CornwallLocal Plan StrategicPolicies Proposed … · 2019. 1. 22. · Cornwall Local Plan Proposed Submission Document – consultation response The Tregothnan Estate. 1.0. Introductionto

Cornwall Local Plan Strategic Policies – Proposed Submission Document 2010 – 2030

Response made on behalf of The Tregothnan Estate

April 2014

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Representations 588 - 599

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Cornwall Local Plan Proposed Submission Document – consultation response The Tregothnan Estate

Contents

Page No

1.0 Introduction to the consultation response ..................................................... 1

2.0 Local Plan preparation – tests of soundness................................................... 1

3.0 Policy 1 – Presumption in favour of sustainable development ........................ 2

4.0 Policy 2 – Key targets and spatial strategy..................................................... 2

5.0 Policy 3 – Role and function of places ............................................................ 4

6.0 Policy 5 – Jobs and skills ................................................................................ 6

7.0 Policy 6 – Housing mix ................................................................................... 7

8.0 Policy 7 – Housing in the countryside............................................................. 7

9.0 Policy 8 – Affordable housing ......................................................................... 8

10.0 Policy 9 – Affordable housing led schemes ..................................................... 8

11.0 Policy 14 – Development standards................................................................ 9

12.0 Policy 24 – Historic environment .................................................................. 10

13.0 Policy 28 – Infrastructure ............................................................................ 10

14.0 Policy PP1 – West Penwith CNA.................................................................... 11

15.0 Policy PP3 – Helston and the Lizard CNA ...................................................... 13

16.0 Policy PP6 – Truro and Roseland CNA........................................................... 13

17.0 Policy PP9 – St Austell and Mevagissey; China Clay; St Blazey, ....................... Fowey and Lostwithiel CNA .......................................................................... 15

18.0 Attendance at Examination........................................................................... 15

Appendix A Completed representation form

Steve Briggs BSc DipTP DipDBE MRTPI Partner


1.0 Introduction to the consultation response

1.1 This consultation response has been prepared by Smiths Gore on behalf of the Tregothnan Estate. The submission has been prepared following an invitation from the Council to comment on its Local Plan Proposed Submission Document.

1.2 As a significant owner of land and property in Cornwall the Tregothnan Estate is keen to ensure that the policies within the emerging Local Plan are responsive to local circumstances and support, rather than constrain, the development that Cornwall’s urban and rural communities and businesses require to meet their social and economic needs.

1.3 The form of this response follows the advice given by Cornwall Council in that comments have been made on the representation forms provided. However as these forms do not allow for an adequate level of detail to be provided, the main body of the submission is included within this written report. Therefore the comments submitted in the forms and in this written submission should be read together to appreciate the full response to this consultation. The full written response has been submitted both electronically and as a hard copy to Cornwall Council.

1.4 This written report makes detailed comments on particular sections of the consultation document, clearly identifying whether policies are considered to be ‘sound’ or ‘unsound‘ and why. Where policies are deemed to be unsound recommendations will be provided regarding how they should be amended in order to make them sound. The sections to which the comments relate are clearly identified by each subheading.

2.0 Local Plan preparation – tests of soundness

2.1 Local Plans at the presubmission stage should accord with certain tests which are outlined within the National Planning Policy Framework (the Framework). The tests are in place to allow a planning Inspector to assess whether a plan is ‘sound’. A sound plan is described at paragraph 182 of the Framework as being:

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on crossboundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2.2 This consultation response has been prepared with these tests in mind and considers the policies contained within the Cornwall Council Local Plan Proposed Submission Document against each of them. It also tests them against the other relevant policies within the Framework in order to ensure it is consistent with national policy.


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3.0 Policy 1 – Presumption in favour of sustainable development

UNSOUND – This policy does not accord with paragraph 14 of the Framework which sets out the Government’s presumption in favour of sustainable development.

3.1 The Tregothnan Estate has concerns over the reference in the last paragraph of the policy, which is permissive of applications where “there are no policies relevant to the application at the time of making the decision”. This statement does not accord with the Framework, which clarifies that permission will be granted where the development plan is “absent, silent or relevant policies are outofdate...” The wording should be revised to be more specific, to give a clearer indication of the scope of the intended policy.

3.2 The Tregothnan Estate does however welcome the Council’s commitment to “work with applicants, infrastructure providers and the local community to find solutions which mean that proposals will be approved wherever possible…” This approach will lead to enhanced levels of confidence among all stakeholders in the planning system, which will in turn help to facilitate the delivery of developments over the plan period that meet the social, economic and environmental needs of Cornwall’s communities and businesses.

3.3 It is also pleasing to see that in considering if a development proposal is sustainable or not, account will be taken of “its location, layout, design and use against the three pillars of economic development, social development and environmental protection and improvement” as the Framework recognises that the achievement of sustainable development through the planning system should be sought jointly and simultaneously through economic, social and environmental gains.

4.0 Policy 2 – Key targets and spatial strategy

UNSOUND – The housing target proposed for the county does not seek to meet objectively assessed needs. It is therefore not positively prepared, is unjustified and inconsistent with national policy.

4.1 Paragraph 14 of the Framework sets out the Government’s presumption in favour of sustainable development. This specifically states that “local planning authorities should use their evidence base to meet the full, objectively assessed needs for market and affordable housing…” Unless the Inspector is satisfied that the Local Plan achieves this it will undoubtedly be deemed to be unsound and will not be able to proceed to adoption.

4.2 It is clear from our previous submissions on behalf of the Tregothnan Estate that there has been a great deal of uncertainty over the level at which Cornwall’s housing target should be set, and the debate at Cornwall Council’s committee meetings over the last six months has considered various housing targets.

4.3 In the Core Strategy Preferred Options document, published in January 2012 for consultation, a target was set for the delivery of 48,000 new homes between 2010 2030. In the Local Plan PreSubmission document the target was lowered to 42,250 new homes over the plan period. The Proposed Submission Document then increases the housing target slightly to 47,500, which equates to an average of 2,300 homes per year over the plan period.

4.4 The Strategic Housing Market Needs Assessment (SHMNA) published in July 2013 identifies a need for between 47,278 71,980 houses over the plan period. The SHMNA also states that the lower range target is based on the Rebased SNPP (Subnational


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Population Projection) 2010 scenario and should be considered to represent a minimum for understanding the housing pressures likely to result from the growth in households.

4.5 The Proposed Submission Document housing target of 47,500 only meets the minimum growth range, and does not take into consideration growth anticipated through other forecasts which are identified in the SHMNA. The SHMNA uses two other forecast scenarios to predict the housing target by assessing the economic forecast positions for Cornwall. These employmentled scenarios show higher levels of growth, which have been completely disregarded in the consideration of setting the housing target.

4.6 Our previous submission on behalf of the Tregothnan Estate referred to the ‘Household Interim Projections 2011 2021, England’, published by the Department for

9th Communities and Local Government on April 2013. Using a robust methodology based on trends observed in Census (including the 2011 Census) and Labour Force Survey data, this document projects the increase in population and household growth over the period between 2011 2021.

4.7 In this document Cornwall is projected to experience a growth in households of between 1% and 1.25% per year; one of the most significant rates of household growth in the country. The table below uses this projection to illustrate the likely rate of growth in households in Cornwall over the plan period. We acknowledge that this projection can not be entirely relied upon, as it assumes that the growth rate will continue unaltered after 2021. It also covers the period between 2011 – 2031 rather than 2010 2030. Regardless it still provides a useful indication of the likely level of household growth over the coming 20 year period, based on projections produced from national government. It is rather striking how significant the gap is between these projections and the target of 47,500 set by the Council.

Annual Household growth (1%)

Annual Household growth (1.25%)

Current level* 230,400 230,400 Year 1 232,704 233,280 Year 2 235,031.04 236,196 Year 3 237,381.35 239,148.45 Year 4 239,755.16 242,137.80 Year 5 242,152.71 245,164.52 Year 6 244,574.23 248,229.07 Year 7 247,019.97 251,331.93 Year 8 249,490.16 254,473.57 Year 9 251,985.06 257,654.48 Year 10 254,504.91 260,875.16 Year 11 257,049.95 264,136.09 Year 12 259,620.44 267,437.79 Year 13 262,216.64 270,780.76 Year 14 264,838.80 274,165.51 Year 15 267,487.18 277,592.57 Year 16 270,162.05 281,062.47 Year 17 272,863.67 284,575.75 Year 18 275,592.30 288,132.94 Year 19 278,348.22 291,734.60 Year 20 281,131.70 295,381.28 Total change** + 50,732 + 64,982

*The starting number of households is based on the number provided within the Cornwall Council publication ‘2011 Census at a glance (First Release) July 2012. **Rounded up to nearest whole number.


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4.8 The Local Plan must aim to meet the full, objectively assessed needs for market and affordable housing. At Examination all evidence used by the Council in determining the proposed housing target will be rigorously assessed and tested. If this evidence is found not to be sufficiently robust the plan will be found unsound and will delay its adoption, leaving the Council vulnerable to ‘planning by appeal’. It is important to note that the vast majority of Local Plans rejected at examination are due to the fact that their housing targets were too low and did not meet the projected growth in households, i.e. the full, objectively assessed needs. This point is emphasised by the recent example of the examination of East Devon District Council’s Local Plan, which was found to be unsound as the housing target was considered to be unjustified. Furthermore the Inspector specifically referred to the validity of choosing low migration models when other supporting documents lean towards higher figures.

4.6 As it stands the housing target set out in policy 2 is considered to be a long way short of addressing the needs of Cornwall and we would encourage the Council to revisit this issue and to increase its housing numbers accordingly.

5.0 Policy 3 – Role and function of places

UNSOUND – This strategy is too restrictive to deliver the required level of housing outside of the main settlements. This approach is considered to be unjustified and ineffective. The policy also fails to acknowledge the relationships that exist between smaller rural settlements.

5.1 The Tregothnan Estate has concerns regarding the mechanisms proposed to facilitate the delivery of development over the plan period, specifically outside of the main settlements. Most notably these concerns relate to an over reliance on Neighbourhood Plans, affordable housing led schemes and infill development to deliver rural development over the plan period.

5.2 Since the Localism Act received royal ascent, no Neighbourhood Plans for any areas in Cornwall have been submitted for Examination. While there has been a great deal of interest among local communities for preparing Neighbourhood Plans in Cornwall and indeed nationally, the reality is that the process requires significant resources of time, commitment and funding to see it through. This type of approach cannot therefore be relied upon to deliver much needed development in the county’s smaller communities in the early years of the plan period. This situation will be further exacerbated if a policy of restraint is imposed upon settlements while Neighbourhood Plans are being prepared.

5.3 Similarly it is not considered effective to rely on affordable housing led schemes to bring forward the required level of housing outside of the main settlements. The revised wording in Policy 3 refers to exception schemes which will allow an element of market housing to provide cross subsidy. While the Tregothnan Estate appreciates, and is fully supportive of the need for affordable housing outside of the main settlements, to ensure that local needs are met, Policy 3 should not rely so heavily upon exception schemes.

5.4 A significant proportion of growth is rightly proposed to take place outside of the county’s main settlements and so if development in these areas does not come forward as anticipated it is likely that the Council will fail to achieve the targets set out in policy 2. At a time when Cornwall is already unable to demonstrate a deliverable five year supply of housing land this type of approach will do little to generate confidence among landowners and developers who, with greater levels of certainty, would be better placed to come forward with sustainable development proposals. The consequence of this is


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that the Council’s strategy will be undermined and the county will continue to suffer from a shortfall in its five year supply. The authority will then be in a weak position to resist developments which are contrary to local housing policies, on sites which it might otherwise look to resist. This is because local policies relating to the supply of housing cannot be considered up to date if the local planning authority is unable to demonstrate a five year supply of deliverable housing sites (see paragraph 49 of the Framework).

5.5 To ensure the delivery of sufficient levels of housing outside of the main settlements the Tregothnan Estate would like to encourage the local planning authority to identify strategic sites (of an appropriate scale) within, and adjacent to, a range of smaller settlements and to allocate these within the proposed Site Allocations DPD. This is a tried and tested process for allocating sites which ensures a far greater certainty of outcomes. Furthermore this process also allows for meaningful involvement and engagement with local communities to take place through effective techniques such as workshops, exhibitions etc.

5.6 Functional relationships between smaller settlements

When planning for the future development of urban and rural settlements across the county, the Council needs to develop a detailed understanding of their role and function. For rural settlements the Council should make specific reference to the ways in which smaller rural communities interact with each other and how the functional relationships that exist between them influences the travel patterns of people in rural communities. These relationships should form an important consideration when planning for the future development needs of rural communities. This is the approach advocated in paragraph 55 of the Framework which states that “where there are groups of smaller settlements, development in one village may support services in a village nearby”.

5.7 All too often local planning documents take the overly simplistic view that a settlement should have access to ‘x’ number of facilities and services in order to be deemed a sustainable location for development. This simplistic approach is considered to be flawed as it fails to recognise the complex inter relationships that exist between settlements which should be considered together in a holistic way. A small settlement may have limited access to services and facilities when considered in isolation but may actually demonstrate more sustainable patterns of living and working when you take account of its shared functional relationship with surrounding settlements. For example one settlement may have a primary school, another might contain employment units, whilst a third may be the centre of social life with a community hall and active local clubs and societies. Any or all may be appropriate locations for modest housing and economic development on the basis that all combine to provide a sustainable community life.

5.8 Recent advice contained within the National Planning Policy Guidance recognises that rural housing is essential to ensure the viable use of local facilities as a thriving rural community in a living, working countryside depends, in part, on retaining local services and community facilities. The guidance also recognises that all settlements can play a role in delivering sustainable development in rural areas, and that blanket policies restricting housing development in rural settlements should be avoided. This clear Governmental policy position clarifies that the approach advocated by the Council in Policy 3 of the Proposed Submission document is not consistent with national policy, in respect of the housing strategy.


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6.0 Policy 5 – Jobs and skills

UNSOUND – The policy should specifically identify livework units as a form of development to be supported. To not do so is contrary to national planning policy.

6.1 The Tregothnan Estate is disappointed to see that Cornwall Council has not provided specific support for livework units within policy 5. This was highlighted in both our previous responses to the Core Strategy Preferred Options document and the PreSubmission document, as a sustainable form of development which should be encouraged by Cornwall Council.

6.2 Fuelled by the impact of new technology (such as improved internet access in rural areas), a growing frustration with the stress and time wasting associated with the daily commute and a desire for a better work/life balance, self employed people in rural areas are increasingly choosing to opt for homeworking. In fact this is now a wellestablished trend with livework units being delivered through both new build and conversion schemes. Both should be supported in local planning policies.

6.3 This type of development is specifically supported within paragraph 21 of the Framework which states that local planning authorities should “facilitate flexible working practices such as the integration of residential and commercial space within the same unit”. The Council is therefore strongly urged to support this form of development within policy 5 of the Local Plan; an approach which is being taken up by many other local authorities in the south west and nationally.

6.4 Across the Cornwall countryside there is a significant supply of buildings, traditional and more modern, which are well suited to providing this type of livework arrangement. The conversion of rural buildings to establish a livework arrangement offers a wide range of benefits, not only to individuals and their businesses, but also to the wider economy and environment as well.

6.5 In May 2013 the Trade Union Congress (TUC) published an analysis of the number of people working from home in the UK. This analysis found that the number of people working from home has increased by 13% in the last five years. Just over four million employees usually worked at home in 2012, a rise of 470,000 since 2007. The Office of National Statistics (ONS) also reported an increase in the level of home working, based on 2011 census data, and attributes this increase to a greater prominence of home businesses in rural areas. Furthermore, the Annual Population Survey 2010/2011 carried out by the ONS identified working from home as being more common in rural areas of England than in urban areas.

6.6 Over recent years the principle of livework units within the countryside has become more acceptable as a means of promoting the sustainable reuse of existing buildings. Such schemes are inherently sustainable as they help to meet local demand for housing (socially sustainable) and they provide local employment opportunities (economically sustainable). They also serve to reduce the need to travel by car by removing the need for a daily commute and also safeguarding the character and appearance of rural buildings which might otherwise fall into disrepair (environmentally sustainable).


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7.0 Policy 6 – Housing mix

SOUND – This policy accords with paragraph 50 of the Framework which sets out the objective of delivering a wide choice of high quality homes

7.1 The Tregothnan Estate is pleased to see that our recommended changes from the PreSubmission document consultation have been incorporated within Policy 6. The delivery of a wide choice of high quality homes will create sustainable, inclusive and mixed communities, which reflects local demand.

8.0 Policy 7 Housing in the countryside

UNSOUND – The policy should specifically support livework developments. To not do so is contrary to national policy.

8.1 The Tregothnan Estate is largely supportive of the approach advocated within policy 7, which sets out the circumstances whereby housing development in the countryside will be supported. The Estate is particularly pleased to see that Cornwall Council has responded to the comments made within our previous submission and to changes in guidance from national government by specifically supporting residential conversion schemes. This is an approach which has not historically been taken within local planning policies but it is pleasing to see that the Council is responding to the recent changes in national planning policy brought about by the publication of the Framework.

8.2 It is however disappointing to see that despite our comments made in relation to the PreSubmission document, policy 7 does not provide support for the development of livework units in the countryside. In fact we are surprised to see that this is the case considering that draft policy C of the Core Strategy Preferred Options document (relating to housing) actually did support this form of development.

8.3 A strong planning case in support of livework developments has already been provided in our response to draft policy 5 and so will not be reiterated in full here. It is however important to point out that livework units are identified as a form of development which should be supported within the Framework. Paragraph 21 of the Framework explains that local planning authorities should “facilitate flexible working practices such as the integration of residential and commercial space within the same unit”.

8.4 In order to conform to national policy it is strongly recommended that Cornwall Council provides specific support for livework developments, both within urban areas and the countryside. This should be the case for both new build developments and conversion schemes. This support could be provided within policy 3 – Role and Function of Places, policy 5 – Jobs and Skills or policy 7 – Housing in the Countryside.

9.0 Policy 8 – Affordable housing

UNSOUND – This policy does not seek to satisfy local need/demand for selfbuild homes. This is contrary to national planning policy.

9.1 The principal area of concern regarding this policy is that there does not seem to be any mention of ‘selfbuild homes’ within the mix of affordable housing products. This is considered to be an oversight particularly as selfbuild housing is identified on the Cornwall Council website as a form of affordable housing. Furthermore the recently published National Planning Policy Guidance under the section ‘Housing and economic


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development needs assessments (paragraph 21), promotes enabling people to build their own home. The guidance refers to strong industry evidence of significant demand for such housing, and local planning authorities should plan to meet the strong latent demand.

9.2 It is strongly recommended that policy 8 is amended to include reference to selfbuild housing as a product which will be considered as part of the overall mix of affordable housing provision on development sites.

9.3 In April 2014 there were over 28,000 households on the affordable housing register in Cornwall and this number is growing week by week. Since 2007 there have been over 700 affordable houses per year completed in Cornwall. In 2013 the Council and its partners approved an ambitious housing target to deliver 1,000 affordable homes each year over the next four years. To achieve this target it is essential that policy 8, along with all other policies which influence affordable housing development are appropriately worded in order to facilitate this level of delivery.

9.4 In light of the desperate need within the county the Estate is supportive of the proposed requirement for all new housing schemes comprising two or more dwellings to provide a contribution to this issue, either directly through the provision of affordable homes or through financial contributions to facilitate delivery elsewhere. This approach is clearly appropriate in Cornwall where the vast majority of housing proposals are relatively small scale. It is also encouraging to see that the Council has acknowledged the important issue of development viability within the wording of the policy and that there will be a willingness to negotiate on the mix of affordable housing products where necessary. In order to ensure that housing developments are deliverable over the coming years it will be important for the local planning authority to take a flexible approach which takes account of the financial viability of individual developments. This approach is supported in paragraph 54 of the Framework which calls on local planning authorities to “consider whether allowing some market housing would facilitate the provision of additional affordable housing to meet local needs”.

9.5 The policy also provides broad guidance on what the likely affordable housing requirements are likely to be in particular areas of the county. It is understood that this has been determined on the basis of ‘house price areas’, which will clearly be a significant determinant of overall viability. This type of approach is useful as it provides landowners and developers with a greater sense of certainty regarding the likely costs of development. It will however be important for the Council to regularly update this assessment of house price areas in order to ensure that it remains accurate over the entirety of the plan period. The Tregothnan Estate recommends that a commitment to carry out this work is provided within the supporting text to policy 8.

10.0 Policy 9 – Affordable housing led schemes

UNSOUND – This policy is not sufficiently flexible to respond to issues of development viability. It is therefore contrary to national policy and could threaten the deliverability of the Local Plan’s development strategy.

10.1 Although the Tregothnan Estate is generally supportive of policy 9, which seeks to ensure the delivery of much needed affordable homes in rural settlements, it is considered that the wording of the policy will prevent it from achieving this aim.

10.2 The policy sets out various criteria, all of which must be satisfied in order to allow the inclusion of open market housing within an ‘affordable housing led scheme’. The Estate is particularly concerned about criterion iii) which states that proposals seeking a


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proportion of open market housing must have the support of the local community – either from the parish council, or through a local referendum.

10.3 It is very common for parish councils and local communities to oppose new development, particularly in rural areas. While it is entirely appropriate for these parties to be consulted for such applications it is the responsibility of the local planning authority to determine whether or not to grant planning permission. In its current form this policy effectively gives local communities the power to veto any new development proposals which require an element of open market housing in order to be viable. This will make it very difficult for any such developments to obtain planning permission and will prevent the development of much needed affordable and open market housing, particularly in rural settlements.

10.4 Paragraph 54 of the Framework requires local planning authorities to consider whether allowing some market housing would facilitate the provision of significant affordable housing to meet local needs. In this paragraph the Framework places the onus on local planning authorities to make an informed judgement on this issue, based on an understanding of the financial viability of developments. It is inappropriate for the Council to expect parish councils or local residents to take a view on such a technical issue.

11.0 Policy 14 – Development standards


11.1 Policy 14 sets out a number of measures to ensure that a high standard of development is reached within all developments over the coming plan period. This is an approach which is welcomed by the Tregothnan Estate however there is a concern that, at present, there is no acknowledgement of how these requirements will impact upon development viability.

11.2 To reiterate comments made previously on behalf of the Tregothnan Estate, our concern relates specifically to point 6, which sets the requirement for all new domestic and non domestic development to be “at least zero carbon” by 2016 and 2019 respectively. While the Estate does not contest that this is a target which should be aspired to wherever possible the policy must recognise that, in certain circumstances, achieving that standard may render some development schemes unviable.

