Local Plan – Strategic Policies · Last year we consulted on a draft Local Plan under the same regulations. In January 2014 the Council agreed a number of changes to that draft

Cornwall Local Plan – Strategic Policies Proposed Submission document March 2014

representation form

Representations can be submitted by email to [email protected] or by post to:

Cornwall Council – Local Plans Team Carrick House St Clement Street

Truro TR1 1EB

This form has three parts: Part A: Your personal details

Part B: Previous representations Part C: Your representation

Part A: Your personal details You must complete Part A for your representations to be accepted. The

Council can not accept anonymous representations.

Regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012, requires all representations received to be submitted to the Secretary of State. By completing this form and

submitting it to the Council you are giving your consent to the processing of personal data by Cornwall Council and that any information received by

the Council, including personal data, may be put into the public domain, including on the Council’s website.

1. Personal

details.

2. Agent details (if applicable).

Name Lumicity Gareth Roberts

Organisation C/O agent Pegasus Group

Address line 1 First Floor, South Wing

Address line 2 Equinox North, Great park Road

Address line 3 Almondsbury

Address line 4 Bristol

Postcode BS32 4QL

Telephone number

Email address

Preferred

contact method

Email (c/o

agent) Post

Email

Post

Q1. Do you wish to be notified of future stages in the Local Plan

including submission, examination and adoption? Yes

No

mailto:[email protected]

6162

Typewritten Text

725

6162

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Representations 725 - 749

Part B: Previous representations

Last year we consulted on a draft Local Plan under the same regulations. In January 2014 the Council agreed a number of changes to that draft and

we are now consulting on this amended version, in its entirety as the draft we propose to submit to the Secretary of State for Examination. If you would like your previous views to be considered at the Examination it is

important they are made as part of this consultation.

We are sensitive to the time and effort people made at the last

consultation and we are happy to accept comments made previously. If you would like your comments to be held over for this consultation you must tell us that is what you want.

Q2 Did you make comments on the Cornwall Local Plan Pre-Submission

Draft undertaken March – April 2013? Yes No

If Yes;

Do you want your previous comments to be included as part of this

consultation? (If you propose no changes to your comments no further information is required).

Yes No

Do you want to make amendments to your previous comments?

Yes No If Yes;

What changes do you want to make;

Part C: Your representation Soundness

Paragraph 182 of the National Planning Policy Framework sets out the consideration in relation to a plan being considered ‘sound’:

Positively prepared Justified

Effective

Consistent with national policy Legal compliance

For a Local Plan to be considered legally compliant, the following needs to be determined:

Whether the Local Plan is detailed in the current Local Development Scheme and that the key stages have been followed,

That community involvement has been carried out in accordance

with the current Statement of Community Involvement Whether the Local Plan makes satisfactory regard to the

Sustainable Community Strategy That the Local Plan complies with the Planning and Compulsory

Purchase Act 2004 (as amended)

That the Local Plan complies with the Town and Country Planning (Local Planning) (England) Regulations 2012

That a Sustainability Appraisal report is published to accompany the Local Plan and is adequate

That the Habitats Regulations Assessment is carried out in

accordance with the Conservation of Habitats and Species Regulations (The Habitats Regulations) 2010

That the Local Plan has regard to national planning policy That Section 110 of the Localism Act 2011 (Duty to Co-operate) has

been complied with. Q3 A local planning authority should submit a plan for examination

which it considers to be ‘sound’. Do you consider the Plan has met these tests?

Yes No

Please specify the reasons below

Please refer to policy specific representations set out below.

Q4. Do you consider that the Local Plan meets the legal and procedural requirements? Yes

No


Elements of the plan do not have regard to national policy.

Q5. Please provide any comments on the Local Plan – Strategic Policies. Please use a separate box for each policy.

Document Page number Policy number

Cornwall Local Plan – Strategic Policies

39 Policy 22

Sustainability Appraisal Report

Objection

This representation relates to Policy 22 ‘Best use of land and existing buildings’ and the preamble to the Policy at Paragraphs 2.86 to 2.87.

Firstly, the preamble to the Policy discusses how safeguarding appropriate land would strengthen the Council’s ability to deliver a range of listed objectives; these include self sufficiency in energy markets; support and

increase biodiversity as well as the effective treatment of waste and sustainable use of minerals. We note that reference to employment,

leisure, tourism and residential are omitted from the preamble. The Policy itself then sets out the priorities for the use of land whereby

preference is duly given to (a) use of previously developed land; (b) use of non-agricultural land; (c) reuse of buildings. Criterion ‘d’ then

discusses how Grade 1, 2 and 3a agricultural land would be safeguarded for food production and where reasonable alternatives for development can be identified, the safeguarding of grade 3b agricultural land.

Paragraph 112 of the NPPF does not seek to place an embargo on the use

of best and most versatile agricultural land it simply seeks that for significant projects the use of land must be demonstrated to be necessary.

We respectful request that Criterion ‘d’ of Policy 22 is reworded accordingly; alternatively, we can rely on national guidance and the policy, in its entirety, can be deleted.

If the Council are minded to retain the policy (incorporating the suggested

rewording set out above); then the policy’s preamble should also be reworded to clarify whether or not it relates to all land uses and if not robust justification is required for any exemptions. Whilst considerable

strain is placed on agricultural land through urban expansion we note that reference to employment; leisure; tourism; residential & affordable

housing exceptions site have all been omitted from the preamble. If the Council intend to closely monitor the use of ‘best and most versatile

agricultural land’ during the plan period then its Monitoring Framework for Policy 22 should also be modified and expanded to assess each land use

(i.e. residential, employment, waste, minerals, tourism, leisure and energy) either permitted or temporarily permitted on agricultural land of all grades.


Cornwall Local Plan –

Strategic Policies

2.55 to 2.62 15

Sustainability Appraisal

Report

This representation relates to Policy 15 and more so the preamble

supporting the renewable energy policy. Before we consider the preamble and our requested change, it is prudent to set the scene with regards to the Council’s own energy targets.

In September 2011 Cornwall Council signed up to the Covenant of Mayors.

This is a European funded project relating to ‘Leadership for Energy Action and Planning (LEAP)’. The LEAP project is a European Commission,

Intelligent Energy-Europe funded project aimed at Local Authorities. Its aim is to increase energy policy, knowledge and awareness, and political will and commitment. It should also increase the number of jobs in the

renewable energy sector and local GDP.

By 2020 the LEAP sets out specific renewable energy related targets that should be achieved by Cornwall Council, these include:- • 25% reduction in CO2 emissions below 1990 levels;

• 25% reduction in primary energy use; • 25% of energy consumption from renewable and low carbon

Sources; • 10% of local jobs in the sustainable energy sector being created; • 5% increase in local GDP.

Having signed the ‘Covenant of Mayors’ there is a clear local policy

requirements for Cornwall Council to achieve both a 25% reduction in CO2 emissions below 1990 levels; and securing 25% of energy consumption from renewable energy and low carbon by 2020. This requirement has

not been correctly identified, discussed and carried forward through the emerging Local Plan.

The local importance of the Covenant of Mayors is underplayed through emerging Policy 15 and its preamble/ amplification. The pre-amble should

be reworded to specifically clarify the relationship between Cornwall Council and LEAP and its agreed energy targets. As a minimum,

paragraph 2.55 of the Cornwall Local Plan should be reworded to state that ‘the Council is committed to achieving at least 25% of renewable energy consumption from renewable and low carbon

sources by 2020.’

Q6. If your representation is seeking a change, do you wish to

participate at the examination in public?

No I do not wish to participate at the examination in public

Yes I wish to participate at the

examination in public

If you wish to be notified of the Submission of the Local Plan – Strategic Policies please tick the box

If you wish to be notified of the publication of the recommendations of the independent examination (Inspector’s Report) please tick the box

If you wish to be notified of the adoption of the Local Plan – Strategic Policies please tick the box

Signature Date 13 April 2014

If you require any assistance in completing this form or require any further explanation as to what is required please contact a member of the

local planning team using the email address below or telephoning 01872 224283.

Data Protection In complying with the Data Protection Act 1998 Cornwall Council confirms

that it will process personal data gathered from this form only for the purposes relating to the consultation.

Personal information will be added to the Council’s Local Plan consultation database and will be used to keep you informed of progress with the Local

Plan and in order to consult with you further at each stage of the process to enable you to make future comments.

Personal information will also be shared with the Government appointed planning inspector (from the Planning Inspectorate), who may wish to

contact you to discuss your comments and concerns, prior to formal examination of the Local Plan and supporting documents.


representation form

Representations can be submitted by email to [email protected]

or by post to: Cornwall Council – Local Plans Team

Carrick House

St Clement Street Truro

TR1 1EB



Part C: Your representation

Part A: Your personal details

You must complete Part A for your representations to be accepted. The Council can not accept anonymous representations.

Regulation 22 of the Town and Country Planning (Local Planning)

(England) Regulations 2012, requires all representations received to be submitted to the Secretary of State. By completing this form and

submitting it to the Council you are giving your consent to the processing

of personal data by Cornwall Council and that any information received by the Council, including personal data, may be put into the public domain,

including on the Council’s website.

1. Personal details.

2. Agent details (if

applicable).

Name STEVE MCTEARE

Organisation RLT ARCHITECTS

Address line 1 THE OLD STABLES

Address line 2 CHYANDOUR LANE

Address line 3 PENZANCE

Address line 4

Postcode TR18 3LP

Telephone

number

Email address

Preferred contact method

Email Post

Email / Post

Q1. Do you wish to be notified of future stages in the Local Plan

including submission, examination and adoption? Yes / No


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726



we are now consulting on this amended version, in its entirety as the draft

we propose to submit to the Secretary of State for Examination. If you

would like your previous views to be considered at the Examination it is important they are made as part of this consultation.


consultation and we are happy to accept comments made previously. If you would like your comments to be held over for this consultation you

must tell us that is what you want.


Draft undertaken March – April 2013?

Yes / No

If Yes;


consultation? (If you propose no changes to your comments no further

information is required). Yes / No

Do you want to make amendments to your previous comments? Yes / No

If Yes;


THE SITE IDENTIFIED AS SUE-1 IN THE LOCAL FRAMEWORK PLAN HAS BEEN WORKED ON WITH CORNWALL COUNCIL UNDER A PPA AND A LIVE HYBRID PLANNING APPLICATION IS IN PROGRESS. THE SITE PROVIDES FOR A SIGNIFICANT AMOUNT OF LOCAL NEEDS HOUSING AND HAS BEEN WORKED ON WITH DELIVERY OFFICERS ALONGSIDE THE EMERGING AFFORDABLE HOUSING SPD. IMPROVED ACCESS TO COMMUNITY FACILITIES FOR THE RESIDENTS OF CARBIS BAY ARE PROVIDED BY INCORPORATING HEALTHCARE USES WITHIN THE PROPOSALS IN ADDITION TO THE PROVISION OF NEW PUBLIC OPEN SPACE, SPORT/RECREATION AND ACCESSIBILITY TO GREEN INFRASTRUCTURE VIA CYCLE/PEDESTRIAN ROUTES AND EASY ACCESS TO PUBLIC TRANSPORT. THE SITE REMAINS THE MOST SUSTAINABLE IN TERMS OF DELIVERING A GOOD PROPORTION OF THE PROJECTED HOUSING GROWTH FIGURES UP TO 2030 FOR ST IVES AND CARBIS BAY AND REMAINS UNDER A SINGLE OWNERSHIP WHICH WILL FACILITATE DELIVERY OF THE SITE IN BEING BUILT OUT, PARTICULARLY WITH REGARD TO THE FIVE YEAR SUPPLY


Soundness

Paragraph 182 of the National Planning Policy Framework sets out the

consideration in relation to a plan being considered ‘sound’: Positively prepared

Justified

Effective

Consistent with national policy

Legal compliance

For a Local Plan to be considered legally compliant, the following needs to be determined:

Whether the Local Plan is detailed in the current Local Development

Scheme and that the key stages have been followed, That community involvement has been carried out in accordance

with the current Statement of Community Involvement

Whether the Local Plan makes satisfactory regard to the

Sustainable Community Strategy That the Local Plan complies with the Planning and Compulsory


That the Local Plan complies with the Town and Country Planning (Local Planning) (England) Regulations 2012

That a Sustainability Appraisal report is published to accompany the

Local Plan and is adequate That the Habitats Regulations Assessment is carried out in

accordance with the Conservation of Habitats and Species

Regulations (The Habitats Regulations) 2010

That the Local Plan has regard to national planning policy That Section 110 of the Localism Act 2011 (Duty to Co-operate) has

been complied with.

Q3 A local planning authority should submit a plan for examination

which it considers to be ‘sound’. Do you consider the Plan has met

these tests? Yes / No


Q4. Do you consider that the Local Plan meets the legal and

procedural requirements?

Yes / No


Q5. Please provide any comments on the Local Plan – Strategic

Policies. Please use a separate box for each policy.



Strategic Policies




Strategic Policies




No I do not wish to participate at

the examination in public

/



If you wish to be notified of the Submission of the Local Plan – Strategic

Policies please tick the box /

If you wish to be notified of the publication of the recommendations of the independent examination (Inspector’s Report) please tick the box /

If you wish to be notified of the adoption of the Local Plan – Strategic

Policies please tick the box /

Signature Steve McTeare Date 07.04.14


local planning team using the email address below or telephoning 01872

224283.

Data Protection

In complying with the Data Protection Act 1998 Cornwall Council confirms



Plan and in order to consult with you further at each stage of the process

to enable you to make future comments.

Personal information will also be shared with the Government appointed

planning inspector (from the Planning Inspectorate), who may wish to



Proposed Submission document March 2014

representation form


Cornwall Council – Local Plans Team

Carrick House

St Clement Street

Truro TR1 1EB

This form has three parts:






(England) Regulations 2012, requires all representations received to be

submitted to the Secretary of State. By completing this form and






Name Martin Gregory

Organisation Looe Town Councillor

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x Post

Email

Post

Q1. Do you wish to be notified of future stages in the Local Plan including submission, examination and adoption? Yes

No

6162

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727





would like your previous views to be considered at the Examination it is



consultation and we are happy to accept comments made previously.

If you would like your comments to be held over for this consultation you


Q2 Did you make comments on the Cornwall Local Plan Pre-Submission Draft undertaken March – April 2013?

