Dartmoor National Park Authority Local Plan Review 2018 - 2036 Full report on Regulation 19 representations (by section) Respondent Number: 0056 Name: Adam Hesse Organisation: Coworth Homes On behalf of: N Haley Rep. Number: 1 Local Plan Section: Paragraph/policy Is the Local Plan sound?: No Is the Local Plan legally compliant?: Yes Is the Local Plan compliant with the duty to co-operate?:Yes Hearing session(s)?: Yes, I wish to participate in hearing session(s) Why? This is naturally a departure from what has been selected by the DNP and we feel it important to attend any hearing. We have spent in excess of £25,000 so far on reports and consultants and are taking this extremely seriously as genuinely can be on site next year assuming our site is selected against the other 2. Did respondent comment on Reg 18 Local Plan?: Detail of representation: We have a fundamental objection to the Buckfastleigh Local Plan that we would like the Inspector's to consider. We believe the plan is not sound. The 2 'allocated' sites have not come forward in a decade showing they are undeliverable and unlikely to provide substantial affordable housing even if they did and the DNP have not taken into account reasonable alternatives. In fact both sites submitted weak applications in the last 12 months to ensure they remained on the shortlist for 'allocated sites' yet Holne Road offered no affordable housing when they know DNP require 45% which shows the mindset they have and you can ensure a viability argument will be trotted out if they were successful in being chosen. Both sites are steep with flooding issues and Holne Road isn't even abutting existing settlement and opens the door to development creep......something the DNP are very anti for obvious reasons. Modifications necessary to make the Local Plan compliant: We have offered an alternate, more suitable site off Gleblands/Oaklands Road which would deliver 45% affordable housing; it would deliver circa 26 much needed homes in the town (waiting list currently 52) and would we believe deliver more affordable housing than the other 2 sites put together.... We met with Joanna Burgess of DNP on 29th January 2018 who told us to carry out the relevant ecological, highways, drainage and site surveys which we carried out over the summer (Bat surveys are March to October). We were then advised to carry out a public exhibition in Buckfastleigh Town Hall which was held on Tuesday 16th of December 2018 between 2.30 and 8pm. On the back of that exhibition we were motivated by the positive response from locals who obviously preferred our site albeit weren't keen on the likely increase in traffic off Silver Street which leads into the town from the Oaklands road entrance. Although Highways were happy with our proposed scheme we re-planned the site to ensure all traffic would enter the proposed development off Glebelands which is an adopted road and feeds better into the town. We submitted on 30th January 2019 to both Joanna Burgess and Dan Janota of the planning team at DNP a completed Comment Form and a Detailed Response Document with regards the draft local plan. We also attached a related Appendices Document covering the various reports carried out as requested by them. The trail went cold shortly after despite numerous attempts in the meantime to engage. To summarise we are ready to get on site immediately and to deliver much needed affordable homes to the community. If you review our detailed response document we are also delivering much needed over spill parking for 15 September 2020 Page 1 of 576 Glebelands, a children's play area and also a large tract of land that we propose making a public area for those living in the immediate vicinity. Authority response: DNPA believes the sites identified to be capable of delivering affordable housing to meet an identified affordable housing need. The level of development needed to meet the overall housing need identified for the National Park is achieved through the combined identification of sites in the Plan, and additional windfall or exception sites as may be needed. If sites do not deliver to meet the idenfitied need in a specific area, and/or additional affordable homes are needed the Local Plan has appropriate scope for the delivery of this on exception sites, or through rolling Plan review. Authority proposed action: None proposed 15 September 2020 Page 2 of 576 Respondent Number: 0218 Name: Sarah Vinetester Organisation: On behalf of: Rep. Number: 1 Local Plan Section: Paragraph/policy Is the Local Plan sound?: Is the Local Plan legally compliant?: Is the Local Plan compliant with the duty to co-operate?: Hearing session(s)?: Why? Did respondent comment on Reg 18 Local Plan?: Detail of representation: We are in the midst of the beginning of climatic and ecological break-down, the result of which will lead to near term societal collapse. Please, through a citizens assembly, create a plan that is