11.3 The Framework, in paragraph 173, places a great deal of emphasis on the need for local planning authorities to pay careful attention to viability and costs in plan making and decision taking in order to ensure that Local Plans are deliverable. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. Paragraph 174 then goes on to explain that the cumulative impacts of these standards and policies should not put implementation of the plan at serious risk and should facilitate development throughout the economic cycle. It is important the local planning authority takes this guidance into account in preparing the Local Plan as consideration of overall viability is part of the evidence base which will be subjected to test, challenge and debate when it is eventually examined. Demonstrably failing to consider this issue will almost certainly result in the Local Plan


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being found to be unsound. While this issue has been considered in relation to affordable housing this does not seem to be the case in this instance.

11.4 Although developers vary in their approach to profit and risk, the key point is that a development which is not viable will not be delivered. This can mean that housing targets will not be met and delivery over the plan period will fall behind and fall short. In such cases, developers will await better market or financial conditions and put their resources into developing more profitable schemes elsewhere instead.

11.5 Echoing the Framework, paragraph 16 of Viability under the National Planning Policy Guidance states where the deliverability of the development may be compromised by the scale of planning obligations and other costs, a viability assessment may be necessary. The Guidance recognises viability should be informed by the particular circumstances of the site and the proposed development in question. For a site to be viable the value generated by its development must exceed the costs of developing it, and it must provide a sufficient incentive for the land to come forward and the development to be undertaken.

12.0 Policy 24 – Historic environment

UNSOUND – This policy does not properly reflect national guidance as set out in the Framework

12.1 Paragraph 132 of the Framework explains that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation”. It then goes on to state that “the more important the asset, the greater the weight should be”. In this paragraph the Government is saying that there are varying degrees of significance when considering heritage assets and that some assets are more important than others.

12.2 The Framework also differentiates between the degrees of harm that might be caused to heritage assets and the way such harm should be considered. For example where a development proposal would result in the ‘total loss’ of a heritage asset, it explains that permission should be refused unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that loss. Where a development would result in ‘less than substantial harm’ to the significance of a heritage asset, this harm will need to be weighed against the public benefits of the proposal, including securing its optimum viable use.

12.3 To reiterate our previous comments made on behalf of the Tregothnan Estate on the PreSubmission document, it is considered in its current state policy 24 does not adequately reflect national policy as it does not differentiate between degrees of significance of heritage assets or indeed the levels of harm to those assets which might be caused by development proposals. It is therefore strongly recommended that the Council looks again at this policy to bring it in to line with national policy.

13.0 Policy 28 Infrastructure

UNSOUND – The policy is not sufficiently flexible to take account of issues surrounding financial viability. It is therefore contrary to national policy.

13.1 New developments can, individually or cumulatively, result in increased pressure on existing infrastructure. The Tregothnan Estate therefore acknowledges that there may

Steve Briggs BSc DipTP DipDBE MRTPI 10 Partner


be a need to secure financial contributions from applicants in certain circumstances in order to make such developments acceptable in planning policy terms.

13.2 When considering the appropriate level of contributions to be derived from a particular development it is important that the local planning authority has a detailed, up to date, evidence base which outlines the infrastructure requirements for the area. In this regard section 1 of policy 28 explains that the Council will “continue to work in partnership with infrastructure providers and other delivery agencies to keep an up to date infrastructure delivery plan”. This is welcomed as it will provide developers with an indication of what is likely to be required and provides useful information on infrastructure constraints which might impact upon certain developments. This will provide landowners and developers with a greater sense of certainty.

13.3 It is however important that the local planning authority carefully considers the value to be gained from imposing such requirements upon developments. When considering the level of infrastructure provision to be required it is essential to weigh the desirability of funding infrastructure against the potential effects of that imposition upon the economic viability of new developments. These decisions should therefore be based on detailed evidence about the likely effects on financial viability. If an appropriate balance can not be achieved there is a real risk that much of the development that Cornwall needs over the coming plan period will be unviable and consequently undeliverable. If this is the case then it is likely that the Local Plan will be found unsound when it goes through the examination process.

13.4 The Tregothnan Estate would also like to see some flexibility built in to the wording of the policy which allows for negotiations to take place regarding infrastructure requirements where appropriate.

14.0 Policy PP1 – West Penwith CNA

UNSOUND The housing target proposed for the CNA does not seek to meet the full, objectively assessed needs of the CNA. It is therefore not positively prepared, is unjustified and inconsistent with national policy.

14.1 When responding to the Core Strategy Preferred Options document and the PreSubmission document the Tregothnan Estate highlighted concerns regarding the fact that an insufficient proportion of the proposed housing growth for West Penwith is being directed outside of Penzance in the area referred to as the ‘remainder of the Community Network Area’. The latest figures reduce the number of dwellings to be located in the remainder of the CNA over the plan period.

14.2 Comments have already been made with regards to the overall housing target for Cornwall and these will not be reiterated in full here. However it is sufficient to say that the decision to set the county’s housing target at such a low level is certainly open to scrutiny, and that to be considered sound at examination the Council will need to increase its housing numbers. With regards to West Penwith, the housing numbers proposed for Penzance and the communities in the remainder of the CNA will also need to be raised accordingly.

14.3 Rather than considering Cornwall’s rural settlements in isolation it is important to recognise the key functional relationships that exist between them. A small settlement may have limited access to services and facilities when considered in isolation but may actually demonstrate more sustainable patterns of living and working when you take account of its shared functional relationship with surrounding settlements.



14.4 The table below provides an example of this in the context of West Penwith:

Settlement Services / facilities

St Just Primary and secondary schools, local food shops, bakers, butchers, post office, pharmacy, pubs/restaurants, sports centre, regular bus services

Botallack Local pub, regular bus services Carnyorth Primary school, regular bus service Trewellard Trewellard workshop units, local pub/hotel, café, church, regular bus

services Pendeen Primary school, post office, local pub/restaurant, food shop, church,

regular bus service.

14.5 In its report entitled ‘Planning for the Role and Future of Smaller Settlements in Cornwall’ Roger Tym & Partners, on behalf of the Council, examines the strength of the relationship that exists between groups of settlements. In this study a number of ‘functional units’ were investigated. These comprised a group of smaller settlements which together are considered to make up a larger spatial entity. One of the functional units examined was St Just and its hinterland. The following is an extract from the report:

“This testing area was chosen to see how strong the influence of St. Just was on settlements in the Lands End peninsula given the proximity of Penzance. It became apparent that St Just does play a role as a service centre for surrounding villages, and that it is a focus for people in the smaller settlements for some of their every day needs. Cape Cornwall secondary school is a particular driver in this relationship. St. Just falls some way short of meeting all the day to day needs of local people however, particularly around work, post 16 education and health care. Links with Penzance and to a more limited extent Falmouth and Truro are maintained to address these needs.”

14.6 The findings outlined above are very significant and should not be overlooked when planning the approach to development in West Penwith over the plan period. Policy 3 of the Local Plan PreSubmission document actually acknowledges that the functional role of settlements should be a key determinant when considering their suitability for development where it states that “the scale and mix of development…should be proportionate to the role and function of places”. Unfortunately this approach has not been carried through to policy PP1.

14.7 There is an excellent opportunity to strengthen the relationship that already exists between the settlements in the Lands End peninsula in West Penwith. This does not mean that development in this area of the CNA should be provided solely within St Just, but that an appropriate level of economic and housing development should be provided throughout the cluster of settlements in order to support and enhance sustainable rural communities.

14.8 With significant land holdings in and around the settlements of Botallack and Carnyorth the Tregothnan Estate is well placed to meet local housing and employment needs by releasing areas of land for appropriately scaled development to meet local needs. There is considered to be an excellent opportunity to meet local housing and/or economic



needs through the provision of well designed and appropriately scaled housing and/or work premises. Such development would serve to enhance the sustainability of Botallack and Carnyorth and would help to ensure the viability of services and facilities within the neighbouring villages. In both settlements the Estate’s land holdings adjoin the built form of the villages and so with sensitive design and layout it will be possible to provide development which not only meets local needs but which also safeguards and enhances the character and appearance of these villages.

14.9 Paragraph 1 of Rural Settlements within National Planning Policy Guidance states rural housing is essential to ensure the viable use of local services and community facilities such as schools, local shops, cultural venues, public houses and places of worship. Therefore it is essential that all settlements play a role in delivering sustainable development in rural areas.

15.0 Policy PP3 – Helston and the Lizard CNA

SOUND – The policy seeks to direct an appropriate level of growth to the remainder of the CNA outside of Helston.

15.1 While it is certainly appropriate for Helston, as the most significant settlement in the CNA, to accommodate the majority of housing growth over the coming plan period it is important that communities within the remainder of the CNA are also able to meet their own needs.

15.2 In this regard the Tregothnan Estate is pleased to see that the Council has increased the number of homes proposed for delivery within the wider CNA outside of Helston by 200. This revised target will contribute towards meeting the needs of the local area.

15.3 Although the vast majority of the Tregothnan Estate’s land holdings within the CNA comprises areas of open countryside (including the Lizard National Nature Reserve), the Estate also owns a number of sites within the Lizard which could be brought forward for development over the coming plan period. These sites, which have been submitted within the most recent Strategic Housing Land Availability Assessment (SHLAA) call for sites are well related to the main built up area of the settlement. With sensitive design and layout it will be possible to provide high quality development schemes which meet local housing needs and which safeguard the character and appearance of the village.

16.0 Policy PP6 – Truro and Roseland CNA

UNSOUND – The housing target proposed for the CNA does not seek to meet the full, objectively assessed needs of Truro and the wider CNA. It is therefore not positively prepared, is unjustified and inconsistent with national policy.

16.2 While the Tregothnan Estate recognises that the Proposed Submission Document has increased the housing targets set for the plan period in both Truro and the wider CNA, it remains deeply concerned that these targets are too low. The comments made in respect of policy PP6 follow on from the response to policy 2 – Key targets and spatial strategy. A strong case has already been presented that the overall housing target for the county is far too low and that the way in which it was set is deeply flawed and may fail to stand up to scrutiny at examination.

16.3 Paragraph 14 of the Framework sets out the Governments presumption in favour of sustainable development. This specifically states that “local planning authorities should



use their evidence base to meet the full, objectively assessed needs for market and affordable housing…” Unless the Inspector is satisfied that the Local Plan achieves this it will undoubtedly be deemed to be unsound and will not be able to proceed to adoption.

16.4 The Proposed Submission document sets a target of 3000 dwellings in Truro, which is an increase of 1000 from the PreSubmission document. However this target still falls well short of the 4,500 target originally set out in the Core Strategy Preferred Options document.

16.5 Decisions regarding the provision of future homes must be supported by robust evidence which can be defended at examination. The following is an extract from the Council’s own evidence base (Planning Future Cornwall: Housing Growth and Distribution, January 2012).

“The population in the Truro & the Roseland area is forecast to grow by about 9,800 over the next 20 years if current trends continue, and housing, jobs and facilities will need to be provided to meet this increase. 1,600 people on the waiting list (9%) have expressed a preference to live in Truro, Threemilestone or Probus. The number of new households in the area is forecast to grow by up to 6,500 over the next twenty years if current trends continue, and many of these households will require additional homes to be built. In addition there is a need for about 2,200 additional affordable homes to be provided over the next ten years to accommodate those already in housing need. Housing development in this area is likely to be predominantly taken up by permanent residents. There are local aspirations to plan for the appropriate location and distribution of housing growth, taking into consideration the evidence gathering work for the Truro and Threemilestone Area Action Plan, and ensuring that the housing needs of the community are met, with a particular emphasis on affordable housing.”

16.6 This quote explains that there is a need for 2,200 additional affordable homes to be provided within the next ten years just to accommodate those who are already in need of such housing. While it is appreciated that there is a degree of complexity in forecasting the needs of future households, there is no disputing the numbers of households who are already on the affordable housing register. If there is a need to provide 2,200 affordable homes in Truro over the next ten years it is clearly insufficient to set a target of 3000 homes (comprising both market and affordable homes) for the entire plan period which covers a span of twenty years.

16.7 The Local Plan must aim to manage change and meet the full, objectively assessed needs for market and affordable housing. It is clear that Cornwall Council is currently not achieving this within its proposed housing targets, both for the county as a whole and certainly not for the city of Truro. As it stands the housing target set out in policy PP6 is considered to be a long way short of addressing the needs of Truro and so to make the Local Plan sound the Council must dramatically increase the proposed provision.

16.8 Disappointingly, the housing target for the wider CNA has also only been increased by 100, which is considered too low particularly as this area is close to Truro and therefore a desirable area of growth.

16.9 In addition to the land at Truro the Tregothnan Estate also has significant land holdings within and adjoining the CNA’s smaller settlements including Chacewater, Blackwater, Tresillian, Playing Place and Portscatho. Within these settlements there are a number of sites within the Estate’s ownership which could be brought forward for development over the coming plan period. These have been submitted within the latest Strategic Housing Land Availability Assessment (SHLAA) call for sites.



16.10 Although the sites at these smaller settlements might not have the same capacity for development as those around the periphery of Truro, their potential to provide small scale development schemes that meet local housing and/or economic needs is no less significant to the local communities that live there. In these settlements it is locally made decisions about small scale development schemes that are of key importance and are crucial to the sustainability of those communities.

17.0 Policy PP9 – St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithial CNA

SOUND the policy seeks to direct an appropriate level of growth to the China Clay CNA

17.1 While the Tregothnan Estate does not support the overall reduction of housing numbers proposed for the county as a whole it is pleased to see the number of homes proposed for the China Clay CNA has actually risen from 800 to 1,500 over the plan period. This is entirely appropriate given the size and nature of settlements in the CNA which have the need and capacity for housing growth over the coming years. It is however important that future growth in housing is supported by sufficient employment development so as to reduce levels of outcommuting to larger centres of employment.

17.2 With significant land holdings in and around the settlements of St Dennis and Roche the Tregothnan Estate is well placed to meet local housing and employment needs by releasing areas of land for development. There is considered to be an excellent opportunity to meet local housing and/or economic needs through the provision of well designed and appropriately scaled housing and/or work premises. Such development would serve to enhance the sustainability of these villages and would also help to ensure the viability of services and facilities within neighbouring settlements. In both settlements the Estate’s land holdings adjoin the built form of the villages and so with sensitive design and layout it will be possible to provide development which not only meets local needs but which also safeguards and enhances their character and appearance. Those sites which are considered to have potential for development have been submitted within the latest Strategic Housing Land Availability Assessment (SHLAA) call for sites.

18.0 Attendance at Examination

18.1 The Tregothnan Estate requests the right to take part in the upcoming Examination into the Cornwall Local Plan so that it can participate in the debate regarding the soundness of the plan. Although the schedule for the Examination process is not yet know the Tregothnan Estate would like to participate in hearing sessions dealing with the following issues.

Policy 1 – Presumption in favour of sustainable development

Policy 2 – Key targets and spatial strategy

Policy 3 – Role and function of places

Policy 5 – Jobs and skills

Policy 6 – Housing mix



Policy 7 – Housing in the countryside

Policy 8 – Affordable housing

Policy 14 – Development standards

Policy 24 – Historic environment

Policy 28 – Infrastructure

Policy PP1 – West Penwith CNA

Policy PP3 – Helston and the Lizard CNA

Policy PP6 – Truro and Roseland CNA

Policy PP9 – St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithiel CNA


Appendix A

Completed representation forms

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

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 2. Agent details (if details. applicable).

Name Organisation

Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Preferred contact method

The Tregothnan Estate

Email �Post �

Steve Briggs Smiths Gore

York House Blackbrook Business Park Taunton Somerset TA1 2PX

Email �

Post �

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

No �

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 PreSubmission 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;

Please see the accompanying written report which sets out our specific comments.

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 Cooperate) 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


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

No comment

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

Policy 1

Sustainability Appraisal Report

UNSOUND – This policy does not accord with paragraph 14 of the Framework which sets out the Government’s presumption in favour of sustainable development.

Please see the full written submission for detailed comments.


Policy 2





Policy 3


UNSOUND – This strategy is too restrictive to deliver the required level of housing outside of the main settlements. This approach is considered to be unjustified and ineffective. The policy also fails to acknowledge the relationships that exist between smaller rural settlements.



Policy 5





Policy 6


SOUND – This policy accords with paragraph 50 of the Framework which sets out the objective of delivering a wide choice of high quality homes.


Policy 7





Policy 8


UNSOUND – This policy does not seek to satisfy local need/demand for selfbuild homes. This is contrary to national planning policy.



Policy 9





Policy 14





Policy 24





Policy 28


UNSOUND – The policy is not sufficiently flexible to take account of issues surrounding financial viability. It is therefore contrary to national policy. Please see the full written submission for detailed comments.


Policy PP1





Policy PP3





Policy PP6


UNSOUND – The housing target proposed for the CNA does not seek to meet the full, objectively assessed needs of Truro and the wider CNA. It is therefore not positively prepared, is unjustified and inconsistent with national policy.



Policy PP9




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 Yes 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 28/04/2014

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.

Planning Team

Steve Briggs Taunton office 01823 445039 [email protected]

Ian Smith Peterborough office 01733 559320 [email protected]

Debbie Mackay Edinburgh office 0131 561 7117 [email protected]

Jo Robison Darlington office 01325 462966 [email protected]

Lee Scott Petworth office 01798 345971 [email protected]

Planning Services

Planning applications and statutory processes • Advice on strategy and approach • Site appraisals and development briefs • Preapplication and stakeholder negotiations • Community consultation • Preparation, coordination and submission of

planning applications • Planning appeals – written representations,

informal hearings and public inquiries • Planning agreements • Lawful development certificates • Enforcement matters

Rural planning projects • Alternative use assessments • Residential development and affordable housing

projects • Employment development • Agricultural and equestrian projects • Farm diversification • Barn conversions • Agricultural occupancy conditions • Tourism and leisure development • Conservation and historic buildings advice • Renewable energy and energy conservation • Rights of way

mailto:[email protected]





Cornwall Local Plan Strategic Policies 2010 – 2030: Presubmission document consultation

Response made on behalf of The Tregothnan Estate

April 2013

6162

Typewritten Text

588

Cornwall Local Plan PreSubmission document consultation response The Tregothnan Estate

Contents

Page No

1.0 Introduction to the consultation response......................................................1

2.0 Local Plan preparation – tests of soundness...................................................1

3.0 Policy 1 – Presumption in favour of sustainable development ........................2

4.0 Policy 2 – Key targets and spatial strategy .....................................................2

5.0 Policy 3 – Role and function of places.............................................................4

6.0 Policy 5 – Jobs and skills ................................................................................6

7.0 Policy 6 – Housing mix....................................................................................7

8.0 Policy 7 – Housing in the countryside .............................................................8

9.0 Policy 8 – Affordable housing .........................................................................8

10.0 Policy 9 – Affordable housing led schemes .....................................................9

11.0 Policy 11 – Managing viability ......................................................................10

12.0 Policy 14 – Development standards ..............................................................10

13.0 Policy 24 – Historic environment ..................................................................11

14.0 Policy 28 – Infrastructure.............................................................................12

15.0 Policy PP1 – West Penwith CNA ....................................................................12

16.0 Policy PP3 – Helston and the Lizard CNA ......................................................14

17.0 Policy PP6 – Truro and Roseland CNA ...........................................................15

18.0 Policy PP7 – St Agnes and Perranporth CNA .................................................16

19.0 Policy PP9 – St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithiel CNA…………………………………………………………17

Appendix A Completed representation form



1.0 Introduction to the consultation response

1.1 This consultation response has been prepared by Smiths Gore on behalf of the Tregothnan Estate. The submission has been prepared following an invitation from the Council to comment on its Local Plan PreSubmission document.

1.2 As a significant owner of land and property in Cornwall the Tregothnan Estate is keen to ensure that the policies within the emerging Local Plan are responsive to local circumstances and support, rather than constrain, the development that Cornwall’s urban and rural communities and businesses require to meet their social and economic needs.

1.3 The form of this response follows the advice given by Cornwall Council in that comments have been made on the representation forms provided. However as these forms do not allow for an adequate level of detail to be provided, the main body of the submission is included within this written report. Therefore the comments submitted in the forms and in this written submission should be read together to appreciate the full response to this consultation. The full written response has been submitted both electronically and as a hard copy to Cornwall Council.

1.4 This written report makes detailed comments on particular sections of the consultation document, clearly identifying whether policies are considered to be ‘sound’ or ‘unsound‘ and why. Where policies are deemed to be unsound recommendations will be provided regarding how they could be amended in order to make them sound. The sections to which the comments relate are clearly identified by each subheading.

2.0 Local Plan preparation – tests of soundness

2.1 Local Plans at the presubmission stage should accord with certain tests which are outlined within the National Planning Policy Framework (the Framework). The tests are in place to allow a planning Inspector to assess whether a plan is ‘sound’. A sound plan is described at paragraph 182 of the Framework as being:

Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;

Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;

Effective – the plan should be deliverable over its period and based on effective joint working on crossboundary strategic priorities; and

Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

2.2 This consultation response has been prepared with these tests in mind and considers the policies contained within the Cornwall Council Local Plan Presubmission document against each of them. It also tests them against the other relevant policies within the Framework in order to ensure it is consistent with national policy.


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3.0 Policy 1 – Presumption in favour of sustainable development

SOUND – This policy accords with paragraph 14 of the Framework which sets out the Government’s presumption in favour of sustainable development.

3.1 The Tregothnan Estate supports the inclusion of policy 1 which clearly sets out how the local planning authority will deal with planning applications over the coming plan period. The policy is considered to adequately reflect the presumption in favour of sustainable development as set out in the Framework and it is fully supported by the Estate.

3.2 The Tregothnan Estate also welcomes the Council’s commitment to “work with applicant’s to find solutions which mean that proposals will be approved wherever possible…” This approach will lead to enhanced levels of confidence among applicants which will in turn help to facilitate the delivery of developments over the plan period that meet the social, economic and environmental needs of Cornwall’s communities and businesses.

4.0 Policy 2 – Key targets and spatial strategy


4.1 Paragraph 14 of the Framework sets out the Government’s presumption in favour of sustainable development. This specifically states that “local planning authorities should use their evidence base to meet the full, objectively assessed needs for market and affordable housing…” Unless the Inspector is satisfied that the Local Plan achieves this it will undoubtedly be deemed to be unsound and will not be able to proceed to adoption.

4.2 In the Core Strategy Preferred Options document, which was published in January 2012 for consultation, a target was set for the delivery of 48,000 new homes between 2010 2030. This target has now been reduced significantly to 42,250, a reduction of some 5,750 homes. Following an assessment of Cornwall Council’s committee meetings over the past four months it is clear that there has been a great deal of uncertainty regarding the level at which Cornwall’s housing targets should be set, with proposals

12th ranging from 29,000 up to 75,000. The minutes of the Full Council meeting on February 2012 show that planning officers advised councillors that the increase in households over the plan period was forecast at between 45,400 – 63,000 depending on the assumptions used. They also explained that the housing allocation had already been brought down from 68,000 to 45,400 and that any lower figure would not be feasible. Despite this, after much toing and froing with housing numbers being chipped off from various areas of the county (seemingly at the whim of councillors), the final resolution was to set the housing target at 42,250. Clearly the way in which the final decision was made can not be considered robust and is unlikely to stand up to challenge at examination.