Yes No

If Yes;



information is required).

Yes No


Yes No

If Yes;



Soundness Paragraph 182 of the National Planning Policy Framework sets out the

consideration in relation to a plan being considered ‘sound’: • Positively prepared

• Justified

• Effective

• Consistent with national policy

Legal compliance For a Local Plan to be considered legally compliant, the following needs to be determined:

• Whether the Local Plan is detailed in the current Local Development

Scheme and that the key stages have been followed,

• That community involvement has been carried out in accordance

with the current Statement of Community Involvement • Whether the Local Plan makes satisfactory regard to the

Sustainable Community Strategy

• That the Local Plan complies with the Planning and Compulsory


• That the Local Plan complies with the Town and Country Planning

(Local Planning) (England) Regulations 2012 • That a Sustainability Appraisal report is published to accompany the

Local Plan and is adequate

• That the Habitats Regulations Assessment is carried out in


Regulations (The Habitats Regulations) 2010 • That the Local Plan has regard to national planning policy

• That Section 110 of the Localism Act 2011 (Duty to Co-operate) has

been complied with.

Q3 A local planning authority should submit a plan for examination which it considers to be ‘sound’. Do you consider the Plan has met these tests? Yes

No


The plan does not take into consideration the land stability, employment to support housing or the infrastructure.


No



Document Page number Policy number Cornwall Local Plan –

Strategic Policies 18.9 PP15


Report

This paragraph should be omitted


Strategic Policies


Report

Policies 6 & 7 – Housing I would strongly recommend that all housing must be supported by employment and the ability of the infrastructure to accommodate this, ie Healthcare, roads, public transport, schools etc. The Looe area has recently seen considerable new housing development and together with the existing and potential current developments in the Looe area I consider that I have already taken our share of the development for our CNA, of which I are only a small part, and as such further development should not be considered for the Looe area. I would support the removal of PP15, Policy No: 18.9. It is important to have an appropriate balance of jobs, services, facilities and homes. There is no mention of amenities or preserving distinctive character and landscape of areas. Policy 12 – Gypsy & Traveller Sites I consider that our CNA has met the requirements with sites in Looe and Pensilva giving a total of four sites for the Caradon area of Cornwall. Policy 15 – Renewable and low carbon energy In areas of outstanding Natural Beauty and undeveloped coast – developments would not be allowed except in exceptional circumstances. The words ‘exceptional circumstances’ must be removed. There must be no commercial development of renewable energy projects in AONBs and other sensitive areas of natural beauty such as SAGLV’s and AGLV’s because by their nature they are obtrusive. Within the Policy 15 of the draft plan I would request a clause preventing wind turbines and solar panels on AGLV, AONB, coastal zones and conservation areas. Policy 22 – Best use of land & existing buildings Policy 22 Best Use of Land & Existing Buildings. Para d. Safeguarding Grade 1,

2 & 3a land & safeguarding grade 3b agricultural land. The council must resist efforts by developers to appoint non independent surveyors to re classify farmland in order to obtain planning consents for a change of use. Classification of agricultural land should be assessed by an independent expert appointed by the council & paid for by the applicant. The importance of all agricultural land must be safeguarded as a means for food production as a source for primary & secondary income for Cornwall [ food produced then processed then retailed]. Solar Panel installations should be promoted only on buildings where their impact is mitigated or on genuine Brown Field sites. The loss of productive farmland in the time of a rapidly increasing population is a very risky development & a poor inheritance for future generations. Policy 22 Para 2.91 The Council should seek to expand the safeguarding of the environment through legislation to extend AONB’s, SAGLVS & AGLV’s and to extend the protection from obtrusive renewable energy projects by confining them to Brown Field sites and to isolated sites where noise pollution will not harm residents. Policy 22 Para 2.95 mention is made of retaining the AGLV’s but not extending them. No mention is made of forming buffer zones from AONB’s and AGLV’s to developments. A new development adjacent to any AONB or AGLV can have just as big an impact as it if was within that area. There is concern that there is a will to downgrade rather than upgrade the status of AGLV’s in order to make life easier for developers. The statement should be that AGLV status should be reinforced not revised. Policy 23 – Natural Environment The AGLV and AONB areas of Looe should be preserved and protected, Policies CL6, CL7, CL9, CL18, CL15 all apply to Looe. It is important to protect our coastal zone and heritage coastline and consider that no development should be permitted within these areas. Policy 24 – Historic Environment Policy 24 makes no mention of the Historic Core of East and West Looe or the listed buildings therein. The retention and enhancement of the historic core is essential to Looe together with the protection of the Conservation Area. (Policy within the Caradon Local Plan 2007 Chapter 5 applies)

Q6. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at

the examination in public No






Signature Date 16/4/2014

If you require any assistance in completing this form or require any

further explanation as to what is required please contact a member of the



that it will process personal data gathered from this form only for the

purposes relating to the consultation.

Personal information will be added to the Council’s Local Plan consultation

database and will be used to keep you informed of progress with the Local





contact you to discuss your comments and concerns, prior to formal

examination of the Local Plan and supporting documents.


representation form


or by post to:


Carrick House

St Clement Street

Truro

TR1 1EB











of personal data by Cornwall Council and that any information received by

the Council, including personal data, may be put into the public domain,




Name Bob Egerton

Organisation Cornwall Councillor

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email Ÿes

Post ¨

Email ¨

Post ¨

Q1. Do you wish to be notified of future stages in the Local Plan including submission, examination and adoption? Yes Ÿes

No ¨

6162

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728


Last year we consulted on a draft Local Plan under the same regulations.

In January 2014 the Council agreed a number of changes to that draft and











Yes ¨ No ¨Don’t think that I did

If Yes;




Yes ¨ No ¨


Yes ¨ No ¨

If Yes;




consideration in relation to a plan being considered ‘sound’:

• Positively prepared

• Justified

• Effective


Legal compliance For a Local Plan to be considered legally compliant, the following needs to

be determined:





• Whether the Local Plan makes satisfactory regard to the





(Local Planning) (England) Regulations 2012

• That a Sustainability Appraisal report is published to accompany the





• That the Local Plan has regard to national planning policy


been complied with.

Q3 A local planning authority should submit a plan for examination which it considers to be ‘sound’. Do you consider the Plan has met these tests? Yes ¨

No ¨


The general concept of the Plan is fine, but I have concerns about some of

the policies as detailed in my submission. Therefore, I cannot give it an

unqualified Yes.

Q4. Do you consider that the Local Plan meets the legal and procedural requirements? Yes Ÿes

No ¨




Strategic Policies 9-10-11 2 Key targets and

spatial strategy


Report

Paragraph 6 Maintain the special character of Cornwall, recognising all

landscapes are important, in order to etc. a, b, c, d

The landscape of central Cornwall has been completely reconfigured by

the activities of the clay and aggregate industries over the past couple of

centuries. Elsewhere are the remnants of mining. The green fields have

been created as the result of deforestation by mankind and the field

patterns have been established by man using the land to grow crops and

keep farm animals. Towns and villages and smaller settlements have been

constructed thereby altering the landscape. Roads and railways have been

built across the whole county to link these settlements. Electricity pylons

cover the whole county bringing energy to all parts. Other infrastructure

such as factories, offices, sewage plants etc. have been imposed in the

landscape. Without them, we would not now be enjoying the benefits of a

modern industrial society. In other words, the whole landscape of

Cornwall is man made. To have as a policy trying to freeze in time the

landscape as it is today at the beginning of the 21st century is to run

counter to everything that man has done for the past few thousand years.

Yes, we need to ensure that change is managed carefully and that we

hope that it will be for the net benefit of Cornwall, but to give the status

quo such prominence and priority will be detrimental to Cornwall. In

particular, paragraph d is a Nimby’s charter to oppose virtually all

development in the AONB (which accounts for such a high proportion of

Cornwall’s land area) and then the addition of “undeveloped coast” with

no definition of what is meant by that phrase imposes a further constraint

on those parts of the land that are not within the AONB.

Paragraph 8 b) v) “supporting the Newquay Cornwall Airport …”

Newquay Airport is of dubious economic benefit to Cornwall, some would

argue that it is a drain on the county’s resources. It does not merit special

status of being explicitly mentioned in what is supposed to be a long term

plan for Cornwall – there is a real possibility that it will sink under the

weight of its own contradictions within a few years. Should be deleted

from this document.


Strategic Policies 20-21 7 Housing in the

countryside


Report

Paragraph 4 of this policy says, “Dwellings for full time agricultural and

forestry and other rural occupation workers will be allowed where

appropriate for these needs and supported by an up-to-date evidence of

need.” I would like this policy to be more relaxed to allow those people

who genuinely wish to work on the land and require accommodation in the

countryside to be allowed to do this even where conventional analysis of

their “business plan” means that they do not meet the somewhat arbitrary

income criteria set by the Land Agent. Many people currently working the

land combine their agricultural income with income from other sources,

e.g. a part-time job, rural diversification etc. and new entrants to the

agricultural system should be accorded the same flexibility.


Strategic Policies 31 15 Renewable and low

carbon energy


Report

Paragraph 4 “In and adjacent to Areas of Outstanding Natural Beauty and

undeveloped coast developments would not be allowed except in

exceptional circumstances and should generally be very small scale in

order that the natural beauty of these areas may be conserved.”

Paragraph 5 “When assessing proposals for wind turbines on the outskirts

of Areas of Outstanding Natural Beauty, the status of the Area of

Outstanding Natural Beauty shall be taken into account when assessing

landscape impact.”

The AONB covers nearly 28% of the land area of Cornwall. To say that

renewable energy installations should be allowed only in exceptional

circumstances and in very small scale is to put up an impossibly high

barrier against renewable energy projects. Paragraphs 4 and 5 are

repetitive in that paragraph 4 specifies “adjacent AONB” and paragraph 5

says “outskirts of AONB”. Neither adjacent nor outskirts are defined,

thereby presenting Nimbies and climate change sceptics with ample

latitude to object to any proposal that might just about be visible from

somewhere within an AONB. The concept of adjacent and outskirts should

be removed and it should be left to the judgment of the planning officer

and/or planning committee to decide if a proposal has an adverse impact

on an AONB. The phrase undeveloped coast should be deleted as it is

meaningless. Paragraph 4 should be amended to say something more

moderate such as “within AONBs, special care should be taken to ensure

that any renewable energy proposal does not severely impact upon the

landscape.”


Strategic Policies 42-43 24 Historic

environment


Report

The phrase “Protect, conserve and enhance” suggests that all change

when there is anything with the label historic, conservation etc. on it is a

bad thing and is to be resisted almost at any cost.

A better policy would be “Pay due regard to historic environment … etc.

and ensure that an appropriate balance is struck between the benefits of a

development proposal and the detriment to the historic assets.”

The policy says that “Development proposals should be informed by a

proportionate historic environment assessment.” This seems eminently

reasonable in theory but, in practice, the volume of information that is

frequently required for an historic environment report, particularly in

regard to renewable energy developments, would be considered by

anyone not steeped in the culture of historic environment to be grossly

disproportionate. It is essential, therefore, that the Council lays down

some guidance on these assessments that demonstrates that it is truly

proportionate.





Yes


Policies please tick the box Yes

If you wish to be notified of the publication of the recommendations of the

independent examination (Inspector’s Report) please tick the box Yes


Policies please tick the box Yes





224283.














representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Paul Jordan

Organisation

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x

Post Email

Post

Q1. Do you wish to be notified of future stages in the Local Plan including submission, examination and adoption? Yes x

No

6162

Typewritten Text

729



In January 2014 the Council agreed a number of changes to that draft and we are now consulting on this amended version, in its entirety as the draft




We are sensitive to the time and effort people made at the last consultation and we are happy to accept comments made previously.




Draft undertaken March – April 2013? Yes No x

If Yes;

Do you want your previous comments to be included as part of this consultation? (If you propose no changes to your comments no further


Yes No

Do you want to make amendments to your previous comments? Yes No

If Yes;





• Positively prepared • Justified

• Effective



be determined: • Whether the Local Plan is detailed in the current Local Development




• Whether the Local Plan makes satisfactory regard to the Sustainable Community Strategy





• That a Sustainability Appraisal report is published to accompany the Local Plan and is adequate




• That the Local Plan has regard to national planning policy • That Section 110 of the Localism Act 2011 (Duty to Co-operate) has

been complied with.


No x



No x


The current statement of community involvement is not effectively inclusive. Many people are not on email/web in the county and the process is difficult to discover and to

participate in



Strategic Policies 31 15.1.d


Report

….do not have an overshadowing or overbearing effect on nearby housing BY RESTRICTING THE SETBACK DISTANCE TO A MINIMUM OF 1500M. The Council has no evidence to define the overbearing nature of wind turbines and needs to establish the facts from affected residents before approving further turbines.

Document Page number Policy number Cornwall Local Plan – Strategic Policies

31 15.4


In and adjacent Areas of Outstanding Natural Beauty and undeveloped coast developments would not be allowed. (DELETE REMAINDER OF STATEMENT) - No wind turbines should be placed within an AONB or within 5 km of the boundary of one. - AGLV’s should be afforded a high level of protection and no medium-size turbines should be built in an AGLV.


Strategic Policies 30 15


Report

Should place a moratorium on all future wind developments until the Council has carried out an informed and comprehensive study (section 2.58, p 30) as to the long-term effects of wind turbine noise/flicker on residents in proximity to wind turbines. It is nonsense to continue to approve these developments whilst carrying out a parallel study to understand detrimental affects.





X

If you wish to be notified of the Submission of the Local Plan – Strategic Policies please tick the box X

If you wish to be notified of the publication of the recommendations of the independent examination (Inspector’s Report) please tick the box X

If you wish to be notified of the adoption of the Local Plan – Strategic Policies please tick the box X

Signature Paul Jordan Date 21.4.14


further explanation as to what is required please contact a member of the local planning team using the email address below or telephoning 01872

224283.

Data Protection In complying with the Data Protection Act 1998 Cornwall Council confirms that it will process personal data gathered from this form only for the










representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Elizabeth Jordan

Organisation

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x

Post Email

Post


No

6162

Typewritten Text

730












If Yes;



Yes No


If Yes;






• Effective

















been complied with.


No x



No x


The community involvement process is difficult to discover and difficult to understand - and by its nature excludes many in the community from effectively being heard





Report

Do not have an overshadowing or overbearing effect on nearby houses by requiring them to be at least 2000m from the nearest residences.

