Cornwall Site Allocations Development Plan Document (DPD): Schedule of Proposed Modifications (Regulation 22) Consultation

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Representation Form

Please return your completed form by email to: delivery@cornwall.gov.uk or by post: Cornwall Council, Planning Delivery Team, Dolcoath Avenue, Camborne TR14 8SX or by hand: at any Cornwall Council office (marked FAO: Planning Delivery Team)

Why are we consulting?

The Allocations DPD is currently going through its Examination; as part of this examination a series of hearing sessions were held. As a result of the examination process to date a number of changes have been proposed to the submitted Allocations DPD, which is set out in the Schedule of Proposed Modifications. The Examination Inspectors have now asked the Council to undertake a period of public consultation on these proposed changes and its associated evidence base including the Sustainability Assessment and the updated Heritage Impact Assessment (which can be viewed via: www.cornwall.gov.uk/allocationsplan. (It is not a consultation on the whole Site Allocations DPD, only the proposed modifications and the associated evidence documents). Once the consultation period has finished, the Council will collate the responses it receives and forward them to the Inspectors for their consideration.

Once the Inspectors have completed their review of the Site Allocations DPD, they will issue their findings in a report to the Council.

Completing the form You must complete your contact details in Part 1 for your representation to be registered. The Council cannot accept anonymous representations.

Part 1 Your contact details

Name: …….Victoria and Daniel Mavin

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Please indicate your preferred method of contact. If you chose email, please ensure it is included above. Email ☒ Post ☐

Do you want to know when:-

The publication of the Planning Inspectors recommendations of the Yes ☒ Cornwall Site Allocations DPD under section 20 of the Planning and No ☐ Compulsory Purchase Act 2004; Yes ☒ The adoption of the Cornwall Site Allocations DPD No ☐

Keep me on the mailing list to be notified about future reviews of the Yes ☒ plan. No ☐ We will keep your details on file for 4 years in line with our Planning Policy and Guidance Consultations Database. At that point the records will be refreshed and further consent sought. You can unsubscribe at any time by contacting [email protected]

Part 2 Your comments You may extend the boxes to respond to any of the questions.

1. Do you consider that the Cornwall Site Allocations DPD: Schedule of Proposed Modifications document meets the legal and procedural requirements? Yes ☐ No ☐ Please specify your reasons below I do not know I am neither a planner nor in a position to pay a consultant to assess.

2. A local planning authority should submit a plan for examination which it considers to be sound – namely that it is: positively prepared, justified, effective and is consistent with national policy. Do you consider the Cornwall Site Allocations DPD Submission Document now meets these tests in light of the Schedule of Proposed Modifications? Yes ☐ No ☒ Please specify your reasons below This relates to Saltash – North Pill Additional site Highways were consulted on the impact regarding the strategic network, I do not see if the Highways Officer has been involved in looking at the impact on the single access road and capacity of the difficult junction (Cutlers Corner- Clanville Tce, Old Ferry Road and North Road). I believe Highways England only considered the strategic impact specifically on the A38 trunk road and slip road. I believe that a extensive analysis of the road from Cutlers Corner to the China Fleet needs to be carried out. Glanville Terrace & Cutlers corner - there are no parking restrictions on the terrace & there are no facilities for pedestrians to cross the road in the vicinity of Cutlers Corner such as footbridge, pedestrian crossing or subway. There will be an adverse impact of sustained long term building works, large vehicles / traffic lights on what is in in effect a single lane due to narrowness of Glanville Tce. There are also two blind corners on both sides of Salt Mill Creek which is already worrying for both pedestrians and motorists. North and Middle Pill Landowners Consortium brought these matters up in Feb 2014 in which it was stated that the Highways Officer ‘has raised concerns regarding the capacity of the junction where the A38 and the B3271 join the minor roads’. This was reaffirmed in a pre app response to Cavanna Homes in June 2015 where it was concluded ‘I have concerns regarding the infrastructure and access to the site and whether the road network can accommodate the additional traffic.’ ‘There is no public footpath which would take residents to the local facilities by foot and the highways officer has raised concerns regarding the capacity of the junction where the A38, and the B3271 join the minor roads.’

These concerns then do appear to have been largely discounted in the current evidence base and arguments being put forward now for the new site. Photos are provided later in this response showing the roads in question.