congruent with this, 4C is unlivable. Please read these documents [documents enclosed] Thank you Modifications necessary to make the Local Plan compliant: Authority response: The Plan has been developed taking into consideration all available tools to improve our impacts on climate change and is balanced against other requirements such as development viability and affordable housing. Authority proposed action: None proposed 15 September 2020 Page 3 of 576 Respondent Number: 0091 Name: Matthew Cuthbert Organisation: Aggregate Industries UK Limited On behalf of: Rep. Number: 5 Local Plan Section: 1 Paragraph/policy Stategy Is the Local Plan sound?: Yes Is the Local Plan legally compliant?: No Is the Local Plan compliant with the duty to co-operate?:Yes Hearing session(s)?: No, I do not wish to participate in hearing session(s) Why? Did respondent comment on Reg 18 Local Plan?: Yes Detail of representation: OBJECTION - Chapter 1 – Vision and Spatial Strategy, first paragraph on Page 13 states “Major Development will not take place in the National Park other than in exceptional circumstancesâ€. The wording should reflect Paragraph 172 of the National Planning Policy Framework 2019 (NPPF19) which uses the word ‘should’, as in “Planning permission should be refused for major development other than in exceptional circumstances. This is so the Local Plan is consistent with the NPPF19 as per Paragraph 35 Point (d). This was previously highlighted during the First Draft consultation and remains within the Final Draft. Modifications necessary to make the Local Plan compliant: It is suggested that the wording of the first paragraph is amended to read “Major development should not take place in the National Park other than in exceptional circumstancesâ€. Authority response: The wording is considered consistent with the NPPF, ‘should’ in the NPPF allows local policy a degree of flexibility in the application of the policy and the possibility of introducing other criteria which could allow major development to occur in a National Park, other than the exceptional circumstances stated in NPPF para 172. DNPA have not decided to introduce any further flexibility and so the stronger wording is justified. This approach is consistent with other recently adopted National Park Local Plans, e.g. South Downs Core Policy SD3. Authority proposed action: None proposed. 15 September 2020 Page 4 of 576 Respondent Number: 0002 Name: John Penny Organisation: Devon Stone Federation On behalf of: Rep. Number: 7 Local Plan Section: 1 Paragraph/policy Strategy Is the Local Plan sound?: Yes Is the Local Plan legally compliant?: No Is the Local Plan compliant with the duty to co-operate?:Yes Hearing session(s)?: Yes, I wish to participate in hearing session(s) Why? to ensure the Plan is consistent with national policy Did respondent comment on Reg 18 Local Plan?: Yes Detail of representation: plan needs to be consistent with national policy Modifications necessary to make the Local Plan compliant: The paragraph states "Major development will not take place in the National Park other than in exceptional circumstances". The use of the word 'will' is not appropriate and does not reflect the definition given on page 9 under "Understanding the Local Plan". The sentence about Major development is supposed to reflect para 172 of the NPPF 2018. This uses the word 'should', as in "Planning permission should be refused for major development other than in exceptional circumstances". Therefore, the sentence in the Local Plan should be changed to: "Major development should not take place in the National Park other than in exceptional circumstances". We suggest that the use of the word 'will' is reviewed elsewhere in the Draft Local Plan. Authority response: The wording is considered consistent with the NPPF, ‘should’ in the NPPF allows local policy a degree of flexibility in the application of the policy and the possibility of introducing other criteria which could allow major development to occur in a National Park, other than the exceptional circumstances stated in NPPF para 172. DNPA have not decided to introduce any further flexibility and so the stronger wording is justified. This approach is consistent with other recently adopted National Park Local Plans, e.g. South Downs Core Policy SD3. Authority proposed action: None proposed. 15 September 2020 Page 5 of 576 Respondent Number: 0026 Name: Paul Cottington Organisation: National Farmers' Union On behalf of: Rep. Number: 2 Local Plan Section: 1.1 Paragraph/policy 1.1 Is the Local Plan sound?: Is the Local Plan legally compliant?: Is the Local Plan compliant with the duty to co-operate?: Hearing session(s)?: Why? Did respondent comment on Reg 18 Local Plan?: Yes Detail of representation: Special qualities – we agree with the special qualities but given that the landscape is special because of the way it is managed then we would like to see this at the top of the list.