Research the effect on current affected residences before approving any more. Document Page number Policy number Cornwall Local Plan –

Strategic Policies 31 15.4


Report

In and adjacent AONB and undeveloped coastal developments would not be allowed. - No wind turbines should be approved within or close to an AONB. I suggest a distance of at least 5kms No medium size turbines should ever be built in an AGLV




Report

Council should place a moratorium on future wind turbine developments until they have researched the effects on health and wellbeing of residents (section 2.58, p 30) in proximity to wind turbines .

It is unacceptable to continue to approve wind turbines until such a study has been carried out


the examination in public X



If you wish to be notified of the Submission of the Local Plan – Strategic Policies please tick the box X

If you wish to be notified of the publication of the recommendations of the independent examination (Inspector’s Report) please tick the box X


Elizabeth Jordan Date 21.4.14



224283.

Data Protection In complying with the Data Protection Act 1998 Cornwall Council confirms that it will process personal data gathered from this form only for the



database and will be used to keep you informed of progress with the Local Plan and in order to consult with you further at each stage of the process





Observations on Cornwall Local Plan : March 2014 iteration

by email to [email protected]

Page 1 of 1

Summary Strengthen policy statements and reasoning

• Justifying the nil target for alternative development on agricultural land grades 1,2 and 3a by explaining its value in more depth

• Proving that there is no viable alternative to the use of grade 3b land

• Protecting the WHS in the same way that AONBs are safeguarded Reasoning agricultural land

Plan Objective 9c, supporting local food production is good to see. However it should be made clearer that this goes wider across the County than the agri-food focus note on the Key Diagram Planning is fundamentally about the use of land – that is the point of origin of all planning considerations. Because Cornwall is a rural county with a significant rural economy, the protection of its natural land resource [including its economic contribution to national welfare] merits, at the least, the

same consideration as the treatment given to the natural and built environment, landscape distinctiveness, tourism etc. which are mentioned over and over again in the strategy.

Adjusting this imbalance requires a more comprehensive reasoned justification about the value of agriculture and the jobs it supports, both primary and secondary. One obvious place [to me!] would be to add them to the key facts listed for each Network Area. The alternatives to Grades 1, 2, 3a and 3b,

such as using derelict or despoiled land should be explored more rigorously as well. Also there needs to be a clear explanation of how the Council will consider and deal with cumulative impact on its best and most versatile agricultural land. Most Government Agencies acknowledge the

need to do this but are not being properly consulted because the Council is dealing with individual applications on a piecemeal basis. This is not within the spirit of the National Policy Planning Framework and the Local Plan deficiency in this respect needs addressing.

Reasoning WHS

Following a visit to Cornwall’s WHS in October 2013, UNESCO recommended that it would like to see the general planning environment strengthened to protect the WHS from large scale developments “within the designated areas and their buffer zones”.

The UNESCO recommendations 1, 2 and 3 in its report are relevant. They surely show a more useful understanding than English Heritage has managed of the need to protect the “outstanding universal value” particularly with regard to cumulative development impact.

If one looks at the context for the June 2014 UNESCO Conference, the Cornwall and W Devon WHS is on the same list for consideration as Victoria Falls, the Palace of Westminster and similar sites of

“outstanding universal value”. This value needs to be stated much more robustly in the Local Plan as it can then be hoped that the emerging Neighbourhood Plans will be led by example.

Conclusion Please strengthen the Local Plan as outlined above to give proper weight to the priorities relating to best and most versatile agricultural land and to promote the World Heritage Site designation to at least the same level as that for the AONBs.

I sincerely hope Cornwall Council does not overlook what it has until it’s been blanketed remorselessly in grey.

C Trevan, 16 April, 2014

6162

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Cler 8 [email protected] www.parish‐council

CORNWALL LOCAL PLAN – COMMENTS Policy 4 page 16 Shopping Services and Community Facilities.

a) With relation to all points listed. The development of the Park & Ride, Supermarket, Food Hall and Recycling Centre at Eastern Truro goes against every part of this listed policy.

Policy 6 Page 20 Housing Mix.

a) With relation to point 2. None of the points listed appears to have occurred in most developments of ten or more houses that I have seen recently built. There is a much greater need for 1, and 2 bedroom accommodation mainly for rent, but this does not produce a big enough profit for the developers

Policy 7 Page 20 Housing in the Countryside.

a) With relation to point 1) Replacement dwellings. Where we attempted to support a proposal to alter an existing application for holiday lets to a permanent dwelling that fitted this criteria, it was turned down on “sustainability” and being outside the village envelope. What else could be meant by Countryside?

Policy 9 Page 24 Affordable Housing led schemes

a) Mark and note point iii)

Policy 15 page. 31 Low Carbon Energy

a) With relation to point 1. The only proposed Energy from Waste Plant in the local plan is the Mass Burn Incinerator at St. Dennis. This is not low Carbon. It produces twice the Carbon output of landfill (due to Carbon sequestration in the latter) and has 14 times more Carbon output than a sorting/recycling/anaerobic digestion plant

b) With relation to point 1 b) Waste heat, The Incinerator will only produce a potential 8% waste heat. At the moment no facility will use this waste heat so the CHP (combined heat and power) factor is Zero.

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c) With relation to point 1d) Overbearing effect on habitation. The Chimney at St. Dennis will be the tallest man-made object in Cornwall (400 feet) and have an overbearing effect on the entire village.

d) With relation to point 4. ANOB. An SAC (European Special Area of conservation), is the highest level of environmental protection, far higher than an AONB, however the Incinerator is being built within 500 meters of an SAC.

Policy 17 page 32. Health and wellbeing

a) With relation to point 1. Mitigation of pollution. The proposed incinerator at St. Dennis is the only such unit anywhere in the world being built right next to a China Clay works. There is considerable dust in the air in the form of Kaolinite (a form of china clay), which has high absorbent qualities. Clay dust is also a component of Sahara sand and is used for tracking dust storms. The original of the storm is determined by the toxic heavy metal particles attached to the clay particles. There are several peer reviewed scientific papers on this subject from academics in Arabia, Japan and the Far East, showing that Incinerator exhaust emissions also stick to clay particles and accumulate (lead loading up to x40 observed). The current “smog” in the South East is causing problems, but nobody (EA, Public Health England nor Cornwall Council) is prepared to comment on the potential health risk in central Cornwall.

Policy 20 page 38 Strategic Waste Management Principles

a) With relation to point 1. Waste Hierarchy. Cornwall Waste Forum and Eunomia Consultancy have both shown over a period of years during which this policy has evolved, that options higher up the Waste Hierarchy than Incineration can reasonably be realised (and save £320,000,000)

b) With relation to point 3. Recycling and Composting. There have been no proposals to assist communities to recycle or anaerobically digest (which is higher up the Waste Hierarchy than compost), mixed plastics and food waste, despite these facilities being demanded by the general public.

Policy 21 page 38 Managing the provision of waste management facilities

a) With relation to point 1 Recovery of heat – see point b) above with relation to Policy 15. b) With relation to point 2a) Recycling facilities. The Cornwall Council has only constructed two

recycling facilities (MRFs) one in the east and one in the west of Cornwall, neither of which are near the main centres which generate the material (Camborne/ Redruth, St. Austell and


Truro). The sites which are distributed in the correct fashion are HWRCs which are collection only facilities.

c) With relation to point 2f) Transportation other than by road. Cornwall Council selected St. Dennis as the location for the Incinerator on the basis that it was served by a rail line, (this was in fact a planning condition later removed), without first determining whether or not it was possible to use the rail network. It was not.

d) With relation to points 2g) and 2h) Community and local supply chains No attempt has been made to facilitate any proposals to accomplish these policies, in fact any attempt has been deliberately obstructed.

Policy 22 page 39 Best use of land and existing buildings

a) With relation to point 1a) Should give priority to previously developed land. The following large scale developments agreed by Cornwall Council over the period of the emerging local plan include (to my knowledge) Langarth Farm Threemilestone, St. Dennis incinerator, and East Truro Park and Ride plus food hall supermarket and HWRC. All these developments have been on Grade 3 or above Green field sites.

Policy 23 page 41 Natural Environment

a) With respect to point 1. Cornish Landscapes. Does the building of a 240,000 tonnes per year Incinerator with a 400 foot chimney requiring up to 300 vehicle movements per day, in an area between two historic hill forts (An Dinas and St. Denys) with associated medieval field systems constitute a development that recognises and respects landscape character? Does the building of a Park and Ride and Supermarkets on a green approach to Truro up through a beautiful wooded valley with an existing well run farm constitute respect for landscape character?

b) With respect to point 3 b) & 3c) Protection of biodiversity. The site a St. Dennis contains over 50% of the world population of the rarest plant in the UK ( the remaining examples are on Madeira). The plant is Marsupella profunda (Western Rustwort). It is the reason why the area has SAC status. Natural England have stated that the plant will be endangered by the construction of the Incinerator. Cornwall Council fought a High Court ruling to overturn the refusal of planning for the incinerator based on protecting this plant.


Policy 27 Page 45 Transport and Accessibility

a) With respect to point 2. Public Transport and restriction of car travel. How has the developments at Quintrell Downs, and Trevemper achieved this as far as bus services and facilities (i.e. new Doctors surgeries, new schools and college), to prevent car travel from and through our Parish?

b) With respect to point 6.Road traffic impact at Cubert Cross roads has not been mitigated, but could be quite easily with the provision of a roundabout.

Policy 28 page 46 Infrastructure

a) With respect to point 2 page 47 (section underlined) mitigation not delivered on site. This should have been used to ensure parking for Halt Road.

PP7 Pages 78-80 St. Agnes and Perranporth Community Network Area. That this document is a farce should be obvious from the fact that St. Newlyn East, Cubert and Crantock are included in this CNA Policy document when they will obviously be completely overwhelmed by the policy originating next door in the PP8 CNA for Newquay.

a) With this in mind see 10.3 “The focus for growth should be on St. Agnes and Perranporth with good public transport access to Truro. This makes no sense at all for St. Newlyn East, Cubert and Crantock

b) 10.5 How does harnessing the full potential of the waterfront become a community aspiration of St. Newlyn East?

c) 10.7 The area (the whole the six parishes Crantock, Cubert, St Agnes, Perranzabuloe, St. Alan and St. Newlyn East) should plan for about 55 dwellings per year. I think we have more than that just in SNE. See the reference here to Neighbourhood Plans

d) Policy for PP7 page 80 With reference to point f) no evidence of this policy being put into effect.


representation form


or by post to:

Cornwall Council – Local Plans Team Carrick House

St Clement Street

Truro

TR1 1EB







(England) Regulations 2012, requires all representations received to be submitted to the Secretary of State. By completing this form and


of personal data by Cornwall Council and that any information received by

the Council, including personal data, may be put into the public domain,




Name Susan Ball

Organisation

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x Post

Email

Post

6162

Typewritten Text

733


No



In January 2014 the Council agreed a number of changes to that draft and


we propose to submit to the Secretary of State for Examination. If you would like your previous views to be considered at the Examination it is




If you would like your comments to be held over for this consultation you must tell us that is what you want.



Yes No x

If Yes;




Yes No


Yes No

If Yes;





Positively prepared Justified

Effective



be determined:

Whether the Local Plan is detailed in the current Local Development


That community involvement has been carried out in accordance with the current Statement of Community Involvement

Whether the Local Plan makes satisfactory regard to the Sustainable

Community Strategy

That the Local Plan complies with the Planning and Compulsory

Purchase Act 2004 (as amended) That the Local Plan complies with the Town and Country Planning


That a Sustainability Appraisal report is published to accompany the


That the Habitats Regulations Assessment is carried out in accordance

with the Conservation of Habitats and Species Regulations (The Habitats Regulations) 2010

That the Local Plan has regard to national planning policy

That Section 110 of the Localism Act 2011 (Duty to Co-operate) has

been complied with.


No x


I do not feel that the Plan has been produced in a positive manner based on the limited information I have been able to obtain at this late stage in the process.

Q4. Do you consider that the Local Plan meets the legal and procedural requirements?

Yes

No x Please specify the reasons below

I do not feel that the process followed in the production of this Local

Plan facilitates community involvement - a stated objective. I only

recently discovered the existence of the Plan as a result of a chance conversation with a neighbour. Although I have access to

email/internet, I was still unaware of this Plan. As many residents of

Cornwall do not have email/internet access, it means that the whole

process is difficult, if not impossible, to find out about, let alone

contribute to/participate in. Therefore, the process is definitely not inclusive.




Strategic Policies

31 15.1.d - "do not have an overshadowing or overbearing effect on nearby habitations"

My Comments are - the setback distance should be increased to a minimum of 1500m. Currently, the Council has no concrete evidence on which to define what constitutes an 'overbearing effect' and, therefore, should establish the facts from affected residents before approving new wind turbine developments.



Strategic Policies

31 15.4 - "In and adjacent Areas of Outstanding Natural Beauty and undeveloped coast developments would not be allowed"

my comments are - the remainder of para. 4 should be deleted ie. from "except" to and including "conserved." wind turbines should NOT be erected within an AONB or within 5km of an AONB boundary. AGLVs should be afforded a higher level of protection and no medium sized wind turbines should be erected in an AGLV.



Strategic Policies

30 15

My comments are - A

moratorium should be placed on all future wind turbine developments until such time as the Council has completed an informed and comprehensive study (section 2.58; page 30) as to the long-term effects of noise/shadow flicker on local residents. How can the Council continue to approve wind turbine developments whilst undertaking a parallel study to determine the detrimental affects? Also, how can the Council continue to approve these developments without clear written guidelines covering pre-application community consultations etc?

Q6. If your representation is seeking a change, do you wish to participate at the examination in public?





X


Policies please tick the box x

If you wish to be notified of the publication of the recommendations of the independent examination (Inspector’s Report) please tick the box x



Signatu

re

Susan Ball Date 23.04.14



224283.









FM-S-01

Page 1 CAD Architects Ltd Courtleigh House, 74-75 Lemon Street, Truro, Cornwall, TR1 2PN T: 01872 630 040 E: [email protected] W: www.cadarchitects.co.uk

Date: 23 April 2014 File Ref: Representations to CC

Job No:

LOCAL PLAN REPRESENTATION

In respect of Land off B3266 & to South of Fresh Fields and North West of Tor Crag in CAMELFORD

(see attached location plan, land edged red)

Description of the Site

The site lies to the west of the B3266 and extends to approximately 0.8ha (2 acres) and is bounded by

an adopted highway to the east and mature field hedges to the remaining boundaries.