4.3 On 9th April 2013 the Department for Communities and Local Government released its ‘Household Interim Projections 2011 2021, England’. Using a robust methodology based on trends observed in Census (including the 2011 Census) and Labour Force Survey data, this document projects the increase in population and household growth over the period between 2011 2021.

4.4 In this document Cornwall is projected to experience a growth in households of between 1% and 1.25% per year; one of the most significant rates of household growth


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in the country. The table below uses this projection to illustrate the likely rate of growth in households in Cornwall over the plan period. We acknowledge that this projection can not be entirely relied upon, as it assumes that the growth rate will continue unaltered after 2021. It also covers the period between 2011 – 2031 rather than 2010 2030. Regardless it still provides a useful indication of the likely level of household growth over the coming 20 year period, based on projections produced from national government. It is rather striking how significant the gap is between these projections and the target of 42,250 set by the Council.

Annual Household growth (1%)

Annual Household growth (1.25%)

Current level* 230,400 230,400 Year 1 232,704 233,280 Year 2 235,031.04 236,196 Year 3 237,381.35 239,148.45 Year 4 239,755.16 242,137.80 Year 5 242,152.71 245,164.52 Year 6 244,574.23 248,229.07 Year 7 247,019.97 251,331.93 Year 8 249,490.16 254,473.57 Year 9 251,985.06 257,654.48 Year 10 254,504.91 260,875.16 Year 11 257,049.95 264,136.09 Year 12 259,620.44 267,437.79 Year 13 262,216.64 270,780.76 Year 14 264,838.80 274,165.51 Year 15 267,487.18 277,592.57 Year 16 270,162.05 281,062.47 Year 17 272,863.67 284,575.75 Year 18 275,592.30 288,132.94 Year 19 278,348.22 291,734.60 Year 20 281,131.70 295,381.28

Total change** + 50,732 + 64,982

*The starting number of households is based on the number provided within the Cornwall Council publication ‘2011 Census at a glance (First Release) July 2012. **Rounded up to nearest whole number

4.5 The Local Plan must aim to manage change meet the full, objectively assessed needs for market and affordable housing. At Examination all evidence used by the Council in determining the proposed housing target will be rigorously assessed and tested. If this evidence is found not to be sufficiently robust the plan will be found unsound and will delay its adoption, leaving the Council vulnerable to ‘planning by appeal’. It is important to note that the vast majority of Local Plans rejected at examination were due to the fact that their housing targets were too low and did not meet the projected growth in households, i.e. the full, objectively assessed needs. This point is made clear by the statistic that 12 out of 17 councils which submitted their Local Plans in the last 6 months have been forced to amend their housing numbers or the data used to determine these targets.

4.6 As it stands the housing target set out in policy 2 is considered to be a long way short of addressing the needs of Cornwall and we would encourage the Council to revisit this issue and to increase its housing numbers accordingly.


3


5.0 Policy 3 – Role and function of places

UNSOUND – This strategy is overly reliant on the production of Neighbourhood Plans to deliver the required level of housing outside of the main settlements. This approach is considered to be unjustified and ineffective. The policy also fails to acknowledge the relationships that exist between smaller rural settlements.

5.1 Over reliance on Neighbourhood Plans

The Tregothnan Estate has concerns regarding the mechanisms proposed to facilitate the delivery of development over the plan period. Most notably these concerns relate to an over reliance on the preparation of Neighbourhood Plans to allocate development sites outside of the main settlements. So far, in the 18 months since the Localism Act received royal ascent, only one Neighbourhood Plan (Upper Eden) has successfully passed through Examination, a local referendum and been formally adopted. While there has been a great deal of interest among local communities for preparing Neighbourhood Plans in Cornwall and indeed nationally, the reality is that the process requires significant resources of time and funding. This type of approach can not therefore be relied upon to deliver much needed development in the county’s smaller communities in the early years of the plan period. This situation will be further exacerbated if a policy of restraint is imposed upon settlements while Neighbourhood Plans are being prepared.

5.2 A significant proportion of growth is rightly proposed to take place outside of the county’s main settlements and so if development in these areas does not come forward as anticipated it is likely that the Council will fail to achieve the targets set out in draft policy 2. At a time when certain areas of Cornwall are already unable to demonstrate a deliverable five year supply of housing land this type of approach will do little to generate confidence among landowners and developers who, with greater levels of certainty, would be better placed to come forward with sustainable development proposals. The consequence of this is that the Council’s strategy will be undermined and the county will continue to demonstrate a shortfall in its five year supply. The authority will then be in a weak position to resist developments, which are contrary to local policies, on sites which it might otherwise look to resist. This is because local policies relating to the supply of housing can not be considered up to date if the local planning authority is unable to demonstrate a five year supply of deliverable housing sites (see paragraph 49 of the Framework).

5.3 To ensure the delivery of sufficient levels of housing outside of the main settlements the Tregothnan Estate would like to encourage the local planning authority to identify strategic sites (of an appropriate scale) within a range of smaller settlements and to allocate these within the proposed Site Allocations DPD. This is a tried and tested process for allocating sites which ensures a far greater certainty of outcomes. Furthermore this process also allows for meaningful involvement and engagement with local communities to take place through effective techniques such as workshops, exhibitions etc.

5.4 In the previous submission to the Core Strategy Preferred Options document the Tregothnan Estate advocated the use of the Toolkit for Sustainable Rural Communities to ensure that meaningful public consultation takes place. The Toolkit for Sustainable Rural Communities was prepared to inform the production of local development documents in Local Planning Authority Areas in Devon. This work was commissioned by the Devon Strategic Partnership on behalf of a wide steering group including the Housing Corporation, Commission for Rural Communities and SW Regional Assembly as


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well as local authorities. The purpose of the Toolkit was to develop a more sophisticated approach to addressing the sustainability of rural settlements.

5.5 The Toolkit allows local communities, businesses and decisions makers to come to a view on how well (or not) a community performs against sustainability characteristics. It takes a series of sustainability criteria as a starting point and develops a set of questions around each to prompt debate and enable judgements to be made. Once the current position of the sustainability of a community has been established, local people, businesses and local planning authorities are in a much better position to consider the sustainability implications of development. The Toolkit, in effect, serves as the evidence base which can be used to understand the current sustainability of rural settlements and the types of development required, or indeed which should be avoided, in order to enhance the sustainability of communities.

5.6 In addition to engaging with local people and business the Council is encouraged to consult with land owners as part of these exercises. With land holdings in and around a number of the county’s rural settlements the Estate is well placed to make a significant contribution to meeting the needs of rural communities over the coming plan period. The Tregothnan Estate would therefore like to work with the Council, local people and businesses to explore how best to enhance the sustainability of Cornwall’s rural communities where appropriate.

5.7 Functional relationships between smaller settlements

The Tregothnan Estate supports the approach taken by Cornwall Council in considering the level of development to be planned for in towns and villages across the county which, rather being based simply on their size is actually based on a more detailed understanding of their role and function. There is also recognition that new development in smaller settlements can support, or even enable, the provision of appropriate services and facilities locally, thus enhancing their sustainability.

5.8 While broadly supportive of this approach it is considered that the Council should make specific reference to the ways in which smaller rural communities interact with each other and how the functional relationships that exist between them influences the travel patterns of people in rural communities. These relationships should form an important consideration when planning for the future development needs of rural communities. This is the approach advocated in paragraph 55 of the Framework which states that “where there are groups of smaller settlements, development in one village may support services in a village nearby”.

5.9 All too often local planning documents take the overly simplistic view that a settlement should have access to ‘x’ number of facilities and services in order to be deemed a sustainable location for development. This simplistic approach is considered to be flawed as it fails to recognise the complex inter relationships that exist between settlements which should be considered together in a holistic way. A small settlement may have limited access to services and facilities when considered in isolation but may actually demonstrate more sustainable patterns of living and working when you take account of its shared functional relationship with surrounding settlements. For example one settlement may have a primary school, another might contain employment units, whilst a third may be the centre of social life with a community hall and active local clubs and societies. Any or all may be appropriate locations for modest housing and economic development on the basis that all combine to provide a sustainable community life.


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6.0 Policy 5 – Jobs and skills


6.1 Tourism

In our previous consultation response to the Core Strategy Preferred Options document we encouraged the local planning authority to specifically identify tourism as an industry to be supported within the policy relating to jobs and skills. In this regard we are greatly encouraged to see that these comments have been taken on board and that policy 5 is now supportive of schemes for “high quality sustainable tourism facilities, attractions, accommodation and the upgrading of existing facilities in sustainable locations”.

6.2 The Tregothnan Estate is also pleased to see that policy 5 now provides further clarity about the types of employment related developments which will be supported in different locations. Of particular note is the support given to such developments in the “countryside and smaller rural settlements where it is of a scale appropriate to its location or where the use can show an over riding business need for its location.”

6.3 Livework units

The Tregothnan Estate is disappointed to see that Cornwall Council has not provided specific support for livework units within policy 5. This was highlighted in our previous response as a sustainable form of development which should be encouraged by Cornwall Council.

6.4 Fuelled by the impact of new technology (such as improved internet access in rural areas), a growing frustration with the stress and time wasting associated with the daily commute and a desire for a better work/life balance, self employed people in rural areas are increasingly choosing to opt for homeworking. In fact this is now a well established trend. Across the Cornwall countryside there is a significant supply of buildings, traditional and more modern, which are well suited to providing this type of livework arrangement. The conversion of rural buildings to establish a livework arrangement offers a wide range of benefits, not only to individuals and their businesses, but also to the wider economy and environment as well.

6.5 In November 2010 the Trade Union Congress (TUC) published an analysis of average commuting times in the UK. This analysis found that the average time spent commuting to and from work increased year on year from 1998 to 2006 when it reached a peak of 52 minutes 36 seconds per day. Since 2006 however average commute times have decreased every year. The TUC attributes this gradual reduction in commuting times partly to the growth in home working. Between 20062008 the number of people working from home increased by 291,000 which actually accounted for more than half of employment growth during this time period.

6.6 With approximately 25 million people in the UK commuting to work, it is estimated that commuting costs approximately £337 million of potential work time every day. Therefore one opportunity to help rural businesses deliver far more for the local economy is through the promotion and enabling of homebased work. With 11.59% of people in rural districts working from home (2001 census) this is clearly a highly significant factor in the rural economy – more so than in urban economies and in other rural economies.


6


% working from home

England 9.16

Rural districts 11.59

Urban districts 8.02

6.7 Over recent years the principle of livework units within the countryside has become more acceptable as a means of promoting the sustainable reuse of existing buildings. Such schemes are inherently sustainable as they help to meet local demand for housing (socially sustainable) and they provide local employment opportunities (economically sustainable). They also serve to reduce the need to travel by car and safeguard the character and appearance of traditional buildings (environmentally sustainable).

6.8 This type of development is specifically supported within paragraph 21 of the Framework which states that local planning authorities should “facilitate flexible working practices such as the integration of residential and commercial space within the same unit”. The Council is therefore strongly urged to support this form of development within policy 5 of the Local Plan; an approach which is being taken up by many other local authorities in the south west and nationally.

7.0 Policy 6 – Housing mix

SOUND subject to minor amendment to recognise issues surrounding development viability

7.1 Policy 6 explains that on developments comprising ten or more dwellings, applicants should seek to provide a range of housing types and tenures. It also sets a requirement to incorporate an element of, or provide a financial contribution towards the provision of an element of special care or shelter needs where there is evidence of need. The Tregothnan Estate is broadly supportive of this policy as there is clearly a need to ensure that future development responds to the needs of local communities; however it is important that such requirements do not threaten the overall viability of developments.

7.2 The Framework, in paragraph 173, places a great deal of emphasis on the need for local planning authorities to pay careful attention to viability and costs in plan making and decision taking in order to ensure that Local Plans are deliverable. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, housing mix, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. Paragraph 174 then goes on to explain that the cumulative impacts of these standards and policies should not put implementation of the plan at serious risk and should facilitate development throughout the economic cycle. It is important the local planning authorities take this guidance into account in preparing the Local Plan as consideration of overall viability is part of the evidence base which will be subjected to test, challenge and debate when it is


7


eventually examined. Demonstrably failing to consider this issue will almost certainly result in the Local Plan being found to be unsound.

8.0 Policy 7 Housing in the countryside


8.1 The Tregothnan Estate is largely supportive of the approach advocated within policy 7, which sets out the circumstances whereby housing development in the countryside will be supported. The Estate is particularly pleased to see that Cornwall Council has responded to the comments made within our previous submission and to changes in guidance from national government by specifically supporting residential conversion schemes. This is an approach which has not historically been taken within local planning policies but it is pleasing to see that the Council is responding to the recent changes in national planning policy brought about by the publication of the Framework.

8.2 It is however disappointing to see that policy 7 does not provide support for the development of livework units in the countryside. In fact we are surprised to see that this is the case considering that draft policy C of the Core Strategy Preferred Options document (relating to housing) actually did support this form of development.

8.3 A strong planning case in support of livework developments has already been provided in our response to draft policy 5 and so will not be reiterated in full here. It is however important to point out that livework units are identified as a form of development which should be supported within the Framework. Paragraph 21 of the Framework explains that local planning authorities should “facilitate flexible working practices such as the integration of residential and commercial space within the same unit”.

8.4 In order to conform to national policy it is strongly recommended that Cornwall Council provides specific support for livework developments, both within urban areas and the countryside. This should be the case for both new build developments and conversion schemes. This support could be provided within policy 3 – Role and Function of Places, policy 5 – Jobs and Skills or policy 7 – Housing in the Countryside.

9.0 Policy 8 – Affordable housing

SOUND subject to minor amendments to identify other affordable housing products which will be considered as part of the overall mix.

9.1 As of 31st December 2012 there were 27,532 households on the affordable housing register in Cornwall and this number is growing week by week. It is understood that the Council and its partners have recently approved an ambitious housing target to deliver 1,000 affordable homes each year of the next four years. To achieve this target it is essential that policy 8, along with all other policies which influence affordable housing development are appropriately worded in order to facilitate this level of delivery.

9.2 In light of the desperate need within the county the Estate is supportive of the proposed requirement for all new housing schemes comprising two or more dwellings to provide a contribution to this issue, either directly through the provision of affordable homes or through financial contributions to facilitate delivery elsewhere. This approach is clearly appropriate in Cornwall where the vast majority of housing proposals are relatively small scale. It is also encouraging to see that the Council has acknowledged


8


the important issue of development viability within the wording of the policy and that there will be a willingness to negotiate on the mix of affordable housing products where necessary. In order to ensure that housing developments are deliverable over the coming years it will be important for the local planning authority to take a flexible approach which takes account of the financial viability of individual developments. This approach is supported in paragraph 54 of the Framework which calls on local planning authorities to “consider whether allowing some market housing would facilitate the provision of additional affordable housing to meet local needs”.

9.3 The policy also provides broad guidance on what the likely affordable housing requirements are likely to be in particular areas of the county. It is understood that this has been determined on the basis of ‘house price areas’, which will clearly be a significant determinant of overall viability. This type of approach is useful as it provides landowners and developers with a greater sense of certainty regarding the likely costs of development. It will however be important for the Council to regularly update this assessment of house price areas in order to ensure that it remains accurate over the entirety of the plan period. The Tregothnan Estate recommends that a commitment to carry out this work is provided within the supporting text to policy 8.

9.4 The one area of concern regarding this policy is that there does not seem to be any mention of ‘self build homes’ within the mix of affordable housing products which will be considered. This is considered to be an oversight particularly as self building housing is identified on the Cornwall Council website as a form of affordable housing. It is strongly recommended that policy 8 is amended to include reference to self build housing as a product which will be considered as part of the overall mix of affordable housing provision on development sites.

10.0 Policy 9 – Affordable housing led schemes

SOUND – This policy acknowledges the need to allow a certain amount of market housing as part of affordable housing led schemes where necessary to ensure developments are viable. This is consistent with the Framework.

10.1 In light of the fact that a significant proportion of Cornwall’s population reside within smaller towns, villages and hamlets it is important for there to be specific guidance for how the development needs of these communities will be provided for over the plan period. This policy is considered to satisfactorily fill that role and will help to deliver, rather than stifle, the delivery of much needed housing development in rural areas, thus helping to ensure that housing targets are achieved.

10.2 During difficult economic times such as this, financial viability is a key consideration to be taken into account for all developments, particularly because public funding for affordable housing provision is not as available as it once was. This means that the delivery of affordable housing will need to be funded by landowners and developers through future development schemes. Therefore in order for ‘affordable housing led schemes’ to be financially viable it will be necessary to allow a proportion of market housing as a method of funding the affordable provision through cross subsidy. The Tregothnan Estate is therefore pleased to see that the policy allows for the provision of market housing in such proposals where it “is satisfied it is essential for the delivery of the development”.

10.3 It is also encouraging to see that there is recognition within policy 9 that market housing is not simply something which must be tolerated in order to facilitate the delivery of affordable housing. On the contrary it is important to provide a mixture of housing tenures, including both market and affordable, in order to maintain or create


9


balanced communities. This seems to be acknowledged within the policy which says that market housing will be supported where “it can demonstrate it meets a local need for housing”.

10.4 When allocating housing to people in need every effort should be made to ensure that it is local people who have access to affordable housing. In this regard a cascade mechanism is the most appropriate approach to take which prioritises those with the closest association with the local area. The cascade approach should firstly accommodate households who are either current residents or have an existing family connection or employment connection with the local area. Only after it can be determined with certainty that there are no such households in need should others be considered. This is the approach advocated within the policy which explains that homes will be allocated in line with the Council’s adopted local connections policies.

11.0 Policy 11 Managing viability

SOUND – The approach advocated in this policy will ensure that developments will not be rendered undeliverable by affordable housing requirements.

11.1 There is recognition in this policy and its supporting text that it is not always possible to deliver the full quota of affordable housing as part of developments. The Tregothnan Estate welcomes the Council’s commitment to adopting a proactive approach to managing viability on a site specific basis.

11.2 The Framework, in paragraph 173, places a great deal of emphasis on the need for local planning authorities to pay careful attention to viability and costs in plan making and decision taking in order to ensure that Local Plans are deliverable. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. Paragraph 174 then goes on to explain that the cumulative impacts of these standards and policies should not put implementation of the plan at serious risk and should facilitate development throughout the economic cycle. It is important the local planning authority takes this guidance into account in preparing the Local Plan as consideration of overall viability is part of the evidence base which will be subjected to test, challenge and debate when it is eventually examined. With regard to affordable housing it is considered that Cornwall Council has sufficiently addressed the issue of managing viability with policy 9.

10.3 This policy also provides an element of clarity to landowners and developers looking to bring forward development schemes. The proposed sequential approach will form a useful starting point for negotiations between applicants and the Council when there is a need to discuss issues relating to development viability. This is to be welcomed.

12.0 Policy 14 – Development standards


12.1 Policy 14 sets out a number of measures to ensure that a high standard of development is reached within all developments over the coming plan period. This is an approach



which is welcomed by the Tregothnan Estate however there is a concern that, at present, there is no acknowledgement of how these requirements will impact upon development viability.

12.2 This concern relates specifically to point 6, which sets the requirement for all new domestic and non domestic development to be “at least zero carbon” by 2016 and 2019 respectively. While the Estate does not contest that this is a target which should be aspired to wherever possible the policy must recognise that, in certain circumstances, achieving that standard may render some development schemes unviable.

12.3 The Framework, in paragraph 173, places a great deal of emphasis on the need for local planning authorities to pay careful attention to viability and costs in plan making and decision taking in order to ensure that Local Plans are deliverable. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable. Paragraph 174 then goes on to explain that the cumulative impacts of these standards and policies should not put implementation of the plan at serious risk and should facilitate development throughout the economic cycle. It is important the local planning authority takes this guidance into account in preparing the Local Plan as consideration of overall viability is part of the evidence base which will be subjected to test, challenge and debate when it is eventually examined. Demonstrably failing to consider this issue will almost certainly result in the Local Plan being found to be unsound. While this issue has been considered in relation to affordable housing this does not seem to be the case in this instance.

12.4 Although developers vary in their approach to profit and risk, the key point is that a development which is not viable will not be delivered. This can mean that housing targets will not be met and delivery over the plan period will fall behind and fall short. In such cases, developers will await better market or financial conditions and put their resources into developing more profitable schemes elsewhere instead.

13.0 Policy 24 – Historic environment


13.1 Paragraph 132 of the Framework explains that “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation”. It then goes on to state that “the more important the asset, the greater the weight should be”. In this paragraph the Government is saying that there are varying degrees of significance when considering heritage assets and that some assets are more important than others.

13.2 The Framework also differentiates between the degrees of harm that might be caused to heritage assets and the way such harm should be considered. For example where a development proposal would result in the ‘total loss’ of a heritage asset, it explains that permission should be refused unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that loss. Where a development would result in ‘less than substantial harm’ to the significance of a heritage asset, this harm will need to be weighed against the public benefits of the proposal, including securing its optimum viable use.



13.3 In its current state it is considered that policy 24 does not adequately reflect national policy as it does not differentiate between degrees of significance of heritage assets or indeed the levels of harm to those assets which might be caused by development proposals. It is therefore strongly recommended that the Council looks again at this policy to bring it in to line with national policy.

14.0 Policy 28 Infrastructure

UNSOUND – The policy is not sufficiently flexible to take account of issues surrounding financial viability. It is therefore contrary to national policy.

14.1 New developments can, individually or cumulatively, result in increased pressure on existing infrastructure. The Tregothnan Estate therefore acknowledges that there may be a need to secure financial contributions from applicants in certain circumstances in order to make such developments acceptable in planning policy terms.

14.2 When considering the appropriate level of contributions to be derived from a particular development it is important that the local planning authority has a detailed, up to date, evidence base which outlines the infrastructure requirements for the area. In this regard section 1 of policy 28 explains that the Council will “continue to work in partnership with infrastructure providers and other delivery agencies to keep an up to date infrastructure delivery plan”. This is welcomed as it will provide developers with an indication of what is likely to be required and provides useful information on infrastructure constraints which might impact upon certain developments. This will provide landowners and developers with a greater sense of certainty.

14.3 It is however important that the local planning authority carefully considers the value to be gained from imposing such requirements upon developments. When considering the level of infrastructure provision to be required it is essential to weigh the desirability of funding infrastructure against the potential effects of that imposition upon the economic viability of new developments. These decisions should therefore be based on detailed evidence about the likely effects on financial viability. If an appropriate balance can not be achieved there is a real risk that much of the development that Cornwall needs over the coming plan period will be unviable and consequently undeliverable. If this is the case then it is likely that the Local Plan will be found unsound when it goes through the examination process.