3. Did you raise this concern during previous consultations on the Cornwall Site Allocations DPD? Yes ☐ No ☒ Please give details below This site has not previously been included in the DPD allocations. Indeed prior to this late entry all indications given by you were that this site was not appropriate for other than a site suitable for a small development of up to 50 houses. It feels like due process has been followed throughout and then at the 11th hour this site has been added simply to meet the concerns of the Inspector over the deliverability of the Broadmoor site. However I am not aware of any evidence being put forward to support these concerns. My own research shows that the Broadmoor site developer, CEG, has delivered on larger and more complex developments elsewhere and has a good track record of delivery, e.g Lighthorne Heath, Thame and Carlyon Bay. http://www.ceg.co.uk/what- we-do/our-track-record The addition of the North Pill site will also increase the original allocation by c.85 properties that Saltash is required to deliver. This is however inconsistent with the approach being taken with the Launceston amendment which allows effectively for a reserve site rather than an allocation. Please see further comments below re MM-126

4. Please set out below any concern(s) you have with the Cornwall Site Allocations DPD Schedule of Proposed Modifications document, or its associated evidence base, including any change(s) you consider necessary to address this concern(s).

You will need to say how the change(s) will address your concern(s) and it would be helpful if you could put forward your suggested revised wording to the policy or text and any evidence to support the change(s).

Please also state the proposed modification references that each of your comments relate to. The reference can be found within the Schedule of Modifications document (the reference starts with ‘MM’). Furthermore, if the comment relates to an evidence document, clearly state the title of the document that you are commenting on

Please use a new box for each Modification you are commenting on.

Schedule of Concerns, changes and reasons/evidence modification reference; or title of evidence document MM135 Our fundamental objection is that we do not believe that

Schedule of Concerns, changes and reasons/evidence modification reference; or title of evidence document the North Pill site needs to be brought forward now but should be held in reserve should evidence emerge that demonstrates significant slippage in delivery of the Broadmoor target. We believe that this is entirely consistent with the approach being adopted at Launceston (MM-126) MM-135 states with reference to Broadmoor that ‘It is forecast that the site will be fully developed within the plan period’ and yet by including an additional site at North Pill the Council appears to have accepted the Inspector’s query without challenge and in spite of the evidence showing otherwise. It is recognised that the Inspector will have had limited time to examine the issues; will have only had the opportunity to discuss concerns from a small number of individuals many of whom have a pecuniary interest in adding development sites. We further believe that the Inspector will not have the local knowledge of the area and the limitations associated with the North Pill site. Cornwall’s officers are experienced planners who know the area, have been closely involved with the Broadmoor development and are aware that CEG has delivered large projects elsewhere on more complex and controversial large projects elsewhere (examples include Carlyon Bay and Lighthorne Heath shown on the CEG website are shown http://www.ceg.co.uk/what-we-do/our-track-record). Finally our understanding is that many of the delays at the Broadmoor site are as a result of highways and infrastructure issues raised by Cornwall officers rather than any tardiness by CEG to commence building. Thus, in order both to allay the Inspector’s concerns and also to be consistent with the treatment of similar scenarios elsewhere in the DPD document (i.e. ref MM-126 with respect to Launceston), we would propose alternative wording to MM-135 as follows:- Replace 13.24: ‘In addition to Broadmoor, a smaller scale site, for 85 dwellings (SLT-H1) is identified in order to provide flexibility in the plan and to ensure that the housing provision for Saltash is effective.’

Schedule of Concerns, changes and reasons/evidence modification reference; or title of evidence document With:- 13.24: ‘If in the event of Broadmoor not meeting the target after 3 years from adoption of the Site Allocations DPD, through Cornwall Council’s annual monitoring, support would be given for an additional smaller scale site, for 85 dwellings (SLT-H1) to ensure that the housing provision for Saltash is effective.’

