Cornwall Site Allocations Development Plan Document (DPD): Schedule of Proposed Modifications (Regulation 22) Consultation
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, Please din Cornwall Site Allocations Development Plan Document (DPD): Schedule of Proposed Modifications (Regulation 22) Consultation Representation Form Please return your completed form by email to: [email protected] 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. 1 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. 2 Part 1 Your contact details Name: …….Victoria and Daniel Mavin Organisation (if applicable): Click here to enter text. Address: …… Postcode: ……. Email Address: …… Telephone number: . If an agent, the individual or organisation you are representing: Click here to enter text. 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] 3 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. 4 5 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 6 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:-