The site has existing development on three sides, (north, east & south) with open countryside to the

west.

The land is currently to grass and is relatively flat, with no intermediate field boundaries or trees,

other than those on the boundary hedgerows.

Opposite the application site is recent housing development.

Character of the Site

The site is situated at the southern end of the village of Camelford, but is well related to and

contained by residential development. Save for the application site the south side of the B3266 is

continuous residential development.

Immediately to the north significant residential development has taken place in a dense two storey

form, creating an extension to the village.

Proposed Form of Development

The site owners wish to promote the land through the local plan process for residential development.

Due to it’s locations, size and character the owners consider the land suitable for development as part

of the body of Camelford.

Prepared by

Mark Dawes

Managing Director

For and on behalf of CAD Architects Ltd


http://www.cadarchitects.co.uk/

6162

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representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Colas UK Ltd John Salmon

Organisation Land & Mineral Management Ltd

Address line 1 Roundhouse Cottages

Address line 2 Bridge Street

Address line 3 Frome

Address line 4 Somerset

Postcode BA11 1BE

Telephone number

Email address


Email

Post

Email x

Post


No

6162

Typewritten Text

735












Yes No

If Yes;




Yes No


Yes No

If Yes;





• Justified

• Effective

















been complied with.


No



No






Report

In order to comply with Policy 18(1) Minerals – General Principles, operators of existing quarries do from time to time need to extend their quarries or improve their workings or working practices or replace, improve or renew plant and machinery or provide new items of plant and machinery with the intention of increasing the efficiency of an existing quarry or preventing sterilisation of resources. In these circumstances such proposals should be supported. It is suggested that a further sub-policy should be added to Policy 18 to say: “Minerals related development which enables greater efficiency in extraction or processing or avoids sterilisation of minerals at existing quarries will be supported”. Document Page number Policy number Cornwall Local Plan –

Strategic Policies


Report


the examination in public X




Policies please tick the box X


independent examination (Inspector’s Report) please tick the box X


Signature John Salmon Date 28 April 2014




224283.














representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Alan Simpson

Organisation

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email EMAIL

Post

Email

Post

Q1. Do you wish to be notified of future stages in the Local Plan including submission, examination and adoption? Yes YES

No

6162

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Yes YES No

If Yes;




Yes YES No


Yes YES No

If Yes;


I would like land at east of Portland Gwavas lane Newlyn TR18 5LH to be included in the

Cornwall Local plan.





• Justified

• Effective



be determined:



• That community involvement has been carried out in accordance with the current Statement of Community Involvement

• Whether the Local Plan makes satisfactory regard to the




• That the Local Plan complies with the Town and Country Planning (Local Planning) (England) Regulations 2012

• That a Sustainability Appraisal report is published to accompany the



accordance with the Conservation of Habitats and Species Regulations (The Habitats Regulations) 2010



been complied with.

Q3 A local planning authority should submit a plan for examination which it considers to be ‘sound’. Do you consider the Plan has met these tests? Yes YES

No


Q4. Do you consider that the Local Plan meets the legal and procedural requirements? Yes YES

No




Strategic Policies


Report


Strategic Policies


Report


the examination in public x




Policies please tick the box


independent examination (Inspector’s Report) please tick the box


Signature Alan simpson Date 24/04/2014




224283.







Personal information will also be shared with the Government appointed planning inspector (from the Planning Inspectorate), who may wish to





representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Kate Little

Organisation Torridge District Council

Address line 1 Riverbank House

Address line 2 Bideford

Address line 3

Address line 4

Postcode EX39 2QG

Telephone number

Email address


Email

Post

Email

Post


No

6162

Typewritten Text

737












Yes No

If Yes;




Yes No


Yes No

If Yes;





• Justified

• Effective

















been complied with.


No



No




Strategic Policies Page 9 Policy 2


Report

We support the identification within the Cornwall Local Plan – Strategic

Policies Proposed Submission Document March 2014 (the ‘Plan’) for the provision of 47,500 dwellings over the Plan period, a figure recognised to

be in excess of the requirement identified through the Strategic Housing

Market Needs Assessment (GVA, July 2013) as being the floor figure for

the objectively assessed need for housing across Cornwall during that

period.

We do however maintain concerns that it is not possible to currently

demonstrate that the Plan will provide for a distribution of housing

sufficient to ensure that the level of housing provided within each

individual housing market area found within Cornwall is such that it will

meet the scale of objectively assessed housing need arising within it; recognising that paragraph 47 of the National Planning Policy Framework

(NPPF) states that local planning authorities should ‘use their evidence

base to ensure that their Local Plan meets the full objectively assessed

needs for market and affordable housing in the housing market area…’. In

particular, we seek assurances that the Plan will provide for sufficient housing within the Cornwall Council area of the Northern Peninsula

Housing Market Area, within which Torridge also resides, to meet the

objectively assessed housing needs generated within it, or alternatively,

that these needs will justifiably be provided for elsewhere within the

Cornwall Council area.

For information, the proposed Publication draft of the North Devon and

Torridge Local Plan (Committee Draft, April 2014) makes provision for the

delivery of housing sufficient to meet the objectively assessed needs for

housing arising from the local planning authority areas of both North

Devon and Torridge, as specified within the Strategic Housing Market Assessment: Torridge and North Devon Update (Housing Vision,

December 2012). As such, Torridge District Council is not seeking, on a

Duty-to-cooperate basis, the assistance of Cornwall Council to contribute

towards the provision of housing to meet the objectively assessed needs

for housing arising from within Torridge.

Q6. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

X

Yes I wish to participate at the examination in public






Signature Kate Little Date 24/04/2014




224283.














representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Councillor Carl Leadbetter

Organisation Newquay Town Council

Address line 1 Municipal Offices

Address line 2 Marcus Hill

Address line 3 Newquay

Address line 4

Postcode TR7 1AF

Telephone number

Email address


Email Post

Email

Post


No

6162

Typewritten Text

738












Yes No

If Yes;




Yes No


Yes No

If Yes;





• Justified

• Effective

















been complied with.


No


Q4. Do you consider that the Local Plan meets the legal and procedural requirements? Yes No




Strategic Policies 11 Policy 2. Key Targets &

Spatial Strategy Sustainability Appraisal

Report

Paragraph 8 lists a number of measures to reflect the importance to the strength of Cornwall’s economy as a whole. Newquay plays a significant role in the wider economy yet the town is only mentioned obliquely with regard to Newquay Cornwall Airport and the Aerohub Enterprise Zone. Several other towns are subject to a broad policy aim. Given Newquay’s economic importance, I believe this is an omission that should be corrected and I offer a new sub-paragraph (between 8e and 8f) as follows:

“supporting Newquay’s wider role as a major national beach-holiday destination and the UK’s surf heritage centre, and grow its role as a centre of excellence for all types of board sports and related leisure activities.”


Strategic Policies 15 Policy 3. Role and

Function of Places. Sustainability Appraisal

Report

The data for Newquay and associated CNA given in the table on Page 15 differ from the data provided for PP8 on pages 80/81. This requires amendment or an explanation for the differences.


29 Policy 14. Development Standards.


Report

Page 29 lists a number of provisions expected of all new developments. Number 4 on the list calls upon the avoidance of adverse impacts during construction, operation or restoration stage of development. The associated content under the heading ‘Development Standards’ does not address the blight caused by empty, dilapidated

or dangerous buildings on the health, wealth and well-being of the surrounding amenity. I believe this is an omission that should be corrected and I offer the following amendment:

“2.55. The presence of long-term empty buildings and sites, or derelict or dangerous buildings, has a materially adverse effect on local community. We will maintain a proactive, cohesive and robust approach to ensure sites and buildings awaiting development do not blight communities.”


Strategic Policies 81 PP8 Newquay & St

Columb Community Network Area.


Report

Page 81 lists specific objectives to be addressed in planning for /Newquay Community Network Area. I would propose a further objective as follows: Q6. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at




Yes






Signature Joe Piwecki Date 24/04/2014




224283.

Data Protection

In complying with the Data Protection Act 1998 Cornwall Council confirms












representation form


Cornwall Council – Local Plans Team Carrick House St Clement Street

Truro TR1 1EB





Regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations 2012, requires all representations received to be submitted to the Secretary of State. By completing this form and

submitting it to the Council you are giving your consent to the processing of personal data by Cornwall Council and that any information received by

the Council, including personal data, may be put into the public domain, including on the Council’s website.



Name Anna Pentecost

Organisation Mylor Parish Council

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address

Preferred

contact method

Email √

Post

Email

Post

Q1. Do you wish to be notified of future stages in the Local Plan including submission, examination and adoption?

Yes √ No


6162

Typewritten Text

739




we propose to submit to the Secretary of State for Examination. If you would like your previous views to be considered at the Examination it is important they are made as part of this consultation.


If you would like your comments to be held over for this consultation you must tell us that is what you want.


Yes No √

If Yes;


information is required). Yes No


Yes No

If Yes;




consideration in relation to a plan being considered ‘sound’: Positively prepared

Justified Effective



be determined: Whether the Local Plan is detailed in the current Local Development

Scheme and that the key stages have been followed, That community involvement has been carried out in accordance


Whether the Local Plan makes satisfactory regard to the Sustainable Community Strategy

That the Local Plan complies with the Planning and Compulsory Purchase Act 2004 (as amended)

That the Local Plan complies with the Town and Country Planning

(Local Planning) (England) Regulations 2012 That a Sustainability Appraisal report is published to accompany the

Local Plan and is adequate That the Habitats Regulations Assessment is carried out in


Regulations (The Habitats Regulations) 2010 That the Local Plan has regard to national planning policy

That Section 110 of the Localism Act 2011 (Duty to Co-operate) has been complied with.

Q3 A local planning authority should submit a plan for examination which it considers to be ‘sound’. Do you consider the Plan has met

these tests? Yes

No √


The proposals do not follow the National Planning Policy Framework. Mylor Parish is in an

AONB designated area and the NPPF states that planning should be refused in these designated areas, except in exceptional circumstances and where it can be demonstrated that it is in the public interest. For the reasons set out below it is not considered that further development on the scale proposed would be in the public interest. A disproportionate emphasis has been given to the development of Falmouth and Penryn. This approach is not suitable for the outlying parishes which have a completely different

dynamic. There are considerable problems with infrastructure, utilities etc, details of which are given below.

Q4. Do you consider that the Local Plan meets the legal and procedural requirements? Yes √

No


Q5. Please provide any comments on the Local Plan – Strategic

Policies. Please use a separate box for each policy.



20

6


2.17 Housing in the countryside. “The Plan will not be defining settlement boundaries around towns and villages but development should however be limited to infill with the built area, not physically extending

these settlements or through affordable housing schemes” The identified potential sites for further development would have the effect of extending

those settlements in Mylor Parish



Strategic Policies

119

21


Report

This refers to policy 22 found on page 39 – d the safeguarding of grade 1,

2 and 3 agricultural land. Target amount of such land lost to other uses should be nil. This target has already been failed by the Bells Hill development on grade 2 agricultural land. This flouting of the Local

Planning Policy target would continue if developments potentially posed by SHLAA for Mylor Parish are ever allowed, as they are also all on graded

agricultural land



120

26 Transport and

Accessibility (refers to policy 27 on P45


26.1 Indicator – “Working age people with access to employment by

public transport” – target 75.1% by 2015 (7 months time). This target is extremely unlikely to be achieved with the almost total lack of public

transport in Mylor Parish. 26.2 Indicator “Access to services and facilities by public transport” –

target increase. It will not be difficult to show an increase here as there is currently hardly any public transport in Mylor Parish



48-49 28


The consultation document says that the Local Plan gives communities a solid framework within which appropriate community led planning policy

documents, including neighbourhood plans can be brought forward and communities themselves can decide how best to plan locally. This is not borne out by the specific proposals for the Falmouth and Penryn

Community Network. Not every parish has yet produced a Neighbourhood Plan, so it is difficult to see how these can form part of the Local Plan at

this time.



68-72 PP5


OBJECTIVES 8.1 Objective 1 – Housing Growth

The proposed development of 225 dwellings added to the existing developments already underway represents a substantial increase and is unsustainable. The size and scale of the development is not appropriate to

the needs, character and services available in the parish of Mylor. This policy appears to be specifically targeted towards Falmouth and Penryn

which have different requirements to villages such as Mylor and Flushing 8.1. Objective 2 Employment There are very limited employment opportunities in Mylor Parish

8.1 Objective 3 Falmouth Town Centre – not applicable 8.1 Objective 4 – Community Services and Facilities – these are very

limited in Mylor Parish

DEVELOPMENT STRATEGY 8.3 Housing It states that priority should be given to the utilisation of brownfield and

urban sites, however according to the Cornwall Strategic site details, the identified sites in Mylor are predominantly on grade 2 agricultural land.

There is no information as to the form in which the proposed new dwellings will take, e.g. houses, bungalows, flats. No attempt has been made to identify the use of existing redundant or

disused buildings for conversion to housing. There should be a survey done to identify these possibilities. The definition of affordable housing is

misleading as many categorised as such are outside the means of local people. There is also confusion as to what the identified need is, the Homechoice Register includes people of low or nil priority (Cornwall

Council’s own wording )and gives a false impression of local need. The emphasis has once again been given to Falmouth and Penryn without due

regard to the sustainability of smaller communities such as Mylor. The individual parishes are in a much better position to identify those with a

local connection/need and much more consultation with the parishes is required, rather than relying on the Homechoice Register. Greater

transparency is needed by the housing associations when asking for the parish council’s views on the allocation of houses. Mylor Parish Council was recently asked if they would be involved in the marketing of an

affordable housing development at Bells Hill, this was assumed to mean with the advertising of the percentage of the houses which were open

market, when what was actually being asked for was a considered response regarding the allocation of those houses. As a result an opportunity was lost by the council to have any influence in ensuring that

local people were given the opportunity to live in the parish in which they were born and brought up. This opaqueness does nothing to foster trust

in the system. The potential site at Trefusis Road in Flushing would worsen an already

difficult situation with traffic. There is only one route in and out of the village and insufficient parking for existing cars, further development here

would necessitate all residents having their own transport as there is no public transport from or to this location.