14.4 The Tregothnan Estate would also like to see some flexibility built in to the wording of the policy which allows for negotiations to take place regarding infrastructure requirements where appropriate.

15.0 Policy PP1 – West Penwith CNA


15.1 When responding to the Core Strategy Preferred Options document the Tregothnan Estate highlighted concerns regarding the fact that an insufficient proportion of the proposed housing growth for West Penwith is being directed outside of Penzance in the area referred to as the ‘remainder of the Community Network Area’. While the proportion has increased, by virtue of the fact that the number of homes proposed for



Penzance have been dramatically reduced, the actual number of homes proposed in the remainder of the CNA has not increased in real terms.

15.2 Comments have already been made with regards to the overall housing target for Cornwall and these will not be reiterated in full here. However it is sufficient to say that the decision to reduce the county’s housing target is certainly open to scrutiny and that to be considered sound at examination the Council will need to substantially increase its housing numbers. With regards to West Penwith, the housing numbers proposed for Penzance and the communities in the remainder of the CNA will also need to be raised accordingly.

15.3 Rather than considering Cornwall’s rural settlements in isolation it is important to recognise the key functional relationships that exist between them. A small settlement may have limited access to services and facilities when considered in isolation but may actually demonstrate more sustainable patterns of living and working when you take account of its shared functional relationship with surrounding settlements.

15.4 The table below provides an example of this in the context of West Penwith:

Settlement Services / facilities

St Just Primary and secondary schools, local food shops, bakers, butchers, post office, pharmacy, pubs/restaurants, sports centre, regular bus services

Botallack Local pub, regular bus services Carnyorth Primary school, regular bus service Trewellard Trewellard workshop units, local pub/hotel, café, church, regular bus

services Pendeen Primary school, post office, local pub/restaurant, food shop, church,

regular bus service.

15.5 In its report entitled ‘Planning for the Role and Future of Smaller Settlements in Cornwall’ Roger Tym & Partners, on behalf of the Council, examines the strength of the relationship that exists between groups of settlements. In this study a number of ‘functional units’ were investigated. These comprised a group of smaller settlements which together are considered to make up a larger spatial entity. One of the functional units examined was St Just and its hinterland. The following is an extract from the report:

“This testing area was chosen to see how strong the influence of St. Just was on settlements in the Lands End peninsula given the proximity of Penzance. It became apparent that St Just does play a role as a service centre for surrounding villages, and that it is a focus for people in the smaller settlements for some of their every day needs. Cape Cornwall secondary school is a particular driver in this relationship. St. Just falls some way short of meeting all the day to day needs of local people however, particularly around work, post 16 education and health care. Links with Penzance and to a more limited extent Falmouth and Truro are maintained to address these needs.”

15.6 The findings outlined above are very significant and should not be overlooked when planning the approach to development in West Penwith over the plan period. Policy 3 of the Local Plan PreSubmission document actually acknowledges that the functional role of settlements should be a key determinant when considering their suitability for development where it states that “the scale and mix of development…should be



proportionate to the role and function of places”. Unfortunately this approach has not been carried through to policy PP1.

15.7 There is an excellent opportunity to strengthen the relationship that already exists between the settlements in the Lands End peninsula in West Penwith. This does not mean that development in this area of the CNA should be provided solely within St Just, but that an appropriate level of economic and housing development should be provided throughout the cluster of settlements in order to support and enhance sustainable rural communities.

15.8 With significant land holdings in and around the settlements of Botallack and Carnyorth the Tregothnan Estate is well placed to meet local housing and employment needs by releasing areas of land for appropriately scaled development to meet local needs. There is considered to be an excellent opportunity to meet local housing and/or economic needs through the provision of well designed and appropriately scaled housing and/or work premises. Such development would serve to enhance the sustainability of Botallack and Carnyorth and would help to ensure the viability of services and facilities within the neighbouring villages. In both settlements the Estate’s land holdings adjoin the built form of the villages and so with sensitive design and layout it will be possible to provide development which not only meets local needs but which also safeguards and enhances the character and appearance of these villages. Those sites which are considered to have potential for development have been submitted within the latest Strategic Housing Land Availability Assessment (SHLAA) call for sites.

16.0 Policy PP3 – Helston and the Lizard CNA


16.1 While it is certainly appropriate for Helston, as the most significant settlement in the CNA, to accommodate the majority of housing growth over the coming plan period it is important that communities within the remainder of the CNA are also able to meet their own needs.

16.2 In this regard the Tregothnan Estate is pleased to see that the Council has not sought to reduce the number of homes proposed for delivery within the wider CNA outside of Helston. However, it is likely that the decision to reduce the number of homes proposed for Helston itself by 200 will be the subject of scrutiny by interested parties.

16.3 Although the vast majority of the Tregothnan Estate’s land holdings within the CNA comprises areas of open countryside (including the Lizard National Nature Reserve), the Estate also owns a number of sites within the Lizard which could be brought forward for development over the coming plan period. These sites, which have been submitted within the most recent Strategic Housing Land Availability Assessment (SHLAA) call for sites are well related to the main built up area of the settlement. With sensitive design and layout it will be possible to provide high quality development schemes which meet local housing needs and which safeguard the character and appearance of the village.



17.0 Policy PP6 – Truro and Roseland CNA

UNSOUND – The housing target proposed for the CNA does not seek to meet the full, objectively assessed needs of Truro. It is therefore not positively prepared, is unjustified and inconsistent with national policy.

17.1 While the Tregothnan Estate supports the Council’s decision to increase the number of dwellings proposed for the remainder of the CNA it has deep concerns regarding the approach taken with regards to Truro. The comments made in respect of policy PP6 follow on from the response to policy 2 – Key targets and spatial strategy. A strong case has already been presented that the overall housing target for the county is far too low and that the way in which it was set is deeply flawed and will almost certainly fail to stand up to scrutiny at examination.

17.2 The Core Strategy Preferred Options consultation document set a target of delivering 4,500 homes in Truro over the plan period. Policy PP6 of the Local Plan PreSubmission document is now proposing only 2,200 dwellings for the city, a reduction of 2,300 (or 51%). With a reduced target for the county as a whole it is not unexpected that Truro’s housing numbers have also reduced, however it is surprising that the level of the reduction is proportionally far greater than in any other CNA across the county. Even more concerning is that no justification has been provided for why this is the case.

17.3 Paragraph 14 of the Framework sets out the Governments presumption in favour of sustainable development. This specifically states that “local planning authorities should use their evidence base to meet the full, objectively assessed needs for market and affordable housing…” Unless the Inspector is satisfied that the Local Plan achieves this it will undoubtedly be deemed to be unsound and will not be able to proceed to adoption.

17.4 Decisions regarding the provision of future homes must be supported by robust evidence which can be defended at examination. In particular the decision to cut the number of homes at Truro (identified as a top tier settlement in policy 3) by more than half will inevitably be highly challenged and need to be adequately justified. However, no explanation is provided within the Local Plan PreSubmission document, or within any supporting evidence base documents to support the Council’s decision. In fact it is difficult to see how such an explanation can possibly be provided, particularly when you look at the following extract from the Council’s own evidence base (Planning Future Cornwall: Housing Growth and Distribution, January 2012).

“The population in the Truro & the Roseland area is forecast to grow by about 9,800 over the next 20 years if current trends continue, and housing, jobs and facilities will need to be provided to meet this increase. 1,600 people on the waiting list (9%) have expressed a preference to live in Truro, Threemilestone or Probus. The number of new households in the area is forecast to grow by up to 6,500 over the next twenty years if current trends continue, and many of these households will require additional homes to be built. In addition there is a need for about 2,200 additional affordable homes to be provided over the next ten years to accommodate those already in housing need. Housing development in this area is likely to be predominantly taken up by permanent residents. There are local aspirations to plan for the appropriate location and distribution of housing growth, taking into consideration the evidence gathering work for the Truro and Threemilestone Area Action Plan, and ensuring that the housing needs of the community are met, with a particular emphasis on affordable housing.”

17.5 This quote explains that there is a need for 2,200 additional affordable homes to be provided within the next ten years just to accommodate those who are already in need of such housing. While it is appreciated that there is a degree of complexity in



forecasting the needs of future households, there is no disputing the numbers of households who are already on the affordable housing register. If there is a need to provide 2,200 affordable homes in Truro over the next ten years it is clearly insufficient to set a target of 2,200 homes (comprising both market and affordable homes) for the entire plan period which covers a span of twenty years. While a new Housing Growth and Distribution document was produced by the Council in January 2013 no explanation is provided for the significant reduction in the housing target for Truro.

17.6 The Local Plan must aim to manage change and meet the full, objectively assessed needs for market and affordable housing. It is clear that Cornwall Council is currently not achieving this within its proposed housing targets, both for the county as a whole and certainly not for the city of Truro. As it stands the housing target set out in policy PP6 is considered to be a long way short of addressing the needs of Truro and so to make the Local Plan sound the Council must dramatically increase the proposed provision.

17.7 In addition to the land at Truro the Tregothnan Estate also has significant land holdings within and adjoining the CNA’s smaller settlements including Chacewater, Blackwater, Tresillian, Playing Place and Portscatho. Within these settlements there are a number of sites within the Estate’s ownership which could be brought forward for development over the coming plan period. These have been submitted within the latest Strategic Housing Land Availability Assessment (SHLAA) call for sites.

17.8 Although the sites at these smaller settlements might not have the same capacity for development as those around the periphery of Truro, their potential to provide small scale development schemes that meet local housing and/or economic needs is no less significant to the local communities that live there. In these settlements it is locally made decisions about small scale development schemes that are of key importance and are crucial to the sustainability of those communities.

18.0 Policy PP7 – St Agnes and Perranporth CNA

SOUND The policy seeks to direct an appropriate level of growth to Perranporth

18.1 While the Tregothnan Estate does not support the overall reduction of housing numbers proposed for the county as a whole it is pleased to see that the Council has not sought to reduce the number of homes proposed for delivery within Perranporth. It is important that sufficient homes are delivered in order to meet the development needs of local people over the plan period.

18.2 The Tregothnan Estate has significant land holdings to the south and south west of Perranporth which adjoin the built up area of the settlement. There is an excellent opportunity to provide high quality mixed use development schemes on one or more of these sites which would help to meet local housing needs and provide new employment opportunities for local people. In this way it will be possible to reduce levels of out commuting to the larger centres outside of the CNA and to enhance levels of self containment. Those sites which are considered to be appropriate for future development have been submitted within the latest Strategic Housing Land Availability Assessment (SHLAA call for sites).



19.0 Policy PP9 – St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithial CNA


19.1 While the Tregothnan Estate does not support the overall reduction of housing numbers proposed for the county as a whole it is pleased to see the number of homes proposed for the China Clay CNA has actually risen from 800 to 1,400 over the plan period. This is entirely appropriate given the size and nature of settlements in the CNA which have the need and capacity for housing growth over the coming years. It is however important that future growth in housing is supported by sufficient employment development so as to reduce levels of outcommuting to larger centres of employment.

19.2 With significant land holdings in and around the settlements of St Dennis and Roche the Tregothnan Estate is well placed to meet local housing and employment needs by releasing areas of land for development. There is considered to be an excellent opportunity to meet local housing and/or economic needs through the provision of well designed and appropriately scaled housing and/or work premises. Such development would serve to enhance the sustainability of these villages and would also help to ensure the viability of services and facilities within neighbouring settlements. In both settlements the Estate’s land holdings adjoin the built form of the villages and so with sensitive design and layout it will be possible to provide development which not only meets local needs but which also safeguards and enhances their character and appearance. Those sites which are considered to have potential for development have been submitted within the latest Strategic Housing Land Availability Assessment (SHLAA) call for sites.


Appendix A

Completed representation forms

Local Plan – Strategic Policies Presubmission document representation form Please return to Cornwall Council by 5.00pm on 22 April 2013 Please complete a separate sheet for each representation you wish to make (All representations will become public)

1. Personal details. 2. Agent details (if applicable).

Name

Organisation Address line 1

Address line 2

Address line 3

Address line 4

Postcode

Telephone number Email address

The Tregothnan Estate

Steve Briggs Smiths Gore

York House

Blackbrook Business Park Taunton

Somerset

TA1 2PX


No comment

Q2. A local planning authority should submit a plan for examination which it considers to be ‘sound’ – namely that it is; positively prepared, justified, effective and is consistent with national policy. Do you consider the Plan has met these tests?

No



Q3. Please set out below any concerns you have with the Local Plan including any change(s) you consider necessary to address these concerns.

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

Please state which paragraph or policy your change refers to and specify the reasons below:

Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

Policy 1


SOUND:

This policy accords with paragraph 14 of the Framework which sets out the Government’s presumption in favour of sustainable development.



Policy 2


UNSOUND:

The housing target proposed does not seek to meet the full, objectively assessed needs of the county. It is therefore not positively prepared, is unjustified and inconsistent with national policy.



Policy 3


UNSOUND:

This strategy is overly reliant on the production of Neighbourhood Plans to deliver the required level of housing outside of the main settlements. This approach is considered to be unjustified and ineffective. The policy also fails to acknowledge the relationships that exist between smaller rural settlements.



Policy 5


UNSOUND

The policy should specifically identify livework units as a development to be supported. To not do so is contrary to planning policy.


form of national


Policy 5


UNSOUND

The policy should specifically identify livework units as a development to be supported. To not do so is contrary to planning policy.


form of national


Policy 6


SOUND

Subject to minor amendment to recognise issues surrounding development viability.



Policy 6


SOUND

Subject to minor amendment to recognise issues surrounding development viability.



Policy 7


UNSOUND

The policy should specifically support livework developments. To not do so is contrary to national policy.



Policy 8


SOUND

Subject to minor amendments to identify other affordable housing products which will be considered as part of the overall mix.



Policy 9


SOUND

This policy acknowledges the need to allow a certain amount of market housing as part of affordable housing led schemes where necessary to ensure developments are viable. This is consistent with the Framework.



Policy 11


SOUND

The approach advocated in this policy will ensure that developments will not be rendered undeliverable by affordable housing requirements.



Policy 14


UNSOUND

This policy is not sufficiently flexible to respond to issues of development viability. It is therefore contrary to national policy and could threaten the deliverability of the Local Plan’s development strategy.



Policy 24


UNSOUND

This policy does not properly reflect national guidance as set out in the Framework.



Policy 28


UNSOUND

The policy is not sufficiently flexible to take account of issues surrounding financial viability. It is therefore contrary to national policy.



Policy PP1


UNSOUND

The housing target proposed for the CNA does not seek to meet the full, objectively assessed needs of the CNA. It is therefore not positively prepared, is unjustified and inconsistent with national policy.



Policy PP3


SOUND

The policy seeks to direct an appropriate level of growth to the remainder of the CNA outside of Helston.



Policy PP6


UNSOUND

The housing target proposed for the CNA does not seek to meet the full, objectively assessed needs of Truro. It is therefore not positively prepared, unjustified and inconsistent with national policy.



Policy PP7


SOUND

The policy seeks to direct an appropriate level of growth to Perranporth.


Q4. Did you raise this issue earlier in the plan preparation process?

Yes

If yes, please specify at what stage:

The Core Strategy: Preferred Approach Stage


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

Yes


Completed forms should be submitted: by email to: [email protected] by post to: Cornwall Council Local Plans Team Carrick House St Clement Street Truro TR1 1EB

Please submit any views to Cornwall Council using the above methods by 5:00pm on 22 April 2013.

Next steps The representations received during this formal round of consultation will be reported to and considered by

the Council. Any significant changes will be consulted on prior to consideration by the planning inspectorate, who will appoint an inspector to conduct an examination in public.

Planning Team

Steve Briggs Taunton office 01823 445039 [email protected]

Ian Smith Peterborough office 01733 559320 [email protected]

Debbie Mackay Edinburgh office 0131 561 7117 [email protected]

Jo Robison Darlington office 01325 462966 [email protected]

Lee Scott Petworth office 01798 345971 [email protected]

Planning Services

Planning applications and statutory processes • Advice on strategy and approach • Site appraisals and development briefs • Preapplication and stakeholder negotiations • Community consultation • Preparation, coordination and submission of

planning applications • Planning appeals – written representations,

informal hearings and public inquiries • Planning agreements • Lawful development certificates • Enforcement matters

Rural planning projects • Alternative use assessments • Residential development and affordable housing

projects • Employment development • Agricultural and equestrian projects • Farm diversification • Barn conversions • Agricultural occupancy conditions • Tourism and leisure development • Conservation and historic buildings advice • Renewable energy and energy conservation • Rights of way






From: Hayhurst Neil Sent: 30 April 2014 10:19 To: EP&E Local Plan Subject: FW: WD/SH response to Cornwall Plan

Comments West Devon and South Hams District Council

From: Havers Steve Sent: 30 April 2014 10:15 To: Reeder Carol; Hayhurst Neil Subject: FW: WD/SH response to Cornwall Plan

From: Jo Perry [mailto Sent: 28 April 2014 15:32 To: Havers Steve; Grove-White Terry Cc: Webber Paul; Michelle Luscombe Subject: WD/SH response to Cornwall Plan

Dear Mr Grove‐White,

Many thanks for providing us with an opportunity to comment on the Cornwall Local plan.

West Devon previously commented on the draft plan in April 2013 at which time we raised some concerns about the proposed strategy for growth and the approach taken between setting housing numbers and job targets. We suggested that the plan could benefit from a greater acknowledgement of the evidence base used to inform the development strategy, in particular the joint SHMNA. In South Hams, whilst the authority does not adjoin any boundaries with Cornwall there are strategic implications in relation to the overall development strategy for the Plymouth HMA.

Since the publication of the draft plan we have regularly engaged with Cornwall and with all the Authorities in the Plymouth HMA. More recently we have met to discuss how we can continue to proactively and positively engage as we develop our housing strategies. As you will be aware both South Hams and West Devon are currently preparing new Plans and there is a need to ensure that our strategies for delivering growth seek to achieve a more coherent approach to the development strategy for the Plymouth HMA as a whole.

Given our recent discussions I would be grateful if you could accept this email as a holding response as we wish to share recent discussions with lead members before finalising our comments to send to you. I am hoping to be in touch with lead members during this week so hopefully this will not delay our response by too much.

I hope that this is acceptable approach. Please contact me should you wish to discuss this matter further.

Best wishes

Jo

Ms Jo Perry Strategic Planning Manager Planning, Economy and Community South Hams District Council and West Devon Borough Council

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_______________________________________________________________________

_______________________________________________________________________

Tel : 01822 813558

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Please reply to: Jo Perry Service: Strategic Planning Direct telephone: E-Mail: [email protected]

Mr T Grove-White Cornwall Council Carrick House Pydar Street Truro TR1 1EB

Our ref: WD/CP/03 14th May 2014

Dear Mr Grove-White,

Re: Cornwall Plan – Comments from West Devon Borough Council

Thank you for providing us with the opportunity to comment on the Cornwall Local Plan. These comments have been provided by Officers in response to the Proposed Submission document and are made in the context of ongoing discussions between our authorities as part of our Duty to Cooperate partnership across the Plymouth sub-region. We hope they are useful in helping you to finalise the plan for submission.

We commented previously on the draft plan in April 2013, at which time we raised concerns about the proposed strategy for growth and the inconsistent approach between the setting of housing numbers and job targets. In particular, we noted the potential implications on adjoining authorities such as West Devon of not planning effectively for the district’s objectively assessed housing requirements and queried the lack of evidence to support the job growth target of 50,000. We suggested that the plan could benefit from a greater acknowledgement of the evidence base used to inform the development strategy, including the joint SHMNA, and from providing more clarification as to how the objectively assessed housing need for the authority had been calculated.

Since then, through our Duty to Cooperate partnership, we have regularly engaged with Officers from Cornwall Council about the numbers and distribution of housing across the Plymouth HMA and the implications arising from each individual authorities strategy for growth.

As a result of these ongoing discussions and based on the latest consultation, we are pleased to see that the evidence provided in the most recent joint SHMNA (2013) has now been taken into consideration and we welcome the increase in housing numbers to bring them in line with the demographic projections contained within it.

In addition, we are pleased to note that the Proposed Submission document is now supported by the Cornwall and Isles of Scilly LEP target for increase in GVA which is more reflective of the economies of the area and seeks to achieve a growth in not only the quantity but quality of jobs.

We acknowledge that the demographic growth projections for Cornwall do not align themselves fully with the assumptions contained within the SHMNA around potential economic growth scenarios. However, as is the case for West Devon in the SHMNA, the demographic projections include ongoing assumptions around net migration which tend to be driven in the main by economic growth. We therefore accept that the proposed demographic-based figure has a built in allowance for some level of job increase created by net economic growth.

Overall, we consider that the current consultation on the Proposed Submission document has sought to address the concerns raised in our previous response. We welcome the opportunity to continue engaging with Cornwall as part of our Duty to Cooperate as we continue to develop our own plan and in a way which ensures that each authority is able to meet its own individual needs alongside a wider sub-regional strategy for growth and development across the Plymouth HMA.

We hope that the above comments are useful and look forward to working with you as you take forward the Cornwall Local Plan.

Yours sincerely,

Jo Perry Strategic Planning Manager West Devon Borough Council and South Hams District Council

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 Organisation

Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Preferred contact method

Mercian Developments Ltd and LondonMetric Property Plc

Email Post

Paul Newton Barton Willmore LLP

7 Soho Square London

W1D 3QB

Email X 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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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 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 information is required).

Yes No X


Yes No X

If Yes;


Please see the attached Statement, which provides detailed comments on the Plan.


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 X


Please see the attached Statement.

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


No comment.

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


Pages 6-7 (Vision & Objectives)




Policy 2




Policy 3




Page 14, paragraph 1.40




Policy 4




Page 17, paragraph 2.5




Policy 5




Policy 14




Policy 22




Policy 27




Page 84, paragraphs 12.2, 12.4




Page 85, Objectives AU1 and AU3, and paragraph 12.7




Page 86, Paragraph 12.9




Pages 88-90 (Development Strategy), paragraphs 12.22 to 12.35.




Policy PP9




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

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

X

Date 24th April 2014 Signature


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.

24th April 2014 19363/A3/PN

CORNWALL LOCAL PLAN STRATEGIC POLICIES – PROPOSED SUBMISSION DOCUMENT (MARCH 2014) REPRESENTATIONS BY MERCIAN DEVELOPMENTS LTD & LONDONMETRIC PROPERTY PLC

Introduction & Background

1. We act on behalf of Mercian Developments Ltd (Mercian) and LondonMetric Property Plc (LondonMetric) and have been instructed to submit representations in relation to the Proposed Submission version of the Cornwall Local Plan Strategic Policies DPD (previously the Cornwall Core Strategy). This follows previous submissions in relation to the Options Paper in April 2011, the Preferred Approach in March 2012 (both on behalf of Mercian) and the Pre-Submission Document in April 2013.