If you feel that the above is unfounded which would be very disappointing and if the inclusion of the site continues to be included then would wish the following concerns, changes and reasons to be considered

Schedule of Concerns, changes and reasons/evidence modification reference; or title of evidence document MM145 1. The developers have already started publicising their intentions - please see website for further information: http://www.tamarvillagesaltash.co.uk/master-planning.html 2. And the following concerns arise from this: a. MM145 - What does approximately 85 dwellings mean. Already the developer is preparing to submit planning for a further 120 properties on the North Pill site. Referred to as sites 4 and 5 in their published Master Planning material. This represents an additional 41% to the 85 properties stipulated in the draft DPD MM145. 3. The developers are also consulting on a further 5 sites in the North and Middle Pill area, including ‘infill’ and ‘windfall’ sites. These sites are numbered as “blocks” and our understanding is that their current intention is to develop blocks 1,2, and 3 prior to the proposed site, blocks 4 and 5 identified in the draft DPD as SLT-H1. It is clear therefore that they are giving a lower priority to the site now being proposed as an additional allocation in the draft DPD MM145 than their other proposed sites.

Schedule of Concerns, changes and reasons/evidence modification reference; or title of evidence document This in spite of Cornwall’s perception that the developers are ‘available now’ (per 1.7 of Cornwall’s response to the Inspector https://www.cornwall.gov.uk/media/33629360/ccs102- insps14-council-response-saltash.pdf ) for SLT-H1. 4. We are very concerned that there will be an adverse impact on the town’s largest employer, the China Fleet Club in terms of the threat of job losses to people living in Saltash and also an adverse economic impact on the local supply chain given CFC’s policy of supporting local suppliers. 5. We do not understand what MM-145 Additional requirements Ej) means - ‘planning permission for the Development of only part of the site will not be granted, unless it is in accordance with a masterplan or concept plan for the entire site, which clearly sets out the pedestrian, cycling and vehicular connections through the site’. Does this mean that as long as the developer has a masterplan whether it is delivered or not then that is sufficient? How will this be monitored …….? Based on the above concerns we propose the following wording under MM-145 ‘Additional policy requirements’: be changed from: a) ‘Land identified at North Pill offers the opportunity to accommodate approximately 85 dwellings, which includes self or custom build homes.’ To a) ‘Land identified at North Pill offers the opportunity to accommodate up to approximately 85 dwellings, which includes self or custom build homes.’ And

 e) ii) Impacts on the China Fleet are appropriately mitigated’ to add .’The detail of the proposed mitigation will need to be agreed with the China Fleet Club and secured prior to approval of the

Schedule of Concerns, changes and reasons/evidence modification reference; or title of evidence document development’

Photographic examples of issues affecting the only access road to the North Pill Site, Salt Mill Park and China Fleet Club

Looking up towards Glanville Terrace from Salt Mill Park

View from Glanville Terrace looking towards Saltmill

View up towards Glanville Terrace

Looking down from top of Glanville Tce during a busier period leading to traffic congestion and also a blue light ambulance out of sight-cars on the right are parked.

View from Shute Cottage towards China Fleet Club during a tournament at Salt Mill

Cutler's Corner, Saltash and multi junctions

Cutler's Corner, Saltash is the junction of the old A38 (North Road/New Road), Old Ferry Road (the road that ran to the Saltash Ferry, replaced in 1961 by the Saltash Road Bridge), and Glanville Tce -the single road that now leads to the China Fleet Country Club and the proposed site. To the left of the flats is the slip road that leads up from the A38 trunk road at the western end of the Saltash Tunnel. When the tunnel is closed for maintenance or due to an accident, traffic is diverted along North Road and this slip road to join the A38. A barrier normally blocks traffic from entering the slip road.

Views from North Road – looking at cars coming from slip road / waiting at top of Glanville tce and leaving Old Ferry Road – at 12:30 at a quiet time.

Please copy and paste more boxes into your response if required. Privacy Notice

In submitting your representation, you understand that your comments and personal information will be forwarded to the appointed planning Inspectors assigned to the Allocations DPD. Your comment as well as your first and last name will be published on the Council’s web site as part of the consultation process. The information you provide on this form will be used to send you information in connection with Cornwall Council’s Planning Policy and Guidance Consultations. Without this information we will not be able to provide you with this service. Your data will be held within Cornwall Council’s secure network and premises and will not be processed outside of (the UK/the EEA). Access to your information will only be made to authorised members of staff who are required to process it for the purposes outlined in this privacy notice. For the purpose of the Cornwall Site Allocations DPD, we will keep your details on file for 4 years. At that point the records will be refreshed and further consent sought.

For more information, please read Council’s Privacy Policy and the Planning Policy Guidance Consultations Database