INFRASTRUCTURE 8.16 Healthcare – the doctors’ surgery in Mylor Parish has very limited

space for expansion. Lots of people have to travel to Penryn for medical care and there is a chronic shortage of public transport. The Parish does not have a train service and the bus services have been drastically cut in

recent months. There is a ferry service from Flushing to Falmouth, but this is weather dependent and does nothing to assist those people needing

to attend Penryn surgeries or to go to hospital. Treliske Hospital is the only major facility in the county and is already under pressure, further

housing will worsen the situation. Education – no mention of the Mylor Parish schools or their capacity to expand if required, which they presumably will need to do with a large

increase in housing. Cornwall Council sold the land that had been reserved for expansion at Mylor, albeit on a restricted basis.

Utilities – again no mention of any places other than Falmouth and Penryn. The sewage system is already struggling to cope with the existing housing in the parish, an increase in housing would exacerbate

the situation. Mylor currently has virtually no mobile phone reception and internet access is limited on the edge of the parish.

Green Infrastructure – by putting so many more houses within the parish this will neither maintain or enhance the strategic green corridors and will

cut down the possibility of providing enhanced walking and cycling routes and ecological corridors

Transportation –the existing highway network is woefully inadequate for existing traffic, let alone a considerable increase. The highways are in a

bad state, and there is a lack of parking and pavements. This puts the walking public at some danger from traffic in the narrow roads. The

suggested sites will only worsen the situation as presumably the majority of new residents will have their own transport. Flushing already has a very real problem with parking, as previously stated there is very limited

public transport to or from the parish. Any increase in housing will lead to further congestion on the main A39 road which is already at full capacity.

Flooding – Flushing is already subject to flooding, Mylor also has areas subject to flooding, including the site identified for future development at

Comfort Road, which sits on a flood plain

There would appear to be a disproportionate emphasis on the development of Falmouth and Penryn with no real thought into the village

parishes within the Falmouth and Penryn Community Network Area. These parishes do not have the retail provision of either town neither do they provide accommodation for the University College. To apply a broad

brush approach to these villages on the same criteria as the towns would inevitably lead to the loss of the individual characters of these villages.

There is also concern that the government is considering the exemption of small housing schemes from section 106 affordable housing requirements. If this is allowed to go forward then any small area of land will be

available for development, eroding further the rural attraction of the villages within the Falmouth and Penryn Community Network. This will do

nothing to increase tourism in these areas as the unspoiled natural beauty is what the visitors visit Mylor Parish to enjoy, not as a dormitory settlement for Falmouth and Truro. Mylor Parish Council originally

responded with a preference for town development as an alternative to encroaching on the rural settlements, but this plan appears to want to do

both.



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representation form



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Name Henry Christmas

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been complied with.


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I do not believe that sufficient weight is given to matters affecting villages. As an example, in the case of Falmouth/Penryn a village such as Mylor or Flushing is given the same

treatment as a town.


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Life is too short and/or the time remaining also in order to answer this part. It is also too short to be able to delve into such matters.



20 6


I endorse the comments made by Mylor Parish Council. I see no attempt at compliance between the statement in the plan and the proposals relating to the identified potential sites.




Report

I endorse the comments made by Mylor Parish Council.


Strategic Policies 120 26 Transport &

accessability(refers to

Policy 27 on P45.


Report

I endorse the comments made by Mylor Parish Council. No account has

been taken of the current situation with regard to transport. Another

example of lack of consideration of the special cases of villages as opposed to towns.


Strategic Policies 48-49 28


Report

I endorse the response of the Mylor Parish Council. It is undemocratic to

base the imposition of plans upon villages when their wishes must be

expressed in such documents as Neighbourhood Plans. I am given to understand that such documents are very expensive to realise and cannot

be paid for from local resources.


68-72 PP5


I agree with all of the comments made by the Mylor parish Council

ADDENDUM.

The Cornwall Local Plan is a vast document with a complexity that defies

full assessment by a mere mortal who has not spent his life in the

planning sphere. I have therefore concerned myself with those matters that are of concern to me, and the geographical area known to me,

namely Mylor. The matters of my concern are, broadly, the expansion of

the village of Mylor Bridge, and the local environment in the Mylor parish

area. Although largely confined to these, I use them to exemplify concerns

held by many people, I believe, in many outlying parts of Cornwall.

I have scanned through the document entitled 'Cornwall Local Plan

Strategic Policies - Proposed Submission Document 2010-2030', and also

the 'Sustainability Appraisal Report' and it's addendum. I have picked out

the following concerns:

Good health and wellbeing. Environment. Agriculture and food supply.

Landscape. AONB. Infill. Boundaries. Countryside. Village identity, and

Safeguarding land.

On the subjects of Agriculture and food supply, Landscape, AONB, Infill, Boundaries, Countryside, Village identity, and Safeguarding land. These

are obviously all interlinked.

Good health and wellbeing is Theme 3 (p.7). The requirement is for

ensuring appropriate levels of open space and improvement of air quality. This is not achieved by promoting the expansion of small settlements into

larger ones. Surrounding open countryside is the lungs of the population

as a whole.

Related to this is the lack of provision of open space for child play. I have

in mind the current Bells Hill development, where 30 dwellings are being

completed, largely for young families, but there is no play area. Presumably small children are expected to go to the play area in the

playing fields half a mile away, through traffic on busy roads. Clearly, an

open space is much less profitable than a play area, but this has never

been addressed, to my knowledge, including in the proposed plan. This is

also referred to (obliquely) in Policy 17/2, and 17/5, where reference is made to "the opportunity for physical activity through the use of open

space…. outdoor sports & leisure facilities….", and flexible community

spaces that can be adapted to the health needs of the community".

Children, however, are not mentioned.

It goes almost without saying that the environment is key, and it is

difficult to separate from all of its forms and considerations, as in the list

above. Landscape, countryside, and AONB are almost synonymous to me,

and there are numerous references to these in the document. Examples

are: Paragraphs 1.21, 1.22, 1.23 (page 9), which generalise.

Paragraphs 1.24/6 (Page 10), which seeks "to maintain the special

character of Cornwall, recognising that all landscapes are important", and

particularly to "protect the natural beauty of the AONB" (subsection d).

Paragraph 2.88 (Page 39) and following detail considerations of

stewardship with regard to areas such as AONB. This is enshrined in Policy 23 -Natural Environment, and amongst other matters points out the

danger of cumulative impact. I understand from this that the danger is

recognised of one Policy 3 (Role and Function of Places) development

opening the way for further adjacent development. This has been the fear

with regard to the Bells Hill development, and similarly the current Cogos Park proposal. In both of these cases provision has been made for access

to later development.

Paragraphs 2.103, 2.104, and 2.105 talk about green infrastructure,

enshrined in Policy 25, and I read into these that green spaces in towns and villages are supported, but that play areas should be included.

Infill. Par.1.29 suggests the use of 'infill sites within the built form of the

settlement'.

1.30 states that there is a difference between them according to

whether they are in towns and large villages or small villages and hamlets.

1.31 defines such differences as (i) the filling of a small gap in an

otherwise continuously built up frontage that does not physically extend

the village etc. into the open countryside. (ii) The redevelopment of an

existing previously developed site within or adjoining the settlement or

(iii) the rounding off of a settlement where its edge is defined by a physical feature such as a road. 'Rounding off' is a policy that is currently

promoted, for example in Councillor's education briefings by the County

Council. It will be of great interest to see whether this changes from now

on.

1.32 states "Many frontages however are not continuously built up and have substantial gaps between buildings or groups of buildings. These

gaps provide the setting for the village, hamlet or small settlement, and

add to the character of the area. They are not appropriate locations for

infill development, and the development of such large gaps would not

therefore be considered as infill under the policies of this Local Plan.

'Rounding off' is a policy that is currently promoted, for example in

Councillor's education briefings by the County Council. It will be of great

interest to see whether this changes from now on.

Policy 3.3 encapsulates this as follows; Infill for the purposes of residential development should be proportionate

to the scale of the settlement and within its boundaries, respect the

settlement and landscape character of the locality and not physically

extend the settlement. It must clearly relate to part of an established

settlement and not isolated dwellings. Particular preference will be given to sites on

previously developed land.

2.17 Housing in the Countryside:

The plan seeks to address the needs of rural areas, looking in particular at shared solutions to the provision of services and facilities locally as well as

options for improving access to larger centres. It is important that these

rural areas can continue to thrive both economically and socially.

The plan will not be defining settlement boundaries around towns and

villages but development should however be limited to infill within the

built area, not physically extending these settlements or through affordable housing led schemes (i.e. exceptions where an element of

market housing is allowed to support their delivery). The focus is upon

local needs and reflecting and respecting the character of Cornwall's

settlements. Neighbourhood plans may if they feel it appropriate look to

identify specific settlement boundaries consistent with this approach.

Extracts from 'Addendum to Sustainability Appraisal'.

Policy 3 Role and Function of Places:

"This amendment attempts to make the policy much clearer in terms of the

definition of infill and what type of infill is appropriate and where. It also

attempts to reduce the effects of sprawl in village settings".

Agricultural food supply.

Several references are made to the need to preserve the ability to provide

a local food supply, by not intruding upon green agricultural land.

Objective 9 (page 8) advocates "supporting local food production".

Spatial Strategy (page 9), speaks of "the ability for farming and fishing to adapt to the future demands of more local food supplies will be an

important element".

Policy 17 (Page 32) - Health and wellbeing mentions "provision for

growing

local food such as allotments". Par. 2.87 (page 39) says "it will support our ability to respond to longer

term global changes. It will also strengthen a range of objectives; the

protection of our environment (and) aim for self sufficiency in energy and

food and export markets".

Policy 22 (Page 39) mentions the safeguarding of Grade 1, 2 and 3a

agricultural land for food production and, where reasonable alternatives for development can be identified, the safeguarding of grade 3b

agricultural land.

(NB. The Bells Hill and proposed Cogos Park developments are both on

Grade 2 land!).

2.104 (Page 43) says "therefore good quality well planned and appropriately located green infrastructure is critical to Cornwall's future.

Not only does it

help us to live more sustainably and self sufficiently, it helps to increase

resilience and adaptation to climate change and supports ecosystems

providing for food production".


the examination in public √




Policies please tick the box √


independent examination (Inspector’s Report) please tick the box √


Policies please tick the box √

Signature H.F.Christmas Date 24/04/2014

6162

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741

POLICY 2 – KEY TARGET AND SPATIAL STRATEGY

Paragraph 159 of the NPPF requires Local Planning Authorities to assess their full housing

needs including identifying the scale and mix of new housing and range of tenures over the

Plan period. It is extremely unclear from reading the Strategic Housing Market Assessment

July 2013 (SHMA) what the objectively assessed need for market and affordable housing is

over the Plan period. It is also very unclear what the need for other forms of tenure might be

(e.g. private, rent, student housing, retirement housing etc).

Furthermore, it is unclear from the SHMA what the Council considers the actual market need

to be over the Plan period. Indeed the Local Plan confirm that at Paragraph 2.12 where it

states:

“There is no precise measure to predict what level of housing we need to plan for.

Out target is judgement ...”

This figure does not appear to have been identified. Instead Chapter 4 of the SHMA

identifies a range of projections over the Plan period 2010-2030. These projections generate

a range of housing projections from 47,300 to 71,980 dwellings. It is unclear how the figure

of 47,500 new housing within the Local Plan was arrived at especially as it is at the lower end

of the projection range. There is an indication from the Housing Evidence Base Briefing

Note 2 that the housing provision of 47,500 “is mainly based on the SHMA demographic

projection of 47,300”.

However, the SHMA report is clear that the demographic scenario outputs should be

considered to represent a minimum for assessing the housing pressure likely to result from

the growth in households considering the latest demographic evidence at the time of the

research. The report also concluded that it would be important to view the higher

employment land projections as an important benchmark for undertaking the potential future

growth of Cornwall recognising that this will be driven by a continued in migration of people

from outside of the area looking to take up new employment opportunities. The

consideration and treatment of factors such as employment, economic activity rates etc

concludes that the upper levels of housing provision should be utilised.

Accordingly, the Plan does not meet the objectively assessed housing need for the Plan

period. Furthermore, there is no indication within the evidence base of any testing of a higher

housing provision. The accompanying Sustainability Appraisal does not test any housing

scenario higher than 48,000 new dwellings. This is clearly a flawed approach in that there is

no justification for such a lower housing provision especially given the Government guidance

in the NPPF to significantly boost new housing development.

The Council has not indicated how the unmet need will be addressed.

With regards affordable housing paragraph 4.3 indicates a need of 2,241 houses per annum or

11,205 over the next 5 years, but it is unclear what the Council consider the affordable

housing needs will be over the full Plan period. Nevertheless, a need of 2,241 affordable

homes per annum would indicate that the Core Strategy proposed annual requirement of

2,680 new dwellings per annum for all types of accommodation to be totally inadequate to

meet combined housing needs i.e. open market and affordable.

There are fundamental flaws with the way in which the Council has sought to identify its

housing provision over the Plan period. Accordingly, the following recommendations are

suggested.

Recommendation

The Plan is unsound in respect of proposed housing provision in the Plan period in that

it does not seek to meet its objectively assessed housing needs for the area in the Plan

period. The Plan has not been positively prepared and is inconsistent with national

policy.

The housing provision of 47,500 is too low and should be significantly increased i.e. to

65,000. Accordingly, it is contrary to national policy.

The Plan is unsound in that it has not tested any higher housing provision within the

Sustainability Appraisal.

The Plan is unsound in that it has not demonstrated how the unmet housing need will be

met.

The provision for affordable housing is unsound in that the total need has not been

identified over the Plan period. Accordingly, it is unsound and not in accordance with

the NPPF.

POLICY 3 - ROLE AND FUNCTION OF PLACES

The objectors welcome the principle of the policy which seeks to identify larger scale

residential and employment development in a number of settlements. However, nowhere

within the policy or the supporting text does it identify or define ‘larger scale’ ….

development’. Furthermore, it is unclear how the list of settlements has been arrived at

particularly as Helston has not been included within the list of settlements. The objector

controls considerable land to the north east of Helston which is suitable for housing

development. Indeed, the land to the north east has been identified as Site HX1 in the

Helston Town Framework as being suitable for a possible urban extension to the town.