2. Mercian and LondonMetric are key stakeholders and investors in Cornwall and welcome the opportunity to continue to input into the evolution of the Local Plan.

3. Our representations deal with the overall approach of the Local Plan in terms of growth and strategic policies as well as focusing on specific Community Network Areas (CNA). For clarity, where the Proposed Submission Document remains unchanged from the Pre-Submission version, we re-iterate our support / objection to those policies.

Vision and Objectives

4. Mercian/LondonMetric support the Vision and Objectives of the Plan, in particular:

Theme 1 – Objective 1 to remove unnecessary barriers to jobs, business and investment through a positive policy framework;

Theme 1 – Objective 3 to provide and enhance retail provision with a regional and subregional status that adds to economic growth and provide opportunities to improve existing facilities for better economic performance.

Theme 2 – Objective 4 to meet housing need by providing for new homes over the plan period.

Theme 2 – Objective 5 to encourage jobs and homes locally to meet needs and support the role and function of local communities.

Theme 2 – Objective 6 to ensure the delivery of infrastructure to enable development to

benefit local communities. Theme 3 – Objective 7 to meet a wide range of local needs including housing, community,

social, retail and health facilities in order to improve quality of life and reduce social exclusion.

5. The Vision and Objectives are appropriate and provide a sound basis for the more detailed policies within the Local Plan. As we note later in these representations, we believe in some instances the detailed policies do not accord with the vision, objectives or other relevant policy documents and will therefore need to be recast in order for the Plan to be found Sound (as required by the NPPF paragraph 182).

Policy 2 – Key Targets and Spatial Strategy

6. Policy 2 sets out the Council’s key targets and spatial strategy for the Plan period and the aims to increase jobs and includes targets on provision of employment floorspace and new homes.

7. Mercian/LondonMetric supports the increase in housing provision over the Pre-Submission version and also support the addition of criterion 8 b) iii, which seeks to support economic regeneration in St Austell as a centre for retail.

8. Mercian/LondonMetric does however have a number of concerns over the policy as drafted. It is imperative in plan making, that local authorities should base their plans on adequate, up-to-date (our emphasis) and relevant evidence (Para 158 of the NPPF). In this respect, Policy 2 cannot be found Sound:

The NPPF requires (at paragraph 161) that local authorities should use their evidence base to assess the needs for land or floorspace for economic development, including both the quantitative need and qualitative need for all foreseeable types of economic activity over the plan period, including retail and leisure development. The Council commissioned GVA Grimley to undertake a Retail Study (November 2010) to identify future capacity for new retail floorspace over the plan period. However, the findings of the Study (which form an important element of the evidence base) are omitted from the Plan (both in Policy 2 and throughout the CNA policies). In order for the plan to be Sound, Policy 2 should be expanded to incorporate a new criterion detailing the retail capacity for additional retail floorspace as set out in the findings of the GVA Cornwall Retail Study.

Further, the GVA Cornwall Retail Study is now almost 4 years old and considered out-of-date in the context of its baseline assumptions and the changes to the retail landscape that have occurred across the County. Therefore, in line with the advice contained in the recently issued Planning Practice Guidance (Section 12, Paragraph 014, Reference ID: 12-01420140306) the evidence base should be kept up-to-date. If key studies are already reliant on data that is ‘a few years old’, they should be updated to reflect the most recent information available and if necessary the plan adjusted in light of this information. The GVA Cornwall Retail Study should be updated and the revised conclusions incorporated into the plan.

Under criterion 8 a number of regeneration opportunities are identified. Criterion 8 b) iii states that in the St Austell, St Blazey and China Clay Regeneration Area ‘small scale

exemplar development’ will be supported. This is the only mention of St Austell in Policy 2. This conflicts with the adopted St Austell, St Blazey and China Clay Regeneration Plan that seeks developments that are ‘sustainable, transformational, of a nature and scale that would bring about significant change for the better’. Policy 2 as drafted is inconsistent with the Regeneration Plan and should be amended. Reference to the need to regenerate St Austell should be a key thrust of the key targets and spatial strategy to reflect the Council’s corporate priority for the area (see paragraph 12.2, page 96).

Criterion c) seeks to grow Truro’s role as a retail alternative to major centres outside of Cornwall. Whilst it is recognised that Truro provides the largest retail centre within Cornwall, there is no evidence to suggest that it should be strengthened further. Indeed, in order to promote and deliver the sustainability objectives of the Plan, to reduce the need to travel and to accord more fully with the GVA Cornwall Retail Study, other centres should be targeted for growth. Importantly, as the largest town within Cornwall (by population) and given the aspirations of the Regeneration Plan (detailed above) St Austell should be specifically identified for growth and prioritised over other centres.

9. On the basis of the above comments, Policy 2 as drafted is not justified and cannot therefore be considered Sound.

Policy 3 – Role and Function of Places

10. Mercian/LondonMetric supports the identification of St Austell in Policy 3 as a ‘Main Town’, at the top of the development hierarchy. However, the proposed change from the Pre-submission version to the delivery of housing, retail and other uses being managed through a Site Allocations DPD or Neighbourhood Plan is not supported. The Policy should explicitly set out that the towns listed in Policy 3 (1.) are main towns and should identify them on the Key Diagram. The fact that they are ‘main towns’ is implicit in reading criterion 3 of Policy 3 and the fact that only small towns and villages are identified on the Key Diagram leads to unnecessary confusion. The Policy should explicitly state that these are the locations where development will be accommodated.

11. In addition, it is unclear why Threemilestone (Truro) is referred to in Policy 3 and Mercian/LondonMetric are concerned that this may provide some implicit policy support for further large scale retail development in that out-of-centre location. Clearly any proposals that come forward in that location would be required to demonstrate compliance with the sequential and impact (NPPF) tests.

Shopping, Services and Community Facilities

12. In order to be consistent with amended Policy 2 and the NPPF (paragraph 23 sixth bullet), paragraph 1.40 should be redrafted along the following lines:

“A sequential test will be required to assess potential edge and out of town Sites to accommodate retail developments. A threshold for impact testing will be identified for Cornwall’s main towns in the Allocations Development Plan Document and until this is produced, applications will be assessed against the National Planning Policy Framework shall provide the measure.”

13. There is no need to repeat the requirement to undertake a sequential assessment as this is set out in Policy 4 (below).

Policy 4 – Shopping, Services and Community Facilities

14. Policy 4 is supported in general, as it removes the inconsistencies with the NPPF set out in the Pre-submission version. However, it should be made explicit that the first sentence relates to incentre development.

General Policies

Policy 5 – Jobs and Skills

15. Policy 5 could be more usefully retitled ‘Economic Development’ rather than Jobs and Skills. The main thrust of the policy is to encourage appropriate economic development that will in turn stimulate overall economic growth, which is not limited solely to jobs and skills.

16. Mercian/LondonMetric supports the recognition and inclusion at paragraph 2.5 of jobs from ‘non-industrial’ sectors, including retail. However, the policy as drafted still fails to recognise the benefits of jobs and skills that can be generated by other forms of economic development including retail. This should be highlighted within the policy.

Policy 14 – Development Standards

17. Mercian/LondonMetric support the general aim of this policy. However, the policy should be reworded to allow flexibility for exceptions to the policy requirements on a case by case basis, which could otherwise affect the viability and delivery of future developments or when the benefits of a particular scheme may be balanced and outweigh the thrust of the policy.

Policy 22 – Best Use of Land and Existing Buildings

18. Mercian/LondonMetric support the general aim of this policy. However, the policy should be reworded to allow flexibility for exceptions to the policy requirements on a case by case basis. For example where the benefits of a particular scheme or development outweigh the loss of agricultural land or indeed where that land is no longer needed or is no longer viable for agricultural uses. It should also be recognised that elsewhere within the Local Plan it is noted that not all of the future development growth within Cornwall will be capable of being accommodated within existing settlements. There is a clear requirement for some greenfield release and the policy should be sufficiently flexible to allow this in appropriate circumstances.

Policy 27 – Transport and Accessibility

19. Policy 27 (criterion 3) seeks to locate developments which attract a proportionally larger number of people in the city and main towns or locations which are ‘highly’ accessible by public transport or areas which will be made ‘highly’ accessible by the development. Whilst Mercian/LondonMetric support the general thrust of the policy, the word ‘highly’ should be

deleted from criterion 3. The NPPF at paragraph 23 requires developments to be located in ‘accessible’ locations.

PP9 St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithiel Community Network Areas

20. As a general point the structure of this section, being split between a number of different and overlapping CNA areas is difficult to navigate and understand. It would benefit from further clarity.

21. Notwithstanding this concern, Mercian/LondonMetric support the acknowledgement (at paragraph 12.2) that it is the Council’s corporate priority to regenerate the St Austell area and that the context of PP9 should allow for the growth needs of St Austell to be accommodated and co-ordinated in areas adjacent to the town boundary, that reflect the limited options for growth within the town itself. For clarity, the word ‘housing’ should be deleted as Mercian/LondonMetric are of the very firm view that if the regeneration of the area is to be realised, it will be necessary to deliver more than solely housing development beyond the existing St Austell built up area (as acknowledged in paragraph 12.24).

22. Further, whilst the St Austell, St Blazey and China Clay Area Regeneration Plan is noted at paragraph 12.4, the Vision of the Regeneration Plan is not expressly set out. This is an important omission, as the Vision sets the framework to deliver the Council’s corporate priority. Importantly, developments should be ‘transformational’ and of a nature and scale that would bring about significant change for the better. This should be expressly noted in the Introduction section (most appropriately as an extension to paragraph 12.4).

St Austell and Mevagissey Community Network Area

23. Given the findings of the GVA Cornwall Retail Study and the amendments to Policy 2, the overall objectives for the CNA should be expanded to expressly refer to ‘retail’ under Objective AU1. In addition, Objective AU3 should expressly refer to ‘St Austell’ town centre, for the avoidance of doubt.

24. In addition, and in line with St Austell’s status as the largest town (by population) within Cornwall and its identification in Policy 3 as a ‘main’ town (at the top of the retail hierarchy), it should act as more than a ‘local’ service centre to the smaller settlements surrounding it. Indeed, it should act as the ‘main’ centre for the immediate and surrounding settlements. This should be clarified in paragraph 12.7.

25. It should also be noted that in line with the GVA Cornwall Retail Study, a key aspiration for the network area should be the provision of additional retail floorspace (both convenience and comparison). This should be included within paragraph 12.9.

Development Strategy

26. The development strategy for PP9 is set out in paragraphs 12.22 to 12.35 and Policy PP9.

27. Mercian/LondonMetric support the acknowledgment at paragraph 12.24 and 12.35 that the growth of St Austell is likely to occur on the edge of the current built up area of the town. This reflects the lack of appropriately scaled opportunities for housing and/or commercial development within the built up area of the town.

28. Mercian/LondonMetric also support the reference at 12.24 identifying a substantial need for additional retail floorspace in St Austell, including out-of-centre locations. As recognised elsewhere in the Plan, given the scale of the need this paragraph should be amended to reflect the requirement for this growth to be accommodated outside the existing settlement boundary. It is important that provision is made to accommodate the critical mass of floorspace needed to address the existing leakage of expenditure from St Austell and its catchment area.

29. In addition, the separate work undertaken to date in the Regeneration Plan has identified the significant growth potential that the area has, which can be delivered through transformational regeneration projects. Due to the scale of the change identified, we believe it would be appropriate that the Local Plan offers a clear framework for growth in terms of land use quantum and the specific areas where growth will be supported. This has been tested to date through the Regeneration Plan and whilst additional text at paragraph 12.33 refers to transformational proposals, this needs to be consistent with and explicitly refer to the Regeneration Plan to ensure consistency, conformity and certainty.

Policy PP9 St Austell and Mevagissey; China Clay; St Blazey, Fowey and Lostwithiel CNA’s

30. As currently drafted, Policy PP9 cannot be found sound on the basis that it is not positively prepared (as it does not objectively assess development and infrastructure requirements), cannot be justified (when considered against reasonable alternatives) and is not consistent with the NPPF. As such it should be significantly recast, in line with our comments below.

31. The introduction to the policy indicates that development will be permitted where it satisfies a number of priorities for the area. In relation to St Austell, it lists 4 criterion (a – d). Our comments in relation to each are set out below:

a) It is unclear how all (our emphasis) development can protect the vitality and viability of St Austell town centre. Some development will not have an effect on the town centre and other development may have an effect. However, the NPPF is clear that only where there is a ‘significant adverse impact’ (paragraph 27 of the NPPF) should proposals be refused. Criterion a) should be recast to be consistent with the NPPF.

b) The need to provide additional B1a and industrial space to generate new job opportunities is supported.

c) The increase in housing provision is supported. As noted elsewhere in the Plan, it should be recognised in the Policy that much of this will need to be met outside the existing settlement boundary.

d) It is unclear how all development can support the regeneration of St Austell town centre. Some development will not have an effect on the town centre and other development may

have an effect. However, the NPPF is clear that only where there is a ‘significant adverse impact’ (paragraph 27 of the NPPF) should proposals be refused. Criterion d) should be recast to ensure consistency with the NPPF.

32. In addition, and in line with our comments in relation to Policy 2, a further criterion should be added to set out the growth requirements for new retail development within the town, identified at paragraph 12.24. The NPPF requires (at paragraph 161) that local authorities should use their evidence base to assess the needs for land or floorspace for economic development, including both the qualitative need and qualitative need for all foreseeable types of economic activity over the plan period, including retail and leisure development. The Council commissioned GVA Grimley to undertake a Retail Study (November 2009) to identify future capacity for new retail floorspace over the plan period. However, whilst reference is made to capacity for additional retail floorspace at paragraph 12.24, aside from these figures, its findings (which form an important element of the evidence base) are omitted from the Plan (in Policy 2 and the CNA policies). In order for the plan to be sound, Policy PP9 should be expanded to incorporate a new criterion detailing the findings of the required update to the GVA Cornwall Retail Study.

33. Further, the policy continues by setting out a further set of criteria for development within the St Austell, St Blazey and China Clay Area Regeneration Area. This overlaps with the St Austell area (as detailed above) and sets a number of different priorities. It mirrors in part, some of the Vision of the Regeneration Plan (for the same area). It does however go further by identifying two sites for this purpose at West Carclaze/Baal and Par Docks. Both are residential schemes.

34. It is unclear why these two sites have been identified. No detailed justification is provided within the policy or the background evidence base. Should the policy seek to allocate sites, this should be consistent and to meet the strategic development needs of the area, including further residential and economic development (including retail). If this is not to be the case, the two residential allocations at West Carclaze/Baal and Par Docks should be deleted.

35. The policy then concludes that other sites for significant development will normally only be accepted where the site can deliver clear regeneration benefits and accord with ‘the above’. It is unclear what is meant by ‘the above’ – this should be clarified, but the thrust of this policy conflicts with the aspirations and Vision set out in the Regeneration Plan. The policy should be reworded to encourage large scale schemes that deliver transformational change to an area that is acknowledged as a corporate priority for regeneration.

36. It should also be noted that the Cornwall Local Plan Place-Based Topic Paper: St Austell Community Network Area (March 2013), which informs Policy PP9 contains a number of inconsistencies and inaccuracies that undermine the credibility and robustness of the policy position. This should be revisited in relation to the most up to date information available to the Council in order that the policy it informs has the ability to be found sound, without which it is not justified against the evidence base and is not positively prepared.

BARTON WILLMORE LLP

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Appendix 2: Cornwall Housing Provision Changes 2012-2014

Location Preferred Options (2012)

Pre Submission (2013)

Proposed Submission (2014)

Difference

Penzance / Newlyn 2150 1400 2150 0 West Penwith CNA residual

1100 1100 1000 -100

Hayle 2000 1300 1400 -600 St Ives-Carbis Bay 700 750 1000 +300 Hayle and St Ives CNA residual

200 350 350 +150

Helston 1100 900 900 -200 Helston and the Lizard CNA residual

900 900 1100 +200

CPR 6500 4000 4500 -2000

CPR CNA residual 500 500 800 +300

Falmouth-Penryn 3500 3200 2600 -900 Falmouth and Penryn CNA residual

500 800 500 0

Truro-Threemilestone-Shortlanesend

4500 2200 3000 -1500

Truro and Roseland CNA residual

700 800 900 +200

St Agnes and Perranporth CNA

1100 1100 1100 0

Newquay 3000 3000 3550 +550 Newquay and St Columb CNA residual

300 600 600 +300

Eco-community 5000 2300 2300 -2700 St Austell 1500 1700 2000 +500 St Austell CNA residual 250 300 300 +50 St Blazey, Fowey and Lostwithiel CNA

800 800 800 0

China Clay CNA 800 1400 1500 +700 Wadebridge 800 800 1000 +200 Wadebridge and Padstow CNA residual

700 900 1000 +300

Bodmin 1000 3000 3000 +2000 Bodmin CNA residual 250 200 200 -50 Camelford CNA 800 900 1200 +400 Bude-Stratton-Poughill 900 800 900 0 Bude CNA residual 350 450 600 +250 Launceston 1500 1100 1500 0 Launceston CNA residual

400 400 400 0

Liskeard 1250 1000 1250 0 Liskeard and Looe CNA residual

700 1000 1400 +700

Caradon CNA 800 1000 1000 +200 Saltash 1000 750 1000 0 Torpoint 0 300 350 +350 Cornwall Gateway CNA residual

450 250 350 -100

48,000 42,250 47,500 -500

Appendix 3: Cornwall Completions

Locations Permissions Description Penzance and West Penwith

Two consents over 50 dwellings which are older than five years and construction not started equating to 182 houses (08-1694 and 90/P/0668)

Hayle Hayle Harbour development dating back five years comprising 800 dwellings not started (08-0613)

Helston Land at Clodgey Lane and Falmouth Road dating back over ten years not started and comprising 134 dwellings (W2/88/01512).

CPR Six permissions of over 50 dwellings which are older than five years whereby construction has not started equating to 944 dwellings (W2/PA08/00496; W2/PA08/00610; W2/PA06/00352; W2/PA05/01703; W2/PA08/01940; and W2/PA07/01032)

Falmouth Two permissions of over 50 houses dating back over ten years which have not commenced equating to 160 dwellings (PA01/2266/08 and PA01/1382/07)

Truro One permission at Carvinack Farm of 110 houses which is over ten years old not commenced (PA01/2266/08). In addition, permission at Langarth Farm 1500 skewers housing delivery for the settlement when realistically without the two adjoining sites at Willow Green and Maiden Green will not deliver strategic infrastructure nor immediate housing.

Newquay Three permissions of over 50 dwellings which are older than five years and have not started equating to 469 dwellings in total (C2/07/01830; 08/01604; C2/08/01301). In addition, two historic Local Plan allocations at Trencreek Caravan Park and Newquay Growth area are included as Commitments despite no planning application ever been made on these sites.

Bodmin Three permissions of over 50 dwellings which are older than five years and have not started equating to 299 dwellings in total (E1/2008/0292; E1/2008/02363 and E1/2007/02507)

China Clay 113 historic allocated dwellings across four sites which have not had planning permission applied for.

Bude A 400 dwelling permission at Binhamy Road, Stratton which is over 5 years old has not commenced (E1/2008/02281)

Launceston A historic allocation on land to the south of Dutson Road (LAU1) for 72 dwellings has never been subject of a planning application.

Caradon A 155 dwelling development at land off A390, St Anns Chapel which is older than five years has not been started (E2/08/02275/OUT)

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Overall Housing Requirement

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Scenario Projected Economic Growth (jobs) (ref: figure 4.31 of the SHMNA)

Projected Households 2011-2031 (ref: figure 6.17 of the SHMNA)

Jobs to homes ratio

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Using the Experian ratio of 1:2, 47,500 dwellings would deliver around 23,275 new jobs.

Using the Cambridge Econometrics ratio of 1:1.7, 47,500 dwellings would deliver around 26,900 new jobs.

