcome, but care should be taken to preserve the Town skyline, and a landscape plan to accompany the framework is therefore essential. EXISTING VILLAGES The suggestion of providing new centres is admirable, but existing threatened centres should be considered. In particular, Madron village and potentially Gulval could be supported by limited new development. Both Madron’s corner shop and public house are threatened. The village has some important facilities, and a high quality historic centre. Since the chosen Core Strategy includes support for Cornish villages, some of the growth proposed for Heamoor could secure the position of Madron as a small high quality neighbourhood centre, perhaps pedestrianised with a new modest “bypass" road. Likewise Gulval Church Town village could be a very high quality centre. Some of the growth proposed around Gulval Trevarrack could be better related to this centre, which could support a corner shop. The distinctiveness of the village should be preserved by a green belt on the west and south sides. Current proposals do not seem to allow for this and need closer examination. Map 2 p16. This map is central to the framework, and yet is small and very poorly reproduced. Many of the proposals for development impinge on the remarkable series of minor stately homes built in the 17th, 18th and 19th centuries and attractively surrounding Penzance, such as Boskenwyn, Rosemorran and Kenegie. For example the proposals for Trereife and Heamoor and other options could affect the settings of Nancealverne, Roscadabill, Castle Horneck, Trereife, Rosehill and Trengwainton. These properties, which form an important part of the visitor offer and hence employment around Penzance remain unidentified as a major characteristic. This again emphasises the need for a Landscape Plan, which identifies the corridors along Lariggan and Chyandour streams, the skyline of the town and the stately homes and grounds which surround Penzance. In addition, a Coast and Seaside Plan is needed to maximize the area's major asset both for residents and visitors. INFRASTRUCTURE Page 17 Transport. There is a glaring omission of any transport analysis. Creative suggestions have been made including the downgrading of the A 30 and barriers on Wharfside, and there is therefore an opportunity for new thinking. Penzance Promenade Channels Project requires an explanation. GREEN SPACE INFRASTRUCTURE STRATEGY, COAST AND SEASIDE PLAN Page 18 drainage, green space. The Longrock revetment projects may be necessary, but will destroy some natural coastline, to the detriment of tourism objectives, and in the long term seems contrary to the implications of local global warming studies. The reference to a Green Space Infrastructure Strategy is welcome, although it is not possible to have sound development proposals in the current absence was such a strategy. Neither is it clear why this is based on "the emerging economic framework" alone.

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