Accordingly, Helston should be considered for inclusion within the list of suitable settlements

for large scale development in particular. Helston has a wide range of services, shops and

employment provision. It is linked to RNAS Culdrose which covers 600 ha and has in excess

of 3,000 service personnel. It is the largest single site employer and a major source of

spending in Cornwall. In addition, other employment opportunities exist at Water-Ma-Trout,

the main industrial estate which is at capacity. The settlement is of a scale where it should be

included within the list of settlements which can accommodate ‘larger scale development’.

It is unclear within the supporting evidence base why it has been excluded. The Local Plan

should be amended accordingly.

The Helston Framework Plan identifies a number of sites for possible residential

development namely:

U1 Land at Clodgey Lane and Falmouth Road – 134 dwellings – extant permission.

The original permission dates back to the 1980s and has not yet started. The site is still

to be developed and part of the site area has been altered since Tesco’s has been

constructed. Part of the Tesco’s car park has encroached on the permitted area.

Furthermore, the permission was granted at a time when no affordable housing is

provided. It is therefore unlikely that 134 dwellings will be built and the site should not

be included in the trajectory plan.

U2 Land at Clodgey Lane – 46 dwellings permission granted

There is no access available to this site and it appears to be ransomed. Accordingly, it

is unclear when this site will come forward for development, if at all. Site cannot be

relied upon to deliver any dwellings.

U3 Land behind Mormon Church Clodgey Lane

No planning permission exists for this site. There is no indication that the site is

available for housing development. Site cannot be relied upon to deliver any houses.

U4 Land off Hillcrest

No planning permission exists for this site. Furthermore, no application has been

submitted. There are access concerns with regards the site. In addition there are

potential open space/village green issues associated with this site. Site cannot be relied

upon.

U5 Land off Passmore Road – 32 dwellings

This site is under construction.

U6 Land adjacent to Tesco’s & Feathill Ground

Part of the site comprises formal open space which has been laid out as such. It is

considered that this site is unavailable for residential development as it would include

the loss of formal public open space. Site is not available to residential development.

U7 Land at Falmouth Road/Bypass

No planning permission exists on this site.

This site falls within Flood Zone 3. This represents a significant constraint to its

development. Site cannot be relied upon until the flooding issue has been resolved.

It is apparent that these sites will not deliver the numbers anticipated by the Planning

Authority. They will not deliver any signficiant amount of affordable housing.

With regards to the housing distribution, objections have already been made to Policy 2 ‘Key

Targets & Spatial Strategy’ concerning the overall level of housing provision in the period up

to 2030. Table 1 however, identifies a broad distribution of new dwellings across the

Council’s area and some 36 locations are identified. However, there is no explanation as to

how the distribution of dwellings was arrived at. However, it is understood that 1,100 new

dwellings were identified for Helston but that this was reduced at the Council meeting on 12th

February 2013, albeit no justification appears to be available. Furthermore, it is interesting to

note that despite the overall housing provision being increased no additional housing has now

been proposed for Helston. No explanation has been given as to why the housing provision

has not been increased given the suitability credentials of the town. In view of the above

comments, it is recommended that the overall level of housing be increased and accordingly

the distribution to settlements such as Helston should also be increased to some 1,500-2,000

dwellings and 900 dwellings in the remainder of the CNA. Part of the reason to increase the

housing provision is to meet the chronic shortage of affordable housing. The report entitled

‘Growth Factors’, Helston and Lizard Community Networks identifies an annual affordable

housing need of 77 dwellings per annum i.e. 1,540 dwellings over the Plan period. This will

not be met from the current proposed level of housing, especially as the historic sites will

provide little if any affordable housing. It is considered that the Council’s analysis of such

sites is incorrect and a further 200 dwellings needs to be included to the Helston housing

provision. This would enable a wider choice of sites to be identified which would aid

housing delivery and together meet housing needs. In addition it is recommended that the

level of employment development be increased especially where identified sites are available

and deliverable.

Recommendation

It is therefore recommended that the Local Plan be amended to identify Helston as a

settlement which can accommodate larger scale residential and employment development.

The level of housing development should be increased to between 1,500-2,000 dwellings in

Helston and 900 dwellings in the remainder of the CNA.

Paragraph 1.36 – Housing Land Availability

Objections are lodged to the proposed change in approach to calculating the 5 year housing

land supply requirement. The Local Plan is now proposing to assess the 5 year housing

requirement on a County wide basis as opposed to Community Network Area.

We are concerned as to this change in approach, no doubt the council consider that it will find

it easier to demonstrate a 5 year supply of deliverable housing over the County wide area as

opposed to the Community Network area.

Experience in Wiltshire has shown that rather than calculate the 5 year supply over the entire

County Area that Housing Market Areas are used. This approach ensures that housing is

directed to those areas which need it. Accordingly we object to the change in approach and

recommend that the 5 year housing supply remain to be calculated on the Community

Network Area.

Recommendation

Object to the 5 year housing land supply being calculated over the County Wide Area.

Retain the current methodology of calculating it over the Community Network Area.

POLICY 8 - AFFORDABLE HOUSING

The NPPF makes reference to the need to make provision for all housing need in an area

to be met. With regards affordable housing however the NPPF advises that the economic

consideration of providing affordable housing must be taken into consideration. Of

particular concern with the policy are the following factors: -

i. Affordable housing being provided on all new housing schemes where there is a

net increase of 2 units or more than 0.2 hectares. The level of affordable housing

is expected to be delivered without any public subsidiary.

ii. The community are unlikely to be supportive of that level of affordable housing.

iii. The level is not reflective of values, scales, rates, lending criteria and the current

housing market in Cornwall.

iv. It exceeds the requirements of dRSS which was prepared in a good economic

climate when grant funding was available. This is a poor market with no grant

funding and is unlikely to change significantly during the plan period.

v. The balance between affordable housing and housing that is affordable is

complex. The proportion of affordable housing will necessitate market demand

to a much higher overall housing figure in order to meet the needs of local people

who do not qualify for social housing like most of them.

vi. A viability clause is required in the policy for when it cannot be delivered.

vii. The scale of affordable housing will limit the availability of finance to S106 and

infrastructure improvements significantly.

Recommendation

Whilst there is no objection in principle to the provision of Affordable Housing, it is

considered that the policy is fundamentally flawed and is underpinned by an unsound

viability assessment.

The policy needs to be amended with the thresholds increased to enable a more realistic level

of affordable housing to be provided.

POLICY 28 - INFRASTRUCTURE REQUIREMENTS

There is no objection of this policy, in principle, which requires infrastructure needs for and

arising from development. However, it must be demonstrated that the requirement complies

with the guidance in NPPF and the Community Infrastructure Levy 2010 (CIL) Regulation

122 i.e. that it is reasonable, necessary and proportionate to the development being proposed.

Concern is therefore raised to the requirements within this policy to fund specific and

essential infrastructure and provision not in the Regulation 123. It is unclear what is meant

by these phrases clearly if the Policy is seeking contributions not sanctioned by NPPF or CIL,

then there is no justification for the funding sought.

There is no objection in principle to the provision of an Infrastructure Delivery Plan and

Schedule. It is considered that such a document can provide certainty with regards the likely

infrastructure improvements that need to take place and how they should be funded.

However, such a document must be realistic and prepared in open discussion with the

developers who will deliver the scheme. All too often the Infrastructure Delivery Plan and

Schedule is prepared with no discussion with developers, rendering it worthless.

Finally, support is given to the recognition that independent viability testing is at times an

essential part of the development process. It is however, not necessary for every scheme to

submit an independent viability assessment. The policy should also recognise that some

payments may not be capable of being made but that the scheme’s implementation is

essential and so payments are not required.

Recommendations

i. The requirement for an independent viability assessment on every scheme should

be deleted;

ii. Infrastructure Delivery Plans and Schedules should be prepared in consultation

with developers;

iii. Full definitions of specific and essential infrastructure to be provided;

iv. Recognition should be given that some development may be not be able to fund

all of the required infrastructure provision and deferred or no payments will be

required.

POLICY PP3 HELSTON & LIZARD CNA

At the outset, the specific section on Helston and Lizard CNA is welcomed. These

representations should be cross referenced with our representations in respect of Policies 2

and 3 in particular. Those representations requested that the overall housing provision be

increased and that the housing distribution for Helston be increased to between 1,500-2,000

dwellings and 900 for the remainder of the CNA. It also identified an issue that the suggested

levels of housing commitments in the town of 450 dwellings is incorrect. The level is more

akin to 250 dwellings. These comments were also made in respect of the previous version of

the Local Plan. In addition, the representations seek to identify Helston as a settlement

capable of accommodating larger scale development given its relationship to RNAS Culdrose

and the wide range of shops, services and facilities within the settlement.

The objectors have concern at the lack of site identification in the Local Plan and the

potential delay in housing and employment delivery if housing and employment site

allocations are left to the Sites Allocations DPD or Helston Town Framework.

They consider that to aid housing delivery, including the provision of affordable housing, and

provide certainty that the Local Plan should be proactive and specifically identify land on the

edge of Helston i.e. north east Helston in particular to accommodate future development.

We are aware that some work has already been undertaken with regards to potential options

for future development at Helston i.e. the Helston Town Framework. We are also aware that

the Council has recently indicated a preference for an alternative site known as HX2 albeit

the basis of that decision is unknown as there is still technical work that has not been

completed. The objector controls land to the north east of Helston identified as HX1 on the

accompanying plan. They consider that given the number of town and the need for both open

market and affordable housing that 2 sites should be identified. The owner of site has

assembled a consultant team to bring forward the delivery of the site. Work is currently

underway with regards to ecology, landscape and visual impact, highways, drainage,

archaeology etc. Initial work to date indicates that there are no constraints to the

development of the site. It has been suggested that proximity to town centre and health

facilities as well as a lack of community facilities are reasons not to identify the site

However, these are not justified reasons because:

i) The site is as close to the town centre by walking and cycling as HX2;

ii) The site is closer to the major employment area in the town;

iii) Additional health and community facilities can be provided as part of the

development;

iv) This is the only site that can provide part of the Trewennack Bypass.

In view of the above the suggested reasons for not preferring this site are not justified.

With regards the land identified HX1 there are no constraints to the development of that land

in terms of technical or environmental issues and that the site forms a logical extension to

Helston to clearly defined and definable boundaries. Accordingly, it is considered that the

site should be identified as an urban extension for circa 400-500 dwellings in this Local Plan.

This would provide certainty towards its delivery and would enable the objector to proceed

with further plan making etc to enable implementation to take place in the short term. In

addition following public consultation the allocation of the site has considerably local support

particularly for Helston Town council who unanimously support the allocation of site HX1.

The site would help to satisfy many of the points listed as necessary in the Cornwall Delivery

and Investment Plan, in particular education contribution, open space provision, outdoor

sports facilities and doctors surgery. The site would also provide much needed affordable

housing in Helston.

Recommendation

The Local Plan makes provision for some 1,500 to 2,000 dwellings in Helston

The Local Plan identifies land to the north east of Helston for residential development.

From: Dan James Sent: 25 April 2014 17:09To: EP&E Local PlanCc: Ormella RuthSubject: Local Plan comments

Page 1 of 2

29/04/2014

Dear Local Plan Team The following note is a response to the current draft of Cornwall’s Local Plan. As a significant contributor to the Cornish economy, we believe that Eden Project and its future plans shouldbe acknowledged within the document as being of strategic importance for both the St Austell and ChinaClay area and Cornwall generally. Eden’s first chapter, the first ten years was based on establishing a world class tourism destination that hadenvironmental education for the public at its heart. The Project now 13 years old, has welcomed 16mvisitors through its doors and contributed £1.3bn to the Cornish economy. At the time of writing there are375 FTE employees rising to nearly 500 in the summer months when temporary staff join us for the reallybusy period. Chapter two, the next ten years, is about growing the audience, growing impact, and growing influence bydriving and new set of projects that help to transition the site into a year round campus with tourism, leisureand education customers. These projects can play an important part in helping to transform the lives,environments and opportunities of the people who live in St Austell and the China Clay area. Projects will include

1) The Science showcase ‐ the development of the second phase of the Canopy Walkway, re‐invigorating and refreshing the importance of the rainforest and our understanding of dependenceon nature.

2) Eden Accommodation – two types of accommodation, one in partnership with the Youth HostelAssociation, the other. A modular 120 bed accommodation unit. Both located within the boundariesof the existing Eden site

3) Showcase for energy – the development of the UKs first Geothermal energy plant 4) Food and Horticultural campus ‐ A major new learning center run in partnership with Cornwall

College that will use the existing set of farm house buildings located on Eden’s pit parameter 5) Business space at Eden – a hub of offices and workshops for entrepreneurs and businesses located

near the Eden Foundation building. This would supplement the development of the national SolarCentre’s PV testing facility and the Cornwall Sustainable Buildings Trust‐ Green Build Hub, both dueto be constructed on the Eden site within this year.

In previous years there has been Special Planning Guidance developed in relation to the Eden effect of any future development on site. We believe these plans are important for the area and whilst maybe not referenced specifically within the plan, we are looking for some acknowledgement that sustainable development of the Eden site is of importance to the local area. Best wishes Dan

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Dan James Development Director

The Eden Project. Home of the Eden Trust. Charity No. 1093070

This message may contain information from The Eden Project that is privileged or confidential. If you are not the intended recipient, please be aware that any further disclosure of this message is prohibited. Please let The Eden Project know that an error has occurred by calling or messaging the sender.

The Eden Project has taken all reasonable precautions to ensure that no viruses or damaging material are present in this e-mail. We cannot accept responsibility for loss or damage arising from the use of this message or attachments and suggest that you use virus checking procedures in the normal way.

Page 2 of 2

29/04/2014

Cornwall Local Plan – Strategic Policies Proposed

Submission document March 2014 representation

form Representations can be submitted by email to [email protected] or by

post to:


Carrick House

St Clement Street Truro

TR1 1EB




Part A: Your personal details You must complete Part A for your representations to be accepted. The Council

can not accept anonymous representations.

Regulation 22 of the Town and Country Planning (Local Planning) (England)

Regulations 2012, requires all representations received to be submitted to the

Secretary of State. By completing this form and submitting it to the Council you

are giving your consent to the processing of personal data by Cornwall Council and that any information received by the Council, including personal data, may

be put into the public domain, including on the Council’s website.