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2. Impact upon economy activity: Cag)%%j&jDaHl 8B)gjaVl %B5l H8Dl ^dEB)5l %B5&Dl ;j^^l d%%D&Hl H8Dl dHH5d&HjZDaDggl B%l kB5a;d^^l HBl

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Checks and Balances to the process

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Affordable Housing Requirement

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8B)gjaV jal H8Dl 8B)gjaVl?d5-DHl d5Dd/l dgl %d5l dgl jgl &BagjgHDaHl ;jH8l H8Dl "B^j&jDgl B%lKMMOAl l Cal H8dHl

&BaHD\H/l H8Dl %)^^>l BELD&HjZD^>l dggDggDcl d%%B5cdE^Dl 8B)gjaVl aDDcl %B5l kB5a;d^^l kB)a&j^l 8dgl EDDal

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D\"D&HdHjBaAl

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Recent Evidence Base Documents

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%B5&Dl;j^^ld%%D&HlH8DldHH5d&HjZDaDgglB%lkB5a;d^^lHBlD?"^B>D5gl"BHDaHjd^^>l%)5H8D5l&BagH5djajaVlV5B;H8l

jal 1NMl dacl ̂Dggl D?"^B>?DaHl jal kB5a;d^^l ;j^^l D\d&D5EdHDl dal ja&5DdgjaV^>l dVDjaVl "B")^dHjBa/l

")HHjaVl"5Dgg)5DlBal^B&d^lgD5Zj&Dgldacl%d&j^jHjDgA 8Dl5B^DlH8dHl8B)gDlE)j^cjaVl"^d>gljalH8DlD&BaB?>l

jalB5cD5lHBl8D^"lcD^jZD5ldacl&BaH5jE)HDlHB;d5cglH8DlcDgj5DclD&BaB?j&ldaclLBEl&5DdHjBalBELD&HjZDglB%l

H8Dl"^da 8dgld^gBlEDDalBZD5^BB-DcAl

4.4 8Dlja&BagjgHDa&>lEDH;DDalH8Dl;B5cjaVlB%lMB^j&>lJlHBlEBBgHlLBEgldaclH8Dld&H)d^lgH5dHDV>l;8j&8l%dj^gl

HBld&8jDZDlH8jgl"B^j&>ldg"j5dHjBaljgldl%)acd?DaHd^l%^d;gljalH8DlD%%D&HjZDlj?"^D?DaHdHjBalB%lH8Dl"^daAll

8Dld""5Bd&8l&daaBHlEDl L)gHj%jDcl;8Dal&BagjcD5DcldVdjagHl H8Dl"^daajaVlEd^da&DlHDgHglgDHlB)Hl jal

"d5dV5d"8l4hlB%lKMMOA

4.5 MB^j&>lJlB%lH8Dl"5B"BgDc g)E?jggjBalcB&)?DaHlgDD-g HBlcj5D&HlcDZD^B"?DaHlHBlgHj?)^dHDl"5BZjgjBal

B%laD;lLBEgldaclD&BaB?j&lV5B;H8Al CHljgl&BaHDacDclH8dHlH8Dl"B^j&>l"^d&DglHBBl?)&8lD?"8dgjglBal

H8Dl H5dcjHjBad^l )gDl &^dggDgl %B5l D?"^B>?DaHl W:4/l :T/l :=9l dacl H8D5D%B5Dl %dj^gl HBl 5D&BVajgDl H8Dl

E5BdcD5l cD%jajHjBal B%l D&BaB?j&l cDZD^B"?DaHl dgl "5Dg&5jEDcl E>l H8Dl O5d?D;B5-l V^Bggd5>l ;8j&8l

gHdHDg2

“' 1C1/H JD2?2A1�/2C59J72?2A1�/2C5&J HC A$DHC<J 5*1G2J-H5*HCJ 5*2J,J:G2JIAEGG2G&J�$3AH JECDJ

1//$CH5.J$G2GJECDJ/EHCJ51-CJ 2C5)2J$G2GJ=3$5J2@ A$DHC<J*1$GHC<JD2?2A1�/2C5+”

4.6 Cal H8jgl 5DVd5c/l jHl jgl &BagjcD5Dcl H8dHl "B^j&>l hl dacl "B^j&>l Jl g8B)^cl EDl ?D5VDcl HBl "5BZjcDl BaDl

&B?"5D8DagjZDldaclH5dag"d5DaHl"B^j&>l%B5lD&BaB?j&lcDZD^B"?DaHAl


MdVDl46

4.7 Ojad^^>/l H8Dl jaHDaHjBalB%lMB^j&>lJl HBlgd%DV)d5clD?"^B>?DaHl ^dacldaclE)j^cjaVgl jgl jalcj5D&Hl&Ba%^j&Hl

;jH8l "d5dV5d"8l TTl B%l H8Dl O5d?D;B5-l ;8j&8l 5DS)j5Dgl "^daajaVl "B^j&jDgl HBl dZBjcl H8Dl ^BaVl HD5?gl

"5BHD&HjBalB%lgjHDgld^^B&dHDcl%B5lD?"^B>?DaHl)gDAl

Test of Soundness: MB^j&>lJljglaBHl&BagjgHDaHlB5l^ja-Dcl;jH8lH8Dl;jcD5lgH5dHDVj&l8B)gjaVl"B^j&jDglB%l

H8Dl7B&d^lM^daldacljglH8D5D%B5DlaBHlL)gHj%jDc/lD%%D&HjZDlB5l"BgjHjZD^>l"5D"d5DcAlll

Policy 7 Housing in the Countryside

4.8 8Dl"B^j&>ldglc5d%HDcl;j^^l 5Dg)^Hl jaldlg8B5H`HD5?l&Ba%^j&Hl)aHj^l g)&8l Hj?Dldgl H8DlkKXgld5Dl %B5?d^^>l

dcB"HDcl jal "B^j&> dacl aD;l gDHH^D?DaHl EB)acd5jDgl dacl V5B;H8l d5Ddgl d5Dl jcDaHj%jDcl H85B)V8l

D?D5VjaVlKDjV8EB)58BBclM^dagldacl@jHDlX^^B&dHjBalNMNgAl Cal&dgDg/ldlKDjV8EB)58BBclM^dal?d>l

aBHl DZD5l 5Dd&8l dcB"HjBal dacl H8D5D%B5Dl aBl g"dHjd^l "B^j&jDgl %B5l H8dHl ^B&dHjBal d5Ddl dZdj^dE^DAl Cal

dccjHjBa/l jHl &B)^cl ^Ddcl HBl "5BE^D?gl %B5l d""^j&dHjBagl ;8j&8l d5Dl g)gHdjadE^Dl &B?jaVl %B5;d5cgl jal

dcZda&Dl B%l -D>l g"dHjd^l "^daajaVl dacl d^^B&dHjBal NMNgl ;8j&8l &B)^cl EDl L)cVDcl dgl &BaH5d5>l HBl

D?D5VjaVl MB^j&>l [l dgl H8Dl 5DZjgDcl EB)acd5jDgl 8dZDl aBHl >DHl EDDal dcB"HDcAl 8jgl %)5H8D5l

cD?BagH5dHDgl H8dHlE5Bdcl ^B&dHjBaglB%lV5B;H8ld5DlaDDcDcl;jH8jal H8Dl7B&d^lM^dal jal ^jaDl;jH8lKMMOl

;8j&8ld5Dl&)55DaH^>ldEgDaHA

Test of SoundnessPl 8DlM^daljglaBHlD%%D&HjZDldgl jHl %dj^gl HBlcD?BagH5dHDlcD^jZD5dEj^jH>lB%l jH’glV5B;H8l

dgg)?"HjBagljalH8DldEgDa&DlB%lgjHDld^^B&dHjBagldaclE5Bdcl^B&dHjBaglB%lV5B;H8All

Policy 8: Affordable Housing

4.9 KMMO ?d-DgljHl&^Dd5ldHl"d5dV5d"8lh[lH8dHl^B&d^l"^daajaVld)H8B5jHjDglg8B)^cl)gDlH8Dj5lDZjcDa&DlEdgDl

HBlDag)5DlH8dHlH8Dj5l7B&d^l"^dal?DDHglH8Dl%)^^/lBELD&HjZD^>ldggDggDclaDDcgl%B5l?d5-DHldacld%%B5cdE^Dl

8B)gjaV jal H8Dl 8B)gjaVl?d5-DHl d5Dd/l dgl %d5l dgl jgl &BagjgHDaHl ;jH8l H8Dl "B^j&jDgl B%lKMMOAl l Cal H8dHl

&BaHD\H/l H8Dl %)^^>l BELD&HjZD^>l dggDggDcl d%%B5cdE^Dl 8B)gjaVl aDDcl %B5l kB5a;d^^l kB)a&j^l 8dgl EDDal

jcDaHj%jDcl jal H8Dl %jV)5Dl[AhlB%l H8Dl@biKXldglT/ThRlc;D^^jaVgl"D5ldaa)?l;8j&8l jgl?dcDl)"lB%ldl

g)EgHdaHjd^lEd&-l^BVl"^)glaD;^>ld5jgjaVl)a?DHlaDDcAllll 8jgl&B?"d5Dgl;jH8lHBHd^l8B)gjaVlg)""^>ljal

H8DlD?D5VjaVl7B&d^lM^dalT/6[Jlc;D^^jaVl"D5ldaa)?All Bl%)^^>l?DDHlH8Dld%%B5cdE^Dl8B)gjaVlaDDcglB%l

kB5a;d^^/lgB?Dl�h$lB%ld^^laD;l8B)gjaVlE)j^Hl;B)^claDDclHBlEDld%%B5cdE^Dl;8j&8ljgldal)a5Dd^jgHj&l

D\"D&HdHjBaAl

4.10 8Dl"5Dcj&HDcl ^DZD^glB%ld%%B5cdE^Dl8B)gjaV gDHlB)Hl jalMB^j&>l= WJR$ljalIBaDl4ldaclTldaclhR$ljal

IBaDgl 6/l hl daclJ9l cBl aBHl?DDHl H8DlBELD&HjZD^>l dggDggDclaDDcl jal H8Dl &BaHD\Hl B%l H8Dl ^B;lBZD5d^^l

8B)gjaVlV5B;H8l^DZD^gl"5B"BgDclWh[/JRRlc;D^^jaVg9All

4.11 0S)d^^>/l H8D5Dl d5Dl &Ba&D5agl H8dHl DZDal dHl H8Dl ̂DZD^gl B%l JR$l dacl hR$l H8D5Dl d5Dl ̂j-D^>l HBl EDl

d%%B5cdEj^jH>ljgg)Dgl;jH8lcD^jZD5>AllCalB)5lD\"D5jDa&Dl;jH8l?da>l^d5VD`g&d^DlgjHDgld&5BgglkB5a;d^^ljgl


MdVDl4h

H8dHl dEaB5?d^l cDZD^B"?DaHl &BgHgl HDacl HBl EDl ?)&8l 8jV8D5l H8dal BH8D5l "d5Hgl B%l H8Dl gB)H8l ;DgHl

?d-jaVlH8DlcD^jZD5>lB%lH8DlhR$`JR$ld%%B5cdE^Dl8B)gjaVldlgjVaj%j&daHl&8d^^DaVDAlXgldl&BagDS)Da&D/l

H8DlZjdE^DlcD^jZD5>lB%lgjHDgl?d>l5Dg)^HljaldlaDVBHjdHDcl5Dc)&HjBaljald%%B5cdE^Dl8B)gjaVl"5BZjgjBalHBl

DadE^Dl cDZD^B"?DaHl HBl "5B&DDcl E)Hl HBl H8Dl cDH5j?DaHl B%l ?DDHjaVl H8Dl BELD&HjZD^>l dggDggDcl

d%%B5cdE^Dl8B)gjaVlaDDcA

4.12 Cal H8Dl&BaHD\HlB%lZjdEj^jH>lEDjaVldl ^j?jHjaVl%d&HB5/l H8Dl"^dal;B)^claBHlEDlD%%D&HjZDlj%l H8Dl"D5&DaHdVDl

5dHDl;D5Dlgj?"^>lja&5DdgDc/ldglH8jgl;B)^clEDl)a^j-D^>lHBl8dZDlda>lj?"d&Hl)"Bald&H)d^lcD^jZD5>ldacl

;B)^cl")g8l?B5DlgjHDgljaHBlZjdEj^jH>lHDgHjaVl;8j&8ljgldlHj?Dl&Bag)?jaVl"5B&DggAl

4.13 :>l &B?"d5jgBa/l dal ja&5DdgDl jal BZD5d^^l 8B)gjaVl "5BZjgjBal dHl H8Dl ^DZD^gl gDHl B)Hl E>l 0\"D5jdal B5l

kd?E5jcVDl 0&BaB?DH5j&l W5D%D55Dcl HBl dEBZD9l ;B)^cl cD^jZD5l EDH;DDal +/RRRl dacl �/RRRl dccjHjBal

d%%B5cdE^Dl8B)gDgldHldl"D5&DaHdVDl5dHDlB%lhR$A

4.14 CHljg d^gB )a&^Dd5l;8dHl;B5-l8dglEDDal)acD5Hd-DaljalHD5?glB%lHDgHjaVlZjdEj^jH>AlC%lZjdEj^jH>lB%lDZD5>lgjHDl

8dgl HBl EDl HDgHDcl HBl L)gHj%>l "5B"BgDcl ^DZD^gl B%l d%%B5cdE^Dl 8B)gjaV/l cD^jZD5>l B%l 8B)gjaVl ;j^^l EDl

gDZD5D^>l8d?"D5Dcldaclg^B;DcAl 8Dl"B^j&>l^d&-gl&^d5jH>ljalH8jgl5DVd5cAl

4.15 8Dl"B^j&>lgDD-gldl[R!6Rlg"^jHljalHD5?glB%l5DaHDc!jaHD5?DcjdHDAl 8Dl5D%D5Da&DlHBl5DaHDcl8B?Dgl%dj^gl

HBl?DaHjBalH8Dl"BHDaHjd^l%B5l‘d%%B5cdE^Dl5DaH’Al 8Dl"B^j&>laDDcglHBlEDld?DacDclHBlja&^)cDld^^B;da&Dl

%B5l‘d%%B5cdE^Dl5DaH’Al 8jgl;j^^lDa8da&DlH8DlcD^jZD5>lB%ld%%B5cdE^Dl8B?Dg

Test of SoundnessPl 1jZDal H8Dl dEgDa&Dl B%l ja%B5?dHjBa/l H8Dl M^dal %dj^jaVl HBl "5B"D5^>l &BagjcD5l

BELD&HjZD^>ldggDggDclaDDcgldaclH8Dl%dj^)5DlHBl)acD5gHdaclH8DlgB&jd^ldaclD&BaB?j&l&BagDS)Da&Dgl

B%laBHl^ja-jaVlH8DlcD^jZD5>lB%lLBEg/l?d5-DHldacld%%B5cdE^Dl8B)gjaVlH8DlMB^j&>ljglaBHlL)gHj%jDc daclaBHl

gB)acA

Policy 10: Publicly Owned Sites

4.16 M5D`g)E?jggjBal"B^j&>l 4Rl 5D^dHDgl HBl")E^j&^>l B;aDclgjHDg B5l gjHDgl;8j&8l;D5Dl"5DZjB)g^>l ")E^j&^>l

B;aDc/ dacl 5DS)j5Dgl dl 8jV8D5l Hd5VDHl B%l JR$l d%%B5cdE^Dl 8B)gjaVl jal 5DcDZD^B"?DaHl g&8D?Dgl %B5l

H8DgDlgjHDgAlbB;DZD5/lH8jgld""5Bd&8l%dj^glHBl5D&BVajgDlH8dHl")E^j&^>lB;aDclgjHDgl?)gHlcD^jZD5l‘EDgHl

Zd^)D’ljalcjg"Bgd^!5DcDZD^B"?DaHAl 8Dl5DS)j5D?DaHl%B5lEDgHlZd^)Dljgl&^Dd5^>ljalH8Dl")E^j&ljaHD5DgHldgl

H8Dl &d"jHd^l 5D&Dj"Hl VDaD5dHDcl jgl 5D`jaZDgHDcl jal H8Dl ")E^j&l ")5gDAl Xgl g)&8/l jHl jgl )a5DdgBadE^Dl HBl

5DgH5djal H8Dl "BHDaHjd^l Zd^)Dl B%l H8DgDl gjHDgl ;jH8l dl 8jV8D5l H8dal aB5?d^l d%%B5cdE^Dl 8B)gjaVl

5DS)j5D?DaHgAl 8Dl"B^j&>l;j^^ld^gBl?d-Dlg)&8l gjHDgl ^Dggl dHH5d&HjZDl HBl jaZDgHB5gl dacl?d>l 5Dg)^Hl jal

"5DZjB)g^>lcDZD^B"Dcl^daclgjHHjaVljc^DA

Test of SoundnessPl 8DlMB^j&>ljglaBHlH8Dl?BgHld""5B"5jdHDlgH5dHDV>lHBl8D^"lcD^jZD5l8B)gjaVlV5B;H8l

dacl)a^B&-l"5DZjB)g^>lcDZD^B"Dcl ^dacAl CHlcBDglaBHl"5B?BHDlg)gHdjadE^DlcDZD^B"?DaHldacl jglaBHl


MdVDl4J

H8Dl?BgHld""5B"5jdHDlgH5dHDV>l %B5l H8DlM^daAl CHl jgl H8D5D%B5DlaBHl L)gHj%jDclB5l&BagjgHDaHl;jH8ladHjBad^l

"B^j&>A

Policy 11: Managing Viability

4.17 8DlKMMOljglZD5>l&^Dd5ldHl"d5dV5d"8l4J6ldacl4[6lH8dHl")5g)jaVlg)gHdjadE^DlcDZD^B"?DaHl5DS)j5Dgl

&d5D%)^ldHHDaHjBalHBlZjdEj^jH>ldaclDag)5jaV H8Dlg&d^DlB%lBE^jVdHjBaglB5l"B^j&>l5DS)j5D?DaHgljglaBHlgBl

^d5VDlH8dHljHlH85DdHDaglH8DldEj^jH>l%B5ldl;j^^jaVl^daclB;aD5ldaclcDZD^B"D5lHBl?d-Dl&B?"DHjHjZDl5DH)5agAl

8DlgDS)DaHjd^ld""5Bd&8 dacl5DZjD;l"5B&DgglgHdHDclja MB^j&>l44ld""Dd5gl^dEB5jB)gldac ;j^^ &d)gDl

gjVaj%j&daHlcD^d>glHBlH8DlcD^jZD5>lB%lcDZD^B"?DaHg BalH8DlV5B)acAl l15DdHD5l %^D\jEj^jH>l jgl5DS)j5Dc jal

H8Dl"B^j&>lHBlDag)5DlcD^jZD5dEj^jH>ldaclHBld^^B;l&BagjgHDa&>l;jH8lMB^j&>l4[6Al

Test of SoundnessPl 8Dl ja%^D\jE^Dl adH)5Dl B%l MB^j&>l 44l ;j^^l 5DgH5j&Hl cD^jZD5dEj^jH>l B%l H8Dl V5B;H8l

BELD&HjZDglB%lH8Dl"^daAlCHljglH8D5D%B5DlaBHlL)gHj%jDcldVdjagHlH8Dl"5BZjgjBaglB%lMB^j&>l4=TlB%lH8DlKdHjBad^l

M^daajaVlMB^j&>lO5d?D;B5-Al

Policy 14: Development Standards

4.18 MB^j&>l4hlVBDglED>Bacl"^daajaV "B^j&> daclH8dHlE)j^cjaVl5DV)^dHjBaglg8B)^clHd-Dl"5jB5jH>l8D5DA 8Dl

MB^j&>l jgl dHl 5jg-l j%l adHjBad^l DaD5V>l gHdacd5cgl &8daVDAl 8Dl "B^j&>l d^gBl "5DgDaHgl &Ba%^j&Hl ;jH8l H8Dl

ZjdEj^jH>lB%lg&8D?DgAl 8Dl"B^j&>lH8D5D%B5DlaDDcglHBlEDl5D&BagjcD5Dcld&&B5cjaV^>A

Policy 22: Best Use of Land and Existing Buildings

4.19 MB^j&>l TTl ja&B55D&H^>l H8Dl jaHD5"5DHgl H8DlKMMO’gl"5BZjgjBaglBal H8Dl 5D`)gDlB%l "5DZjB)g^>l cDZD^B"Dcl

^dacAl f8D5Dl H8Dl KMMOl gHdHDgl H8Dl 5D`)gDl B%l "5DZjB)g^>l cDZD^B"Dcl ^dacl g8B)^cl EDl Da&B)5dVDc/l

7B&d^lM^dalMB^j&>lTTlgHdHDgljHlg8B)^clEDl"5jB5jHjgDcAl

Test of SoundnessPl MB^j&>l TTl jgl dal ja&B55D&Hl jaHD5"5DHdHjBal B%l adHjBad^l "B^j&>l dacl jgl H8D5D%B5Dl

gB)acAll


MdVDl4+

5 MB^j&>lMM+l 5)5Bldacl_BgD^daclkKXT

5.1 ,)5l&^jDaHgl^dacljaHD5DgHljglgjH)dHDcl;jH8jal‘MM+l 5)5Bldacl_BgD^daclkB??)ajH> KDH;B5-lX5Dd’A

5.2 5)5Bl jgl H8Dl ^d5VDgHl D?"^B>?DaHl 8)El jal kB5a;d^^l ;jH8l -D>l gD5Zj&D/l dc?jajgH5dHjZD/l 8Dd^H8l dacl

Dc)&dHjBad^l j?"B5Hda&Dl %B5l H8Dl kB)aH>Al l 8Dl &jH>l "5Bc)&Dgl 4[$l B%l H8Dl kB)aH>’gl 15Bggl 3d^)Dl

XccDcldacld&&B??BcdHDgl4h/RRRlcdj^>l&B??)HD5gl%B5l;B5-/l;8Bl&)55DaH^>l5DgjcDlB)HgjcDlH8Dl&jH>Al

8jglj?Ed^da&DlB%lV5DdHD5lD?"^B>?DaHlH8dal8B)gjaVldHl 5)5Bl)acD5^jaDglH8DlaDDcl%B5lD?"8dgjglB%l

gH5dHDVj&l 8B)gjaVl V5B;H8l dHl 5)5Bl jal B5cD5l HBl d^^B;l "DB"^Dl HBl ^jZDl dacl;B5-l jal H8Dl gd?Dl "^d&Dl

H8D5DE>l 5Dc)&jaVl H8Dl aDDcl HB H5dZD^l dacl Dag)5jaVl cDZD^B"?DaHl jgl &BagjgHDaHl ;jH8l H8Dl gB&jd^/l

D&BaB?j&ldaclDaZj5Ba?DaHd^lgH5dacglB%lg)gHdjadE^DlcDZD^B"?DaHAlllCal&BagjcD5jaVlH8Dlcj5D&HjBalB%l

gH5dHDVj&l8B)gjaVlV5B;H8ljalH8DlkB)aH>/l;DlcBl&BagjcD5lH8dHl 5)5Bl5D"5DgDaHglH8Dl?BgHlg)gHdjadE^Dl

gDHH^D?DaHl%B5lV5B;H8ldglH8Dldc?jajgH5dHjZDldaclD?"^B>?DaHl8)ElB%lH8DlkB)aH>ldacldglg)&8lg8B)^cl

d&&B??BcdHDlH8DlV5DdHDgHl^DZD^glB%lcDZD^B"?DaHAll

5.3 XglgH5DggDcljal@D&HjBal6lB%lH8jgl_D"B5H/lH8Dl8B)gjaVlcjgH5jE)HjBalgH5dHDV>ldgl&)55DaH^>l"5DgDaHDcljal

H8DlM5B"BgDcl@)E?jggjBal7B&d^lM^daljglaBHlgB)acAl@"D&j%j&d^^>/lH8Dl"5BZjgjBalB%lL)gHl6RRRlc;D^^jaVgl

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CORNWALL LOCAL PLAN

PRE-SUBMISSION DOCUMENT MARCH 2013

CONSULTATION REPRESENTATIONS ON BEHALF OF

LXB GROUP

HIGHER NEWHAM, TRURO

APRIL 2013

127 Hampton Road, Redland

Bristol

BS6 6JE

6162

Typewritten Text

595

CONTENTS

1. Introduction 1

2. General Approach and Strategy of the Pre-submission Document 2

3. Comments on Key Policies 3

- Policy 2: Key Targets and Spatial Strategy

- Policy 3: Role and Function of Places

- Policy 5: Jobs and Skills

- Policy PP6: Truro and Roseland Community Network Area

- Policy 7: Housing in the Countryside

- Policy 8: Affordable Housing

- Policy 11: Managing Viability

- Policy 14: Development Standards

- Policy 20: Strategic Waste Management Principles

Appendix 1: Higher Site Plan

Version: 0.1

Author: CF

Checked: HS

Director: CD

2

Pre-submission Document - March 2013

07-007-P

1. Introduction 1.1 These representations to the Cornwall Local Plan ‘Pre-submission Document’

consultation are made by Origin3 on behalf of LXB Plc in respect of its strategic land

interests at Higher Newham, Truro. A site plan is enclosed at Appendix 1. The site is

located within the Truro and Roseland Community Network Area of the Local Plan

Pre-submission Document.

1.2 These representations consider the soundness of the pre-submission document based

on the criteria set out in paragraph 182 of the National Planning Policy Framework (the

Framework) summarised as follows:

The plan should be positively prepared based on a strategy that seeks to meet

objectively assessed development and infrastructure requirements, including

unmet requirements from neighbouring authorities where it is reasonable to do

so and consistent with achieving sustainable development

The plan should be justified as the most appropriate strategy when considered

against the reasonable alternatives, based on proportionate evidence

The plan should be effective in terms of it being deliverable over its period and

based on effective joint working on cross-boundary strategic priorities; and

The plan should be consistent with national policy (enabling the delivery of

sustainable development in accordance with the policies in the framework.

1.3 The promotion site at Higher Newham extends to approximately 62 hectares and is

situated to the south of the Truro, A390, approximately 0.5 miles from the city centre.

The site is currently used for agricultural purposes.

1.4 Origin3 submit that the pre-submission document does not make adequate provision

for housing needs across the County as a whole nor does it propose sufficient strategic

growth appropriate to the role of Truro as the principal settlement in the county.

1.5 Truro is recognised in the Council’s evidence base as the largest settlement in Cornwall

and the principal employment, shopping and transport hub. The city also has a well

documented shortage of housing and in particular a severe affordable housing

1


07-007-P

deficiency. These representations outline Truro as the most sustainable location for

accommodating new growth in Cornwall, holding the greatest need for strategic new

development.

1.6 Land at Higher Newham provides a logical and sustainable strategic development

extension to the city.

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07-007-P

2. General Approach of the Pre-submission Document

2.1 The general approach of the Pre-submission Document as set out on page 7 is

considered inconsistent with the plan making policies of the Framework and therefore

un-sound in its current format.

2.2 The approach sets out broad locations for development without providing any

indication of site allocations. Paragraph 157 of the Framework sets out crucial objectives

of local plans including to ‘allocate sites to promote development and flexible use of land,

bringing forward new land where necessary, and provide detail on form, scale, access and

quantum of development where appropriate’. The pre-submission document fails to carry

out this requirement and it is therefore inconsistent with the Framework and thus

unsound.

2.3 The Pre-submission Document relies upon the preparation of Neighbourhood Plans,

other Development Plan Documents which have yet to be specified, as well as

supplementary planning documents and ‘a range of site specific and thematic plans’ in

order to provide a comprehensive set of development control policies for the County.

We consider that this fragmented approach which requires numerous additional

documents to supplement the pre-submission document, is contrary to paragraph 153

of the Framework which states that ‘any additional documents should only used where

clearly justified’.

2.4 In consideration of the above, the pre-submission document should be amended to

include site specific allocations with site location plans for strategic growth sites in the

County. Whilst it is recognised that a definitive County wide schedule of allocations may

be a difficult exercise for the pre-submission document, it should at least identify large

scale strategic allocations which should be identified with regard to a robust evidence

base including landscape and sustainability appraisals. Without such amendments, the

pre-submission document is considered inconsistent with the Framework. Paragraph 47

of the Framework requires the preparation of local plans which meet the full objectively

assessed needs of the area, ‘including identifying key sites which are critical to the delivery of

the housing strategy over the plan period’.

2.5 The acknowledgement of the Framework’s requirement for a presumption in favour of

sustainable development in Policy 1of the Pre-submission Document is supported.

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3. Comments on Key Policies

Policy 2: Key Targets and Spatial Strategy

3.1 In general, our client supports the ‘Spatial Strategy’ for dispersed development in a

manner which is proportional to sustainability credentials of settlements. However,

Policy 2 fails to distinguish Truro City as the principal settlement in the County and its

strategic role in accommodating proportionate development growth. The Policy is

intended to provide spatial strategy to help direct development in the County, yet it fails

to highlight Truro’s role in accommodating large scale strategic development alongside

the principal towns and proportionate development in lower order settlements,

including villages.

3.2 As demonstrated below, the growth target identified in Policy 2 for 42,250 homes is

wholly inadequate and the plan is thus unsound as it has not been positively prepared

based on a strategy that seeks to meet objectively assessed development.

3.3 In addition, this inadequate growth target is inconsistent with paragraph 47 of the

Framework which requires local planning authorities to “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‚.

3.4 The Council adopted the growth target of 42,250 homes for the pre-submission

document against officer recommendation at a full council meeting 12 February 2013. In

short, the growth target in the pre-submission document has no evidence base to

support or justify it.

3.5 The Regional Spatial Strategy for the South West (RSS) had not been issued in its final

form when the incoming Government of 2010 announced its intention to abolish

regional strategies. Since the RSS preparation process in the South West had not been

completed, the draft RSS fell immediately; however the evidence base which informed it

remains relevant given that it was independently examined in public and having regards

to recent Government advice. The evidence base of the previously emerging RSS has

also been endorsed by various appeal Inspectors across the south-west as a reliable

source of estimating housing growth requirements in the absence of more up-to-date

and tested data. The draft RSS following examination in public and panel

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07-007-P

recommendations implied a housing growth requirement in Cornwall for the period

2006 to 2026 of 68,700 dwellings. By comparison to this scrutinised growth figure, the

pre-submission document growth target of 42,250 dwellings is hugely deficient.

3.6 Notwithstanding the above, it is recognised that the draft RSS growth target emerged

with regard to 2003 household projections. Therefore, in order to obtain a more up-to-

date indication of the objectively assessed needs of the county, more recent household

projections should be considered. In this regard, the 2008 household projections

indicated growth of 59,030 households for the period between 2006-2026 (plus 5% for

vacancies, second homes and concealed households). It is therefore unequivocal by

comparison with the most up-to-date household projections; the pre-submission

document growth target of 42,250 dwellings remains hugely deficient.

3.7 The inadequacy of the pre-submission document growth target is further emphasised by

reference to housing need in the County. The Council’s Strategic Housing Market

Assessment 2010 (SHMA) identified current housing need at 8,075 dwellings and future

estimated annual housing need of 1,853 dwellings. On the basis of a plan period to

2026, the housing need in Cornwall can therefore be estimated as follows:

8,075 (existing need at 2010) + (16 x 1,853 (the annual estimate over the plan

period)) = 37,723 dwellings

3.8 In consideration of the above, it is clear that increased provision for market housing

needs to be made in order to ensure the delivery of affordable homes to meet the

identified need.

3.9 The pre-submission document should be amended to set out a higher housing growth

requirement for the plan period which represents the objectively assessed needs of the

county. Origin3 contend that the currently proposed target figure falls considerably short

of the actual growth requirement, as indicated by draft RSS and 2008 household

projections.

3.10 Whilst the pre-submission document appears to focus development at the existing main

Cornwall urban centres, it falls short of indicating strategic site allocations.

Notwithstanding that, the focus of growth in and around the main towns is considered

to represent the most appropriate and sustainable growth strategy for the County.

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Policy 3: Role and Function of Places

3.11 Truro should accommodate significant development growth being the principal

settlement and the most viable location for development in the county. Indeed, as

identified in the Preferred Option Core Strategy, the city produces 17% of the County’s

Gross Value Added and accommodates 14,000 daily commuters for work, who

currently reside outside the city. This imbalance of greater employment than housing at

Truro underlines the need for emphasis of strategic housing growth at Truro in order to

allow people to live and work in the same place thereby reducing the need to travel and

ensuring development is consistent with the social, economic and environmental strands

of sustainable development.

3.12 The Council’s own evidence base including ‘Place Based Issues Paper’, the ‘Growth

Factors’ evidence paper and the ‘Cornwall Towns Study’ highlights Truro as the outright

largest settlement in the County with the need and capability for future development

here. Truro’s strategic role as a sub-regional centre, and its capability of accommodating

future growth, was also highlighted in the draft Regional Spatial Strategy for the

Southwest, RPG10, the Carrick Core Strategy and the Cornwall County Structure Plan.

3.13 In this context, policy 3 of the pre-submission document fails to place sufficient emphasis

on Truro and the most sustainable settlement for accommodating strategic growth in

the County and is therefore unsound.

3.14 Table 1 of the pre-submission documents sets out broad locations for development

within the Community Network Areas. Notwithstanding, the inadequacies of the overall

housing growth target in the pre-submission document, it is evident that the strategic

role of Truro and the largest employment and service centre in the County is not

recognised by the distributions of growth set out in Table 1. The table indicates that

significantly higher levels of growth are intended for Newquay, Bodmin, Falmouth-

Penryn and Cambourne-Pool-Redruth than that proposed for Truro. It is contended

that the broad locations and growth targets for the Community Network Areas as set

out in Table 1, do not represent an appropriate distribution of housing growth with

regard to the economic and strategic role of Truro where greater development should

be focused. In this context, the pre-submission document strategy for growth and

distribution is neither, justified or effective as required by paragraph 182 of the

Framework. It follows that the policies are therefore unsound.

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3.15 In respect of the completion and commitment figures provided in Table 1, it is not clear

what these are. For example, are commitments previous plan allocations or sites with

permissions? The pre-submission document needs to provide clarity with definitions of

completions and commitments in this regard.


3.16 Policy 5 of the pre-submission document along with the table set out on page 20 of the

document seek to direct development to stimulate provision of new jobs and economic

growth. It is contended that the policy places too much emphasis on the traditional use

classes for employment (B1, B2, B8) and therefore fails to recognise the broader

definition of economic development as prescribed by the Framework glossary which

states;

“Economic development: Development, including those within the B Use Classes,

public and community uses and main town centre uses (but excluding housing

development)‚

3.17 In this regard, it is considered that policy 4 and policy 5 should be merged to provide

one comprehensive and transparent policy for economic development.

3.18 Furthermore, the intention of Policy 5 to safeguard employment land and buildings is in

direct conflict with paragraph 22 of the Framework which requires planning policies to

avoid the long terms protection of sites allocated for employment use.

3.19 Pre-submission Policy 5 also fails to recognise the strategic role of Truro City as the

economic hub of the county. As highlighted above, the Council’s own evidence

(Preferred Option Core Strategy) indicated that Truro city produces 17% of the

County’s Gross Value Added and accommodates 14,000 daily commuters for work,

who currently reside outside the city. Such statistics highlight the principal economic role

of Truro in the County which needs to be recognised in Policy 5.

3.20 On this basis of the above, policy 5 is considered inconsistent with the framework and is

therefore unsound.

3.21 The pre-submission document seeks to deliver over 50,000 jobs in the plan period. This

objective is supported. However, the policy needs to recognise the strong links between

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economic development and housing growth. The Government paper ‘Laying the

Foundations: A Housing Strategy for England’ (November 2011) sets out the dependency

and relationship of economic growth and housing development:-

“Housing is inextricably linked to the wider health of the economy, the financial markets

and consumer confidence. The current challenging economic and financial circumstances

make action on housing even more important – both to tackle immediate pressures now

and to lay the foundations for stronger growth and stability in the future.

Getting house building moving again is crucial for economic growth – housing has a direct

impact on economic output, averaging 3 per cent of GDP in the last decade. For every new

home built, up to two new jobs are created for a year. Without building new homes our

economic recovery will take longer than it needs to. The construction workforce has fallen

from 2.35 million just before the credit crunch to 2.1 million today and is likely to have

been mostly in house building. This 10 per cent fall is around four times greater than the

decline in the overall workforce.‚

3.22 This underlines the need to make provision for increased housing development in order

to help deliver and contribute towards the desired economic and job creation

objectives of the plan.

3.23 The pre-submission document seeks to promote growth of Cornwall’s marine sector

which is considered ‘critical to the region’s future’. In this context, increased housing

provision is required to enable the economic and job growth objectives.

3.24 It is unclear what is meant by ‘economic performance’ as referred to in the sixth

paragraph. A definition needs to be provided.

Policy PP6: Truro and Roseland Community Network Area

3.25 Our clients land interest is situated within ‘PP6 Truro and Roseland Community

Network Area’.

3.26 Policy PP6 suggests that 2,200 dwellings should be delivered at Truro within this

Community Network Area (CNA). This represents a significant reduction from the

previously proposed 4,500 dwellings as indicated in the Core Strategy Preferred Option.

There is no justification or evidence base to support this reduced provision for Truro

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and thus conflicts with the requirements of the Framework. Origin3 submitted

representations to the Core Strategy Preferred Option questioning whether 4,500

dwellings was sufficient provision for Truro given the relevant evidence base. The now

proposed growth figure of 2,200 dwellings is considered wholly inadequate for Truro

and the policy is therefore unsound.

3.27 Looking at the relevant evidence base associated with pre-submission document, the

Council’s ‘Population and Household Change’ evidence base document (January 2011)

outlines substantial increases in the household projections in Truro up to 2031 indicating

that approximately 7,000 new homes will be required. Origin3 contend that the pre-

submission document should make provision for growth of approximately 7,000

dwellings at Truro in order to be considered sound in relation to the Framework

requirement for the plan to meet the full and objectively assessed needs of the area.

3.28 The general accuracy the January 2011 household projections is underlined by the draft

RSS which was prepared through an extensive and robust evidence gathering process.

Draft RSS directed 6,400 new dwellings to be provided at Truro. It is clear that the pre-

submission document requirement of only 2,200 dwelling at Truro is wholly unjustified

and completely inadequate with regard to the objectively assessed needs of the area.

3.29 In addition, the Council’s SHMA (2010) estimates a current need for 10,480 dwellings in

Carrick, where Truro is located and would be the likely location to absorb this growth. It

is clear that the level proposed in the pre-submission document (2,200 houses) is wholly

inadequate and not in conformity with the Council’s own evidence base. As such the

pre-submission document is considered unsound with regard to the requirements of the

Framework.

3.30 Furthermore, Policy PP6 fails to recognise the significant housing need in Truro deriving

from its strategic role in the County and the very high levels of in-commuting to the city.

Ironically, policy PP6 seeks to reduce the ‘need to travel through the creation of balanced

communities’ but fails to direct sufficient housing growth in Truro in order to address the

current imbalance of housing and jobs that results in circa 14,000 daily commuters

travelling into the city for work. The release of land for development at Higher Newham

can make a sustainable and valuable contribution in helping to provide a more balanced

provision of housing and employment at Truro.

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3.31 Policy PP6 also fails to set out policies and a strategy for delivering necessary housing. In

particular it fails to identify preferred broad locations and specific sites that will enable

continuous delivery of housing in the CNA for at least 15 years from the point of

adoption.

3.32 PP6 outlines the need to support sustainable transport solutions for Truro and to

reduce congestion. We consider that a likely source for investment towards improving

transport infrastructure is through planning contributions derived from strategic

development. Thus new development enables this policy objective. New strategic

development which meets the objectively assessed needs of the areas has not been

properly planned for in the pre-submission document and as such a clear strategy

identifying how necessary infrastructure objectives of the Plan will be achieved is

required.

3.33 Truro is the largest employment hub in Cornwall with key service, administrative, health

and educational importance for the County. Overall, Policy PP6 does not place a strong

enough emphasis on the future economic function of Truro, instead diminishing it. This

approach will hamper economic growth in the County. There is a lack of recognition of

the imbalance between employment and housing in Truro with a need to reduce in-

commuting and encourage sustainable living through housing delivery. In considering the

direction of strategic housing growth in the county, we do consider that Truro

represents the most sustainable settlement for growth and as such should

accommodate the greatest levels of development.

3.34 In light of the above, the pre-submission document does not meet the objectively

assessed needs of Truro and the Community Network Area and is therefore

inconsistent with the requirements of the Framework and is this unsound.

Policy 7: Housing in the Countryside

3.35 The policy as drafted results will result in a short-term conflict until such time as the

CNAs are formally adopted in policy. For example, if an application is submitted now it

could be judged as contrary to emerging policy 7 as the revised boundaries have not yet

been adopted. Clarity on what approach the Council will take in this scenario is required

or revision to the wording of the policy.

10


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3.36 The policy requires the levels of affordable housing on each site to be tested against

viability to be set out in supplementary guidance. However, it is unclear what work has

been undertaken in terms of testing viability. If viability of every site has to be tested to

justify proposed levels of affordable housing, delivery of housing will be severely

hampered and slowed. The policy lacks clarity in this regard.

3.37 The policy seeks a 70/30 split in terms of rented/intermediate. The reference to rented

homes fails to mention the potential for ‘affordable rent’. The policy needs to be

amended to include allowance for ‘affordable rent’. This will enhance the delivery of

affordable homes.


3.38 With regard to the sequential approach taken in order to review schemes to help

ensure the viability to deliver affordable housing, the first priority to review design is

considered weak. Value achieved from design review of housing developments is

considered minimal. Furthermore, this process of review appears laborious and cause

significant delays to the delivery of units on the ground. Greater flexibility is required,

for example S106 obligations should be re-visited.


3.39 It is considered that policy 14 goes beyond planning and that building regulations should

take priority here. The policy also presents conflict with the viability of schemes. The

policy therefore needs to be reconsidered accordingly.

Policy 20: Strategic Waste Management Principles

3.40 This pre-submission policy goes beyond NPPF. The NPPF is clear on requirement in this

regard. It is therefore considered that this issue should be left to national policy and

policy 20 is not required.

Conclusion of Key Policies

3.41 In summary, we raise the following key concerns with the Preferred Approach Paper:

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The document ignores the evidence base, particularly in relation to housing

growth and does not meet objectively assessed needs.

There is no plan or strategy for how growth will exactly be delivered.

Not enough emphasis is placed on the economic role of Truro for Cornwall.

There is no evidence to support the reduced housing growth requirement for

Truro.

The imbalance at Truro between employment and housing is not recognised in

striving towards sustainable development and reduction in the need to travel

with the unjustified and low housing growth target for Truro.

The pre-submission document is not consistent with the requirements of the

Framework and is therefore un-sound in its current form. The plan should

identify the main strategic sites in each settlement that will be required in order

to ensure that housing supply is provided. This will require there to be an

analysis of the merits of different sites and locations. Our view is that land at

Higher Newham is ideally suited to development, is sustainable and should be

identified for strategic residential development over the plan period.

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Appendix 1: Higher Newham Site Plan

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A

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Q

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t

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Chyvela

h Road

LEGEND

Governs Farm

Willow Green

Total Site Area

(excluding bridleway to west)

Area ~ 28.19ha / 69.66ac

A390

CLIENT ISSUED BY

Willow Green Farm Ltd

O3

DRAFT

DRAWING TITLE DRAWN BY

O3

REVISION

Site Application Boundary

-

DRAWING NUMBER CHECKED BY

005

DATE STATUS

09/10/2013 FOR SUBMISSION

therichardspartnership

1:1250 @ A0 / 1:2500 @ A2

m 25 50 75 100 125

Appendix 2: Cornwall Housing Provision Changes 2012-2014

Location Preferred Options (2012)

Pre Submission (2013)

Proposed Submission (2014)

Difference

Penzance / Newlyn 2150 1400 2150 0 West Penwith CNA residual

1100 1100 1000 -100

Hayle 2000 1300 1400 -600 St Ives-Carbis Bay 700 750 1000 +300 Hayle and St Ives CNA residual

200 350 350 +150

Helston 1100 900 900 -200 Helston and the Lizard CNA residual

900 900 1100 +200

CPR 6500 4000 4500 -2000

CPR CNA residual 500 500 800 +300

Falmouth-Penryn 3500 3200 2600 -900 Falmouth and Penryn CNA residual

500 800 500 0

Truro-Threemilestone-Shortlanesend

4500 2200 3000 -1500

Truro and Roseland CNA residual

700 800 900 +200

St Agnes and Perranporth CNA

1100 1100 1100 0

Newquay 3000 3000 3550 +550 Newquay and St Columb CNA residual

300 600 600 +300

Eco-community 5000 2300 2300 -2700 St Austell 1500 1700 2000 +500 St Austell CNA residual 250 300 300 +50 St Blazey, Fowey and Lostwithiel CNA

800 800 800 0

China Clay CNA 800 1400 1500 +700 Wadebridge 800 800 1000 +200 Wadebridge and Padstow CNA residual

700 900 1000 +300

Bodmin 1000 3000 3000 +2000 Bodmin CNA residual 250 200 200 -50 Camelford CNA 800 900 1200 +400 Bude-Stratton-Poughill 900 800 900 0 Bude CNA residual 350 450 600 +250 Launceston 1500 1100 1500 0 Launceston CNA residual

400 400 400 0

Liskeard 1250 1000 1250 0 Liskeard and Looe CNA residual

700 1000 1400 +700

Caradon CNA 800 1000 1000 +200 Saltash 1000 750 1000 0 Torpoint 0 300 350 +350 Cornwall Gateway CNA residual

450 250 350 -100

48,000 42,250 47,500 -500

Appendix 3: Cornwall Completions

Locations Permissions Description Penzance and West Penwith

Two consents over 50 dwellings which are older than five years and construction not started equating to 182 houses (08-1694 and 90/P/0668)

Hayle Hayle Harbour development dating back five years comprising 800 dwellings not started (08-0613)

Helston Land at Clodgey Lane and Falmouth Road dating back over ten years not started and comprising 134 dwellings (W2/88/01512).

CPR Six permissions of over 50 dwellings which are older than five years whereby construction has not started equating to 944 dwellings (W2/PA08/00496; W2/PA08/00610; W2/PA06/00352; W2/PA05/01703; W2/PA08/01940; and W2/PA07/01032)

Falmouth Two permissions of over 50 houses dating back over ten years which have not commenced equating to 160 dwellings (PA01/2266/08 and PA01/1382/07)

Truro One permission at Carvinack Farm of 110 houses which is over ten years old not commenced (PA01/2266/08). In addition, permission at Langarth Farm 1500 skewers housing delivery for the settlement when realistically without the two adjoining sites at Willow Green and Maiden Green will not deliver strategic infrastructure nor immediate housing.

Newquay Three permissions of over 50 dwellings which are older than five years and have not started equating to 469 dwellings in total (C2/07/01830; 08/01604; C2/08/01301). In addition, two historic Local Plan allocations at Trencreek Caravan Park and Newquay Growth area are included as Commitments despite no planning application ever been made on these sites.

Bodmin Three permissions of over 50 dwellings which are older than five years and have not started equating to 299 dwellings in total (E1/2008/0292; E1/2008/02363 and E1/2007/02507)

China Clay 113 historic allocated dwellings across four sites which have not had planning permission applied for.

Bude A 400 dwelling permission at Binhamy Road, Stratton which is over 5 years old has not commenced (E1/2008/02281)

Launceston A historic allocation on land to the south of Dutson Road (LAU1) for 72 dwellings has never been subject of a planning application.

Caradon A 155 dwelling development at land off A390, St Anns Chapel which is older than five years has not been started (E2/08/02275/OUT)

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Scenario Projected Economic Growth (jobs) (ref: figure 4.31 of the SHMNA)

Projected Households 2011-2031 (ref: figure 6.17 of the SHMNA)

Jobs to homes ratio

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Using the Experian ratio of 1:2, 47,500 dwellings would deliver around 23,275 new jobs.

Using the Cambridge Econometrics ratio of 1:1.7, 47,500 dwellings would deliver around 26,900 new jobs.

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1. Impact upon housing provision: @8B)]bk G8Dk D&B`B?>k&B`Gi`)Dk GBkU5B;/k G8ifk;i]]k "]c&Dk)`5Dc]ifGi&k "5Dff)5Dk B`k G8Dk ]B&c]k

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7Dffk 8B)fiÙk &8Bi&Dk %B5k G8BfDk G5>iÙk GBk 5D]B&cGDk ;iG8i`k jB5`;c]]k cfk ck 5Df)]Gk B%k `D;k D?"]B>?D`GA

0YD`kU5DcGD5k"5Dff)5DkB`kG8Dk`DDbk%B5kc%%B5bcE]Dk8B)fiÙk;8i&8kc]5Dcb>kD[&DDbfk�Q$kB%k G8DkGBGc]kc``)c]k8B)fiÙkbD]iYD5>k%B5kG8DkjB)`G>kVcfkfDGkB)Gki`kG8Dk@ahJWkc`bkD?D5UiÙk ]B&c]k"]c`9A

2. Impact upon economy activity: C`f)%%i&iD`Gk 8B)fiÙk %B5k G8Dk ]cEB)5k %B5&Dk ;i]]k c%%D&Gk G8Dk cGG5c&GiYD`Dffk B%k jB5`;c]]k GBk

D?"]B>D5fk"BGD`Gic]]>k%)5G8D5k&B`fG5ciìÙkU5B;G8ki`k1MLA


LcUDk6

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Checks and Balances to the process

2.10 )5ìÙk GBk G8Dk &8D&-fk c`bk Ec]c`&Dfk i`k G8Dk "5B&Dffk B%k bDGD5?iìÙk 8B)fiÙk `DDb/k G8Dk ;ibD5k

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G8Dk%B]]B;iÙO

49 W%%B5bcE]Dk8B)fiÙk5DR)i5D?D`GA

S9 ^D&D`GkDYibD`&DkEcfDki`&])biÙk,J@k"5BKD&GiB`fkc`bk^@kEc&-U5B)`bk;B5-A

Affordable Housing Requirement

2.11 JLLN ?c-DfkiGk&]Dc5kcGk"c5cU5c"8kgZkG8cG ]B&c]k"]c`ìÙkc)G8B5iGiDfkf8B)]bk)fDkG8Di5kDYibD`&DkEcfDk

GBkD`f)5DkG8cGkG8Di5k7B&c]kL]c`k?DDGfkG8Dk%)]]/kBEKD&GiYD]>kcffDffDbk`DDbfk%B5k?c5-DGkc`bkc%%B5bcE]Dk

8B)fiÙ i`k G8Dk 8B)fiÙk?c5-DGk c5Dc/k cfk %c5k cfk ifk &B`fifGD`Gk ;iG8k G8Dk "B]i&iDfk B%kJLLNAk k C`k G8cGk

&B`GD[G/k G8Dk %)]]>k BEKD&GiYD]>k cffDffDbk c%%B5bcE]Dk 8B)fiÙk `DDbk %B5k jB5`;c]]k jB)`&i]k 8cfk EDD`k

ibD`Gi%iDbk i`k G8Dk %iU)5DkZAgkB%k G8Dk@ahJWkcfkS/SgQkb;D]]iÙfk"D5kc``)?k;8i&8k ifk?cbDk)"kB%kck

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D["D&GcGiBÀk

2.12 8Dk"5Dbi&GDbk]DYD]f B%kc%%B5bcE]Dk8B)fiÙkVIQ$ki`kHB`Dk4kc`bkSkc`bkgQ$ki`kHB`Dfk6/kgkc`bkI9kbBk

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"5B"BfDbkVgZ/IQQkb;D]]iÙf9Akk

2.13 0R)c]]>/k G8D5Dk c5Dk &B`&D5`fk G8cGk DYD`k cGk G8Dk ]DYD]fk B% IQ$k c`bk gQ$k G8D5Dk c5Dk ]i-D]>k GBk EDk

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G8DkBEKD&GiYD]>kcffDffDbkc%%B5bcE]Dk8B)fiÙk`DDbA

2.14 8ifk f)UUDfGfk G8Dk "B]i&>k fGc`&Dk B%k G8Dk D?D5UiÙk "]c`k bBDfk `BGk 8D]"k GBk ?DDGk G8Dk BEKD&GiYD]>k

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;B)]bk`BGkEDkD%%D&GiYDk i%k G8Dk"D5&D`GcUDk5cGDk;D5Dkfi?"]>k i`&5DcfDb/kcfkG8ifk;B)]bkEDk)`]i-D]>k GBk


LcUDkg

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Gi?Dk&B`f)?iÙk"5B&DffAk

2.15 :>k &B?"c5ifB`/k c`k i`&5DcfDk i`k BYD5c]]k 8B)fiÙk "5BYifiB`k cGk G8Dk ]DYD]fk fDGk B)Gk E>k 0["D5ic`k B5k

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c%%B5bcE]Dk8B)fDfkcGkck"D5&D`GcUDk5cGDkB%kgQ$A

2.16 Wfkck&8D&-ki`kG8Dk"5B&DffkB%kbDGD5?iìÙkG8Dk5iU8Gk8B)fiÙk5DR)i5D?D`G/kG8ifkbD?B`fG5cGDfkc`BG8D5k

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Recent Evidence Base Documents

2.17 0[c?iìÙk Yc5iB)fk BG8D5k i`bi&cGB5fk %5B?k 8B)fD8B]bk "5BKD&GiB`k GBk jB5`;c]]k EcfDbk 8B)fiÙk

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DYD`k;8D`k&B?"c5Dbk;iG8kMj71k"5BKD&GiB`fkVfDDkGcE]DkED]B;9Akk

Housing Requirement Houses Mj71kLB")]cGiB`kL5BKD&GiB`fkVSQQ=9kSQ4Q_SQ6Q9 I�/Q6Q jjk‘LB")]cGiB`kc`bkaB)fD8B]bkj8cÙD’kVSQ4Q9k Z+/+=+ jjk B;`fk@G)b>kVSQQI9kVSQQ4_SQS+9 ZQ/QQQ L]c`ìÙkN)G)5DkjB5`;c]]kVNDEkSQ449 6=/QQQkV7B;

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2.18 CGkc""Dc5fkG8cGk"]c`ìÙk%B5kck]B;kU5B;G8k]DYD]kifkck"B]i&>k&8Bi&Dk?cbDkE>kjB5`;c]]kjB)`&i]kc`bkG8Dk

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fiUì%i&c`Gkc`bkcbYD5fDA

2.19 Lc5cU5c"8k 4gk B%k JLLN/k ;8i&8k fDGfk B)Gk G8Dk1BYD5`?D`G’fk "5Df)?"GiB`k i`k %cYB)5k B%k f)fGci`cE]Dk

bDYD]B"?D`G/k?c-DfkiGk&]Dc5kVi`kG8Dk&B`GD[GkB%k"]c`k?c-iÙ9kG8cGO

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LcUDkI

2.20 Wfk&c`kEDkfDD`k%5B?kG8DkcEBYDkGcE]D/kE>k&8BBfiÙkGBk"]c`k%B5kck]B;k8B)fiÙkU5B;G8k]DYD]kVgZ/IQQk

b;D]]iÙf9/k G8Dk D?D5UiÙk "]c`k bBDfk ̀ BGk ?DDGk BEKD&GiYD]>k cffDffDbk ̀ DDbfk ;iG8k c`>k %B5?k B%k

%]D[iEi]iG>Ak k1iYD`k G8cGk iGk 8cfk Gc-D`kck`)?ED5k B% >Dc5fk GBkUDGk GBk G8ifk "Bi`Gk i`k G8Dk"]c`k"5D"c5cGiB`k

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ck?Dc`fkB%kcbb5DffiÙkck%ci])5DkGBk"5B"D5]>k"]c`k%5B?kG8DkB)GfDGA

2.21 C`k5Df"B`fDkGBkG8Dk%i5fGk&cYDcGki`k"c5cU5c"8k4gkB%kJLLN/kG8D5Dkc5Dk`BkfiUì%i&c`GkcbYD5fDkD%%D&GfkB%k

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2.22 C`k5Df"B`fDkGBkG8DkfD&B`bk&cYDcGki`k"c5cU5c"8k4gkB%kJLLN/kCGkifkc]fBk5DcfB`cE]DkGBk&B`&])bDkG8cGk

G8D5Dkifkf)%%i&iD`Gk]c`bk;iG8i`kG8DkjB)`G>kGBk]i?iGkbDYD]B"?D`Gk;8D5Dk"B]i&iDfkB%kG8DkJLLNkf)UUDfGkiGk

f8B)]bkEDk5DfG5i&GDbAkkjD5Gci`]>kcfkG8DkbifG5iE)GiB`kB%kbDYD]B"?D`Gk8cfk&8cÙDbkBYD5kG8Dk]i%DkB%kG8Dk

D?D5UiÙk"]c`/kG8D5Dk8cYDkEDD`kck`)?ED5kB%k]B&cGiB`f ;8D5DkcbbiGiB`c]kU5B;G8k8cfkf)UUDfGDbkE)Gk

c""Dc5fkGBkEDk8cYDkEDD`k5Db)&DbkB`kG8DkEcfifkG8cGkiGkifk`BGk`DDbDbA

Phasing of Housing Delivery

2.23 8D5Dk &B`Gi`)Dfk GBk EDk ]iGG]Dk DYibD`&Dk B%k "8cfiÙk B5k 8B;k G8Dk I/k 4Qk c`bk 4Ik >Dc5k 5DR)i5D?D`Gfk B%k

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Ecfif/kE)GkbD%i&iD`&iDfk&c`kB`]>kEDk?DGk;iG8i`k G8DkjJWk;8D5Dk G8D>kD[ifGAk kJLLNkbBDfk`BGk?c-Dk

f)&8k ck G>"Dk B%k bifGi`&GiB`k i`k "c5cU5c"8k gZAk k N)5G8D5?B5D/k "c5cU5c"8k gZk `DDbfk GBk EDk 5Dcbk i`k

&B`K)`&GiB`k;iG8k"c5cU5c"8kg�k;8i&8kD["]ci`fkG8cGk8B)fiÙk"B]i&iDfkf8B)]bkEDk&B`fibD5DbkB)Gk%B5k

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2.24 M)DkGBkG8Dk]c&-kB%kc`>k"8cfiÙk"B]i&iDfk;8i&8kfDGkB)GkG8Dk5DR)i5D?D`GfkB%kI/k4Qkc`bk4Ik>Dc5f/kiGkifk

)`&]Dc5k 8B;k G8Dk jB)`&i]k ifk i`GD`biÙk GBk cbb5Dffk G8Dk I$k B5k SQ$k E)%%D5k 5DR)i5Dbk i`k JLLNAk k 8Dk

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LcUDk+

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Lc5cU5c"8kgZkB%kJLLNA

Tests of Soundness

2.25 eiG8k 5DUc5bk GBk G8DkBYD5c]]k8B)fiÙk 5DR)i5D?D`Gkc`bk G8Dk GDfGfkB%kfB)`b`DffkfDGkB)Gk i`k"c5cU5c"8k

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JLLNA

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Distribution Strategy

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Comments

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Spatial Planning

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LcUDk44

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Test of Soundness and Proposed Policy Modifications:

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LcUDk4S

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Policy 4: Shopping, Services and Communuity Facilities; and


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LcUDk46

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Test of Soundness: LB]i&>kIkifk`BGk&B`fifGD`GkB5k]i`-Dbk;iG8kG8Dk;ibD5kfG5cGDUi&k8B)fiÙk"B]i&iDfkB%k

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Policy 7 Housing in the Countryside

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Test of SoundnessOk 8DkL]c`kifk`BGkD%%D&GiYDkcfk iGk %ci]fk GBkbD?B`fG5cGDkbD]iYD5cEi]iG>kB%k iG’fkU5B;G8k

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8B)fiÙkU5B;G8k]DYD]fk"5B"BfDbkVgZ/IQQkb;D]]iÙf9Akk

4.11 0R)c]]>/k G8D5Dk c5Dk &B`&D5`fk G8cGk DYD`k cGk G8Dk ]DYD]fk B%k IQ$k c`bk gQ$k G8D5Dk c5Dk ]i-D]>k GBk EDk

c%%B5bcEi]iG>kiff)Dfk;iG8kbD]iYD5>AkkC`kB)5kD["D5iD`&Dk;iG8k?c`>k]c5UD_f&c]DkfiGDfkc&5BffkjB5`;c]]kifk


LcUDk4g

G8cGk cE`B5?c]k bDYD]B"?D`Gk &BfGfk GD`bk GBk EDk ?)&8k 8iU8D5k G8c`k BG8D5k "c5Gfk B%k G8Dk fB)G8k ;DfGk

?c-iÙkG8DkbD]iYD5>kB%kG8DkgQ$_IQ$kc%%B5bcE]Dk8B)fiÙkckfiUì%i&c`Gk&8c]]DÙDAkWfkck&B`fDR)D`&D/k

G8DkYicE]DkbD]iYD5>kB%kfiGDfk?c>k5Df)]Gki`kck`DUBGicGDbk5Db)&GiB`ki`kc%%B5bcE]Dk8B)fiÙk"5BYifiB`kGBk

D`cE]Dk bDYD]B"?D`Gk GBk "5B&DDbk E)Gk GBk G8Dk bDG5i?D`Gk B%k ?DDGiÙk G8Dk BEKD&GiYD]>k cffDffDbk

c%%B5bcE]Dk8B)fiÙk`DDbA

4.12 C`k G8Dk&B`GD[GkB%kYicEi]iG>kEDiÙkck ]i?iGiÙk%c&GB5/k G8Dk"]c`k;B)]bk`BGkEDkD%%D&GiYDki%k G8Dk"D5&D`GcUDk

5cGDk;D5Dkfi?"]>ki`&5DcfDb/kcfkG8ifk;B)]bkEDk)`]i-D]>kGBk8cYDkc`>ki?"c&Gk)"B`kc&G)c]kbD]iYD5>kc`bk

;B)]bk")f8k?B5DkfiGDfki`GBkYicEi]iG>kGDfGiÙk;8i&8kifkckGi?Dk&B`f)?iÙk"5B&DffAk

4.13 :>k &B?"c5ifB`/k c`k i`&5DcfDk i`k BYD5c]]k 8B)fiÙk "5BYifiB`k cGk G8Dk ]DYD]fk fDGk B)Gk E>k 0["D5ic`k B5k

jc?E5ibUDk 0&B`B?DG5i&k V5D%D55Dbk GBk cEBYD9k ;B)]bk bD]iYD5k EDG;DD`k +/QQQk c`bk �/QQQk cbbiGiB`k

c%%B5bcE]Dk8B)fDfkcGkck"D5&D`GcUDk5cGDkB%kgQ$A

4.14 CGkif c]fB )`&]Dc5k;8cGk;B5-k8cfkEDD`k)`bD5Gc-D`ki`kGD5?fkB%kGDfGiÙkYicEi]iG>AkC%kYicEi]iG>kB%kDYD5>kfiGDk

8cfk GBk EDk GDfGDbk GBk K)fGi%>k "5B"BfDbk ]DYD]fk B%k c%%B5bcE]Dk 8B)fiÙ/k bD]iYD5>k B%k 8B)fiÙk ;i]]k EDk

fDYD5D]>k8c?"D5Dbkc`bkf]B;DbAk 8Dk"B]i&>k]c&-fk&]c5iG>ki`kG8ifk5DUc5bAk

4.15 8Dk"B]i&>kfDD-fkckZQ!6Qkf"]iGki`kGD5?fkB%k5D`GDb!i`GD5?DbicGDA 8Dk5D%D5D`&DkGBk5D`GDbk8B?Dfk%ci]fk

GBk?D`GiB`kG8Dk"BGD`Gic]k%B5k‘c%%B5bcE]Dk5D`G’Ak 8Dk"B]i&>k`DDbfkGBkEDkc?D`bDbkGBki`&])bDkc]]B;c`&Dk

%B5k‘c%%B5bcE]Dk5D`G’Ak 8ifk;i]]kD`8c`&DkG8DkbD]iYD5>kB%kc%%B5bcE]Dk8B?Df

Test of SoundnessOk 1iYD`k G8Dk cEfD`&Dk B%k i`%B5?cGiB`/k G8Dk L]c`k %ci]iÙk GBk "5B"D5]>k &B`fibD5k

BEKD&GiYD]>kcffDffDbk`DDbfkc`bkG8Dk%ci])5DkGBk)`bD5fGc`bkG8DkfB&ic]kc`bkD&B`B?i&k&B`fDR)D`&Dfk

B%k`BGk]i`-iÙkG8DkbD]iYD5>kB%kKBEf/k?c5-DGkc`bkc%%B5bcE]Dk8B)fiÙkG8DkLB]i&>kifk`BGkK)fGi%iDb c`bk`BGk

fB)`bA

Policy 10: Publicly Owned Sites

4.16 L5D_f)E?iffiB`k"B]i&>k 4Qk 5D]cGDfk GBk")E]i&]>k B;`DbkfiGDf B5k fiGDfk;8i&8k;D5Dk"5DYiB)f]>k ")E]i&]>k

B;`Db/ c`bk 5DR)i5Dfk ck 8iU8D5k Gc5UDGk B%k IQ$k c%%B5bcE]Dk 8B)fiÙk i`k 5DbDYD]B"?D`Gk f&8D?Dfk %B5k

G8DfDkfiGDfAkaB;DYD5/kG8ifkc""5Bc&8k%ci]fkGBk5D&BUìfDkG8cGk")E]i&]>kB;`DbkfiGDfk?)fGkbD]iYD5k‘EDfGk

Yc])D’ki`kbif"Bfc]!5DbDYD]B"?D`GAk 8Dk5DR)i5D?D`Gk%B5kEDfGkYc])Dkifk&]Dc5]>ki`kG8Dk")E]i&ki`GD5DfGkcfk

G8Dk &c"iGc]k 5D&Di"Gk UD`D5cGDbk ifk 5D_i`YDfGDbk i`k G8Dk ")E]i&k ")5fDAk Wfk f)&8/k iGk ifk )`5DcfB`cE]Dk GBk

5DfG5ci`k G8Dk "BGD`Gic]k Yc])Dk B%k G8DfDk fiGDfk ;iG8k ck 8iU8D5k G8c`k ̀ B5?c]k c%%B5bcE]Dk 8B)fiÙk

5DR)i5D?D`GfAk 8Dk"B]i&>k;i]]kc]fBk?c-Dkf)&8k fiGDfk ]Dffk cGG5c&GiYDk GBk i`YDfGB5fk c`bk?c>k 5Df)]Gk i`k

"5DYiB)f]>kbDYD]B"Dbk]c`bkfiGGiÙkib]DA

Test of SoundnessOk 8DkLB]i&>kifk`BGkG8Dk?BfGkc""5B"5icGDkfG5cGDU>kGBk8D]"kbD]iYD5k8B)fiÙkU5B;G8k

c`bk)`]B&-k"5DYiB)f]>kbDYD]B"Dbk ]c`bAk CGkbBDfk`BGk"5B?BGDkf)fGci`cE]DkbDYD]B"?D`Gkc`bk ifk`BGk


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G8Dk?BfGkc""5B"5icGDkfG5cGDU>k %B5k G8DkL]cÀk CGk ifk G8D5D%B5Dk`BGk K)fGi%iDbkB5k&B`fifGD`Gk;iG8k`cGiB`c]k

"B]i&>A


4.17 8DkJLLNkifkYD5>k&]Dc5kcGk"c5cU5c"8k4I6kc`bk4Z6kG8cGk")5f)iÙkf)fGci`cE]DkbDYD]B"?D`Gk5DR)i5Dfk

&c5D%)]kcGGD`GiB`kGBkYicEi]iG>kc`bkD`f)5iÙkG8Dkf&c]DkB%kBE]iUcGiB`fkB5k"B]i&>k5DR)i5D?D`Gfkifk`BGkfBk

]c5UDkG8cGkiGkG85DcGD`fkG8DkcEi]iG>k%B5kck;i]]iÙk]c`bkB;`D5kc`bkbDYD]B"D5kGBk?c-Dk&B?"DGiGiYDk5DG)5`fAk

8DkfDR)D`Gic]kc""5Bc&8 c`bk5DYiD;k"5B&DffkfGcGDbki` LB]i&>k44kc""Dc5fk]cEB5iB)fkc`b ;i]] &c)fDk

fiUì%i&c`GkbD]c>fkGBkG8DkbD]iYD5>kB%kbDYD]B"?D`Gf B`kG8DkU5B)`bAk k15DcGD5k %]D[iEi]iG>k ifk5DR)i5Db i`k

G8Dk"B]i&>kGBkD`f)5DkbD]iYD5cEi]iG>kc`bkGBkc]]B;k&B`fifGD`&>k;iG8kLB]i&>k4Z6Ak

Test of SoundnessOk 8Dk i`%]D[iE]Dk ̀ cG)5Dk B%k LB]i&>k 44k ;i]]k 5DfG5i&Gk bD]iYD5cEi]iG>k B%k G8Dk U5B;G8k

BEKD&GiYDfkB%kG8Dk"]cÀkCGkifkG8D5D%B5Dk`BGkK)fGi%iDbkcUci`fGkG8Dk"5BYifiB`fkB%kLB]i&>k4=SkB%kG8DkJcGiB`c]k

L]c`ìÙkLB]i&>kN5c?D;B5-Ak


4.18 LB]i&>k4gkUBDfkED>B`bk"]c`ìÙ "B]i&> c`bkG8cGkE)i]biÙk5DU)]cGiB`fkf8B)]bkGc-Dk"5iB5iG>k8D5DA 8Dk

LB]i&>k ifk cGk 5if-k i%k `cGiB`c]k D`D5U>k fGc`bc5bfk &8cÙDAk 8Dk "B]i&>k c]fBk "5DfD`Gfk &B`%]i&Gk ;iG8k G8Dk

YicEi]iG>kB%kf&8D?DfAk 8Dk"B]i&>kG8D5D%B5Dk`DDbfkGBkEDk5D&B`fibD5Dbkc&&B5biÙ]>A

Policy 22: Best Use of Land and Existing Buildings

4.19 LB]i&>k SSk i`&B55D&G]>k G8Dk i`GD5"5DGfk G8DkJLLN’fk"5BYifiB`fkB`k G8Dk 5D_)fDkB%k "5DYiB)f]>k bDYD]B"Dbk

]c`bAk e8D5