Name Louise Dowe

Organisation St Ives Town Council

Address line 1 The Guildhall

Address line 2 Street An Pol

Address line 3 St Ives

Address line 4 Cornwall

Postcode TR26 2DS

Telephone number

Email address


Email Post Either

Email Post


No

6162

Typewritten Text

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Last year we consulted on a draft Local Plan under the same regulations. In

January 2014 the Council agreed a number of changes to that draft and we are

now consulting on this amended version, in its entirety as the draft we propose

to submit to the Secretary of State for Examination. If you would like your

previous views to be considered at the Examination it is important they are made as part of this consultation.

We are sensitive to the time and effort people made at the last consultation and

we are happy to accept comments made previously.

If you would like your comments to be held over for this consultation you must

tell us that is what you want.

Q2 Did you make comments on the Cornwall Local Plan Pre-Submission Draft

undertaken March – April 2013?

Yes No

If Yes;

Do you want your previous comments to be included as part of this consultation?

(If you propose no changes to your comments no further information is

required).

Yes No


Yes No

If Yes;






Still uphold call for Cornwall Council consultation with St Ives Town Council on Community Infrastructure Levy – St Ives Provision. And still ask that the definition of affordable homes helps to ensure homes for local people.

• Effective


Legal compliance For a Local Plan to be considered legally compliant, the following needs to be

determined:


Scheme and that the key stages have been followed, • That community involvement has been carried out in accordance with the

current Statement of Community Involvement

• Whether the Local Plan makes satisfactory regard to the Sustainable

Community Strategy

• That the Local Plan complies with the Planning and Compulsory Purchase

Act 2004 (as amended) • That the Local Plan complies with the Town and Country Planning (Local

Planning) (England) Regulations 2012

• That a Sustainability Appraisal report is published to accompany the Local

Plan and is adequate

• That the Habitats Regulations Assessment is carried out in accordance with the Conservation of Habitats and Species Regulations (The Habitats

Regulations) 2010


• That Section 110 of the Localism Act 2011 (Duty to Co-operate) has been

complied with.


No



No




Page 7 Theme 1 – objective 1


Report


Strategic Policies Page 9 Paragraphs 1.20 and 1.23


Spatial strategy – paragraphs 1.20 and 1.23 seem to be very similar in context, both referring to ‘sustainable pattern of development.’


Page 10 Policy 2


Report

...’employment opportunities to drive an increase in the Gross Domestic Product

to rise above 75% of the EU’s average’. It is unnecessary to include a meaningless percentage target. The statement could end with ‘....Gross Domestic Product’.

Theme 1 – ‘Remove unnecessary barriers to jobs.....’ – this implies that there are necessary barriers. Why not simply say ‘Remove barriers to jobs.....’?


Page 10 Policy 2 c


Report

The word ‘qualities’ should be deleted.


Page 11 Policy 2 8 b)iv.


Report

The phrase ‘will be supported’ should be deleted.


Page 11 Policy 2 8 e)


Report

It should be emphasised that ‘economic growth along the A30 and A38’ is

employment space, not retail outlets in competition with town centres. Document Page number Policy number Cornwall Local Plan – Strategic Policies

Page 11 Policy 2 8 f)


Report

Reference to marine businesses should include the Hayle Wave Hub. (This should also be included under renewable energy).


Strategic Policies Page 13 Paragraph 1.38


Paragraph 1.38 has been deleted but the subsequent paragraphs have not been

renumbered accordingly.




The plan should give a stronger message, not simply a sequential test, to discourage edge of centre development in order to retain viability of our town

centres.


Page 14 Paragraph 1.42


Report

Paragraph 1.42 ought to include cinemas in the long list of community facilities.

Some of these are currently under threat, as are facilities which are operated by Cornwall Council. Future cut-backs in funding could result in the loss of facilities

such as libraries and leisure centres. Where such facilities are considered to be essential services for local residents, would this be a reason to prevent

development. Document Page number Policy number Cornwall Local Plan –


1


The second sentence does not make sense. How can ‘Retail and other town centre uses’ be ‘outside defined town centres’? Perhaps this confusing sentence

could be omitted completely.




Report

Paragraph 2.6 – Break the first long sentence with a full stop after

‘environmental well being’. Then start a new sentence – It generates significant revenues......’




Report

Paragraph 2.19 – ‘Development particularly providing homes and employment that meets needs arising from these rural communities is encouraged’ – not are encouraged.


Page 22 Policy 8


Report

‘50% in Zone 1 and 2 including the town of St Ives’ – there is little, if any,

room for development in the town itself. The development target is for the Town Council area which includes Carbis Bay (but not the outlying communities of

Lelant and Halsetown).


Page 23 Policy 8


Report

‘70% rented homes owned and or managed by a bone fide affordable

housing provider’ – should be ‘bona fide’.




‘....off site contributions......’ There should be more emphasis on developers providing the required percentage of affordable housing on site. It is too easy for

developers to push the affordable housing elsewhere by means of planning obligations. This results in yet more land, often Greenfield sites, being lost to

housing. The default position should be on site construction, not off site contributions.


Page 25 Policy 10


Report

‘the Council will seek to negotiate an element of affordable housing to a target of 50%.... In order to make this more positive, the ‘seek to’ should be

removed – ‘the Council will negotiate.....with a target of at least 50%’.


Page 26 Policy 11


Report

As for Policy 8 above, the same comments on off site contributions apply to parts of this policy.




Report

Paragraph 2.58 – It should be explained that the following applies to wind

turbines – ‘the impact of lower frequency noise and aerodynamic intermodulation and their effect on people’.



1c


Report

1.c. How is it possible to mitigate against unacceptable shadow flicker?


Page 31 Policy 15 4


Report

4. It should be ‘in and adjacent to an Area of Outstanding Natural Beauty’.



5


5. What is meant by the ‘status of the AONB’ which ‘shall be taken into account’.




Paragraph 2.89 ......’so that growth is complimentary’ – should be complementary’.




Report

Paragraph 2.75 has been deleted but the numbering of the subsequent

paragraphs has not been adjusted accordingly. (This combined with aforementioned deletion of 1.38 means that the numbering is incorrect

throughout most of the document.




There is no point ‘e’ between d & f (this error has been carried forward from the previous draft)

Q6. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the

examination in public No





Signature Date 25 April 2014

If you require any assistance in completing this form or require any further

explanation as to what is required please contact a member of the local planning

team using the email address below or telephoning 01872 224283.

Data Protection In complying with the Data Protection Act 1998 Cornwall Council confirms that it

will process personal data gathered from this form only for the purposes relating

to the consultation.


database and will be used to keep you informed of progress with the Local Plan

and in order to consult with you further at each stage of the process to enable

you to make future comments.


planning inspector (from the Planning Inspectorate), who may wish to contact

you to discuss your comments and concerns, prior to formal examination of the

Local Plan and supporting documents.

3

St Ives Town Council considered the local plan at it's meeting on 18 April and the relevant extract from the minutes is set out below:

RESPONSE TO CORNWALL COUNCIL CONSULTATION ON LOCAL PLAN

Following discussion on general points, it was

RESOLVED that -

1. Schedule for Community Infrastructure Levy- proposed expenditure - town council to call for Cornwall Council to further consult with St Ives Town Council on the St Ives provision.

2. Need for a definition of what affordable means, to make sure that it is affordable for residents of St Ives to ensure that it helps ensure homes for local people.

3. Agree in principle the development limits in the Local Plan, pending further detail to be set out in the Local Development Framework.

regards,

Louise

Louise Dowe, Town Clerk St Ives Town Council The Guildhall, Street An Pol, St Ives, Cornwall TR26 2DS

website: www.stivestowncouncil.co.uk or for tourist information, visit: www.stivestic.co.uk For events and What's On at St Ives Guildhall: http://www.stivesguildhall.co.uk

This e-mail and attachments are intended for above named only and may be confidential. If they have come to you in error you must take no action based on them, nor must you copy or show them to anyone; please e-mail us immediately at [email protected].

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representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Sarelle Reid

Organisation

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x

Post Email

Post

Q1. Do you wish to be notified of future stages in the Local Plan including submission, examination and adoption? Yes x No

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If Yes;



Yes No


If Yes;






• Effective

















been complied with.


No x


Because I think the housing targets are inadequate for the reasons detailed below.


No


Q5. Please provide any comments on the Local Plan – Strategic Policies. Please use a separate box for each policy. Document Page number Policy number Cornwall Local Plan –

Strategic Policies 1


Report P 5

Policy 1: Presumption in favour of sustainable development The Sustainability Appraisal Addendum 2014 (p.5) urges that these three pillars ‘must be considered together and not in isolation to avoid overriding weight being given to any one pillar.’ In contrast, the Local Plan (LP) is unbalanced as it

gives overriding weight to the economic pillar - ‘our overall aim is to support economic growth’ (LP, para 1.19).

fails to suggest ways of measuring the social and environmental pillars. does not take the social and environmental pillars into account in its Policy

2,.4 ‘provide for 47,500 homes’ does not accord with the National Planning Policy Framework (NPPF), which

explicitly aims at a balance between sustainability and growth (p.i). Just about every planning application by large developers that I have come across promotes itself as sustainable. But what does this mean in practice: A supermarket and houses around it built around it on a greenfield site on high grade agricultural land? With low-paid jobs offered for people to work in the supermarket – and note the supermarkets seem to be heading in the direction of losing staff with the moves for self-checkout increasing? I believe this approach cannot be described as sustainable because:

• We are losing our valuable agricultural land by allowing developers to build on it – Cornwall has rich soil and an excellent climate for growing – produces vegetables, meat and dairy – this is sustainable – it provides local income in the food industry and jobs. Its value in financial and job terms is likely to increase in a world with increasing population and demand for food.

• Income from this land resource goes on year after year. • The income for developers is through a once-off sale of each of the houses.

In this way it is not sustainable income. • The out of town developments that have gone ahead and are being planned

do great damage to the prosperity of our town centres. I believe that tourism will also be damaged if we turn Cornwall into suburbia by the sea with massive out of town developments and suburbs. For example, Sainsbury’s and the new road system by Mounts Bay. I have yet to meet a local person that sees this as beneficial to the area. It is astonishing that in such an iconic area – right opposite St Michael’s Mount - such a development could go ahead despite local opposition from residents and Penzance Council. With massive insensitive development, Cornwall could well be in danger of losing income from tourism – many businesses and jobs rely on this in Cornwall.


Strategic Policies


Report

Policy 2: Key targets and spatial strategy What we need in Cornwall are affordable homes for local people. Around each village and each town I believe there should be small-scale developments, using brownfield sites wherever possible, in consultation with local people. And why not give the work to local building companies? Instead we have huge up-country developers holding us to ransom to make big money out of Cornwall. The council can be strong enough to take a stand against this and provide a better vision for Cornwall’s future, one that is truly sustainable. One way can be through making a special case for Cornwall as per Sarah Newton’s case re. applying new figures: ‘We are proposing a new approach, based not on past building rates, but on the number of local people who need housing now, and those who will need it over the coming years. This produces a lower figure for new homes for Cornwall over the next twenty years. In Parliament last week I was pleased to speak in support of this new approach, and to secure an assurance for the Planning Minister that it was acceptable, provided it was backed up by robust evidence showing that it would deliver the homes that are needed by many people here and now. New tools and funds are available to support Cornwall Council and partners in meeting this need. Cornwall’s plan needs to give far greater priority to delivering genuinely affordable homes for local people and to preserving our precious farmland, needed today and for many years to come.’ I believe that the figures on which you are basing your strategy are flawed. I object to Policy 2.4 ‘provide for 47,500 homes [sic] over the plan period at an average rate of about 2,300 per year.’ A significant proportion of the additional housing stock in Cornwall ends up with no permanent resident, being used as second homes or holiday lets and not first homes. It is therefore inaccurate to call all these ‘homes’. The 47,500 target should be reduced on the following grounds. 1. Inadequate and faulty datasets

The NPPF states that Plans should be based on ‘proportionate evidence’ (para 182) while evidence should be ‘up to date, robust local evidence’ (para 218)

The Cambridge Centre for Housing and Planning Research states that official household projections should be used ‘unless there is strong, local evidence to the contrary’ (Choice of Assumptions in Forecasting Housing Requirements, p.24)

The evidence used to derive the housing target is neither proportionate nor robust. Indeed, there is strong local evidence that official datasets consistently exaggerate population and household growth in Cornwall. All eight Office for National Statistics (ONS)/Department for Communities and Local Government (DCLG) projections in the 2000s overestimated growth. The five ONS projections overestimated population growth in that decade by between 25% and 69%. The three DCLG projections overestimated household growth by 63% to 106%. This consistent inflation was also indicated in the ONS mid-year estimates throughout the 2000s. Such consistent failure suggests a structural flaw, almost certainly principally the result of overstating net in-migration. The demographic projection which is the basis of Policy 2.4 therefore needs to be revised downwards to between 29,800 and 35,500 to take account of the past performance of these flawed projections. 2. Adverse impacts This is crucial following the Minority Status being applied to Cornwall. To monitor this we would need to know the number of new houses built that are going to local people and the proportion that are not. The developers building these new developments in Cornwall are often marketing them out of county. Even to this extent: Free Newquay flats for London home-buyers www.cornishguardian.co.uk LONDONERS are being offered the chance to buy a home in the capital city and get a 'Surfer's Suite' in Newquay - for free. I believe that Minority Status can be a key way for the Council to present a special case to the government and planning minister to significantly reduce the number of houses built here, and to focus on providing housing for local people. Paragraph 14 of the NPPF states that local planning authorities should meet objectively assessed need (although this is not objective in the Cornish case - see 1 above) unless ‘any adverse impacts of doing so would significantly and demonstrably outweigh the benefits’. The adverse impacts of a housing target that potentially doubles Cornwall’s population and built-up area every 77 years are considerable but have been ignored in this policy. These adverse impacts can for example be traced in the following dimensions. a) Cornishness and Cornwall’s distinctiveness. Policy 2.4

is in breach of the Framework Charter for the Protection of National Minorities. Article 16 states ‘All parties shall refrain from measures which alter the proportions of the population in areas inhabited by persons belonging to national minorities’.

fails to provide an Equality Impact Assessment of the effects of its population growth policies on the Cornish as a distinct group.

does not meet guiding principles b) ‘ensuring a strong, healthy and just society’ and d) ‘promoting good governance’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.

does not meet the social dimension of sustainable development, ‘supporting strong, healthy and vibrant communities’ (NPPF, para 7).

does not meet core planning principles of the NPPF (para 17), namely ‘empowering local people’, ‘conserve heritage assets’ and ‘improve health, social and cultural wellbeing for all’.

contradicts para 50 of the NPPF, to meet ‘needs of different groups in the community’.

contradicts the preamble of Policy 2, ‘respecting the natural and historic character of Cornwall.

contradicts Policy 2.6, ’maintain the special character of Cornwall’. b) Landscape and countryside Current policy of the Council giving the go ahead to build on high grade agricultural land seems in direct opposition to the following listed principles. There is also building taking place on areas key to biodiversity. Cornwall’s economic sustainability is entwined with protecting its land and the diversity of species it supports, whether farmland or wild land. Our vision for Cornwall’s future needs to address this. Tourism and agriculture, and the jobs and businesses in Cornwall that depend on these, flourish when our land is looked after. Tourism will drop off if we concrete over our natural spaces. Agriculture will diminish. We will follow the path the Council is taking we will lose those key resources, and developers will simply pocket the money, thank you very much, and move on. I think there is a very strong economic and environmental case that the Council can make to government and the planning minister to significantly reduce the housing figures. Policy 2.4

does not meet guiding principle a) ‘living within the planet’s environmental limits’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.

does not meet the environmental dimension of sustainable development, ‘contributing to protecting and enhancing our natural, built and historic environment’ (NPPF, para 7).

does not meet core planning principles of the NPPF (para 17), namely ‘enhance and improve the places in which people live their lives’, ‘encourage the effective use of land’ (note also the contrast between the detailed local policies for housing (LP, section 4ff) and the SA, p.48), and ‘open land can perform many functions’.

contradicts the preamble to Policy 1, ‘respecting the distinctive character of Cornwall’s diverse landscapes’

contradicts Policy 2.5b ’protection and enhancement of environmental assets’.

contradicts Policy 2.6, ’maintain the special character of Cornwall’. c) Climate change More housing, more concrete, more roads will lead to more waste, more pollution, more flooding All good reasons to reduce the housing targets for Cornwall. Policy 2.4

contradicts its Green Cornwall Strategy aim of reducing greenhouse gas emissions in Cornwall by 34% by 2020 (Green Cornwall Strategy, p.15)

does not meet guiding principles a) ‘living within the planet’s environmental limits’, c) ‘achieving a sustainable economy’ or e) ‘using sound science

responsibly’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.

does not meet the environmental dimension of sustainable development, ‘contributing to protecting and enhancing our natural, built and historic environment’ (NPPF, para 7). The NPPF specifically encourages local planning authorities to ‘move to a low carbon economy’ (para 7)

does not meet core planning principles of the NPPF (para 17), namely ‘support the transition to a low carbon future’.

contradicts Policy 2.3 ’minimise resource consumption’ d) Biodiversity Cornwall has wonderful biodiversity. The plants, birds, animals and insects that are found in our fields, hedgerows, moors and woodlands are the envy of many. People travel from all over the country and from many different parts of the world to experience this unique place. How can we even consider losing this. Personally I believe our biodiversity is important regardless of its economic importance. To me and many others living here, we believe we are amazingly lucky to be living in such extraordinarily beautiful place and that biodiversity as a principle is important for its own sake, and the future of our planet and the survival of future generations. Cornwall is one of the few counties in England that offer such levels of biodiversity so it is crucial that we nurture and retain these. Policy 2.4

does not meet guiding principle a) ‘living within the planet’s environmental limits’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.

does not meet the environmental dimension of sustainable development, ‘contributing to protecting and enhancing our natural, built and historic environment’ (NPPF, para 7). The NPPF specifically encourages local planning authorities to ‘improve biodiversity’ (para 7).

does not meet core planning principles of the NPPF (para 17), namely ‘conserving and enhancing the natural environment and reducing pollution’.

does not meet para 118 of the NPPF, refusing development that will lead to a ‘loss or deterioration of irreplaceable habitats’.

I think that Cornwall’s new Minority Status offers a wonderful opportunity to offer a better vision for the future of Cornwall than the current one that is on offer – one that rolls over to government demands and developers bullying. Please take this opportunity to present a better vision of our future by reducing the housing figures, taking care of local housing need in consultation with local people, and looking after our valuable land and biodiversity.











Signature Sarelle Reid Date 26 April 2014
















representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Sue Blaxley

Organisation St Neot Neighbourhood Plan Steering Group

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x

Post Email

Post


No

6162

Typewritten Text

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Yes No x

If Yes;




Yes No


Yes No

If Yes;





• Justified

• Effective

















been complied with.


No x


See policy comments

Q4. Do you consider that the Local Planeets the legal and procedural requirements? Yes x

No




Strategic Policies 30, 31, 32 15 and 17


Report

We are very concerned that Cornwall Council wishes to explore the issue of noise in relation to wind turbines and its effect on people but is

prepared to go ahead with larger turbines in our area in the absence of

this research . Annex 1(Landscape Sensitivity and Strategy Matrices for

each Landscape), CA21, Fowey Valley suggest turbines of a medium size

(61m – 99m) may be permitted in the middle section of this LCA. We

already have parishioners concerned about the noise from the smaller turbines in our area. We think that the Council should wait for the results

of exploring the noise nuisance in connection with medium sized turbines

before allowing more. The policy, as it currently reads, does not meet the

soundness criteria of evidence based decision making.

Reference is made on page 31 to not allowing wind turbines in AONB’s

and adjacent areas except in exceptional circumstances and that this

would also apply to buffer zones around such areas (page 48 refers).

Clear definitions of “adjacent areas” and “buffer zones “ are needed within

the policy framework. Document Page number Policy number Cornwall Local Plan –

Strategic Policies Part 1 23


Report

We notice that many large developments in rural areas, particularly

agricultural buildings, often lack soft landscaping to mitigate their impact

on the landscape, habitats and biodiversity that policy 23, part 1, seeks to

protect. Such soft landscaping is also a useful carbon sink.

Cornwall Local Plan Policy Number 26, 2(a) We are concerned at the proposed increase in housing at Looe. Given the

flood problems, impermeable surfaces associated with another 642 houses

are surely likely to compromise ecosystem services in relation to flooding

unless these could be built with maximum attention to green

infrastructure. It might be more appropriate to consider increasing the

housing at Liskeard instead given that land is available for up to 3,500 houses and the infrastructure, especially transport, is more developed and

the flood risk much lower.





x

If you wish to be notified of the Submission of the Local Plan – Strategic Policies please tick the box x

If you wish to be notified of the publication of the recommendations of the independent examination (Inspector’s Report) please tick the boxx

If you wish to be notified of the adoption of the Local Plan – Strategic Policies please tick the box x

Signature S Blaxley Date 27/04/14



224283.





database and will be used to keep you informed of progress with the Local Plan and in order to consult with you further at each stage of the process



planning inspector (from the Planning Inspectorate), who may wish to contact you to discuss your comments and concerns, prior to formal


From: Hilda DentSent: 27 April 2014 10:46To: EP&E Local PlanSubject: Fwd: Cornwall Local Plan. My personal appraisal.

Page 1 of 2

29/04/2014

PERSONAL VIEWPOINT....... ( with the reservation that I could have imagined that incineration produces unhealthy fall out of undesirable toxins and Carbon Dioxide ) Please understand this is a personal comment, simply as I ,see Cornwall Council's weakness in understanding ,.....that each contributing float of toxic emissions to an already overloaded atmosphere , to an ever weakening adult work force, to a toxic abuse of the foetus and growing child and to a top heavy list of chronic ailments and BROUGHT. FORWARD DEATH RATE School of Thought alongside a floundering hospital , GP service , residential and home care service,....... does point the finger of suspicion to authorities that create the fouling of our air. Sent from my iPad Begin forwarded message:

From: Hilda Dent Date: 27 April 2014 02:52:41 GMT+01:00 To: "[email protected]" <[email protected]> Subject: Cornwall Local Plan The service given by the collecting body is very well undertaken. Being disabled and elderly, it is a blessing to have both recycling and not recycled items collected from my door. The service given by the Transport and Waste PAC is not well undertaken. 1 ) .......Here, I refer to the absence of a collection of food waste to send to anaerobic digestion to retrieve energy that Cornwall residents could benefit from. 2 ).......Also the fact that insufficient variety of items are collected for recycling. 3 ).......Also the fact the Cornwall Council intend to process ,much of what could be recycled ,and anaerobically digested, to combustion gases and poisons and toss them up a chimney stack to fall willy-nilly back down upon us, our land and water, some falling , others blowing about in the atmosphere for centuries , all around the world, fouling generations to come with contaminated air, land and water, while also affecting both the troposphere and stratosphere , the Jet Stream and the ocean currents. All this , in contravention to the EU regulations on waste. Fly and bottom ash being further contaminants. 4 ) ..... Since we breathe air, since we drink and bathe in water, since we eat food laced with emissions fall out from the atmosphere , just how is our health to be affected. ? Cornwall's Statisticians blithely reckoning brought forward mortality rates, .......deaths ,due to decisions on waste treatment , just as blithely undertaken by Cornwall Transport and Waste PAC., while the hospitals and health services struggle

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to keep up with the illnesses. Cornwall has nothing to celebrate, in achieving Minority Status. Hilda Dent, resident and house owner,

Sent from my iPad

Page 2 of 2

29/04/2014



representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Patricia Francis

Organisation

Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number

Email address


Email x

Post Email

Post


No

6162

Typewritten Text

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If Yes;



Yes No


If Yes;






• Effective

















been complied with.


No x


I am concerned about the public awareness of this consultation. I only recently became

aware of it. There will be many people in the area who have views abut were unable to express it as thy were unaware of it. It was not week publicised


No x


See above



Strategic Policies 31 14, 15 & 16


Report

2.62 states “..the opportunities for renewables in the form of wind and solar are not unlimited” This statement is not reflected in Policies 15 or 16 where there is no reference to the limitation of installations, just what factors need to be taken into account Document Page number Policy number Cornwall Local Plan –



Report

There should be a moratorium on the building of more wind turbines until

the consultation referred to in 2.58 is completed.





x



If you wish to be notified of the adoption of the Local Plan – Strategic Policies please tick the box x

Signature Patricia Francis Date 27/4/14



224283.











representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Dale Francis

Organisation

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6162

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748












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• Justified

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been complied with.


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Please specify the reasons below As recognised in the document (1.8) Cornwall has some of the most

disadvantaged people in the UK. As they do not necessarily have access

to the internet or other media, it is impossible for these people to

express their views on the Plan

Q5. Please provide any comments on the Local Plan – Strategic Policies. Please use a separate box for each policy. Document Page number Policy number Cornwall Local Plan –



Report

Add “…to meet the following minimum distances: If the height of the wind turbine is— (a) greater than 25m, but does not exceed 50m, the minimum distance requirement is 1000m; (b) greater than 50m, but does not exceed 100m, the minimum distance requirement is 1500m; (c) greater than 100m, but does not exceed 150m, the minimum distance requirement is 2000m; This is to meet the proposals in the Wind Turbines (Minimum Distances from Residential Premises) Bill Document Page number Policy number Cornwall Local Plan –



Report

I believe there should be a moratorium on all future wind turbine developments until the Council has carried out a comprehensive study into

the long term effects of turbines on residents in close proximity to

turbines. In 2.58 the Council says it will explore more widely the impact

of noise, this should be completed before more turbines are built.









Signature Dale Francis Date 27/4/14



224283.








planning inspector (from the Planning Inspectorate), who may wish to contact you to discuss your comments and concerns, prior to formal




representation form



Carrick House

St Clement Street

Truro TR1 1EB














Name Patrick Aubrey-Fletcher

Organisation National Farmers Union

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Strategic Policies Page 18 Policy 5 Jobs and Skills


Report

Whilst welcoming the statement made:

Employment proposals should be located either: subsection d “in the

countryside and smaller rural settlements where it is of a

scale appropriate to its location or where the use can show an

overriding business need for its location”

The NFU feel that greater empahsis should be made about the need to permit planning where employment is being created or protected on-farm

or within the rural economy. The Agri-food sector makes a significant

contribution towards the employment of Cornwall’s residents and the

policy as worded does not reflect this.

“


Strategic Policies Page 32 Policy 17 Health and

wellbeing


Report

Paragraph 2 refers to “2. Maximise the opportunity for physical activity

through the use of open space indoor and outdoor sports and leisure facilities and travel networks supporting walking, riding

and cycling”

We feel that reference needs to be made to managed public within the

countryside and suggest that this paragraph is amended to read

2. Maximise the opportunity for physical activity through the use of

open space indoor and outdoor sports and leisure facilities and managed

travel networks supporting walking, riding and cycling in the countryside.

Cornwall Local Plan Page 39 Policy 22 Best Use of Land

Sub section e To ensure the best use of land development proposals

should give priority to: the safeguarding of land to make space for water at times of flood.

No account appears to have been taken to protect the occupier of

farmland which it is proposed to flood. Most land is utilised for 12 months

of the year and unless it is already managed with flooding in mind “the flood plain” this policy will will reduce agricultural output at a time when

farmers are being asked to produce more food at more competitive prices.

The NFU would therefore like to see the following added at the end of sub

section e “ whilst taking into account the need to protect farmland from

prolonged flooding.

Cornwall Local Plan Page 41 Policy 23 Natural Environment

No mention is made of agriculture within this policy and yet is has been the farmers and land managers who have created much of the Cornish

Landscape as we see it today.

The NFU would therefore like to see the following statement to be included

within Section 1 The Cornish Landscape

“ without restricting development which would ensure agricultural

production is improved in efficiency and productivity”

Cornwall Local Plan Page 44 Flood Risk Management

Section 2 of this policy reads “2. Development should be sited, designed,

of a type and where necessary relocated in a manner

that: followed by a number of sub sections none of which make

reference to prolonged flooding of agricultural land.

The NFU would like to see a further sub section added as follows:

“ does not put agricultural land at risk from prolonged flooding”





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Signature Patrick Aubrey-Fletcher Date 27/04/2014














Documents

Local Plan – Strategic Policies · Last year we consulted on a draft Local Plan under the same regulations. In January 2014 the Council agreed a number of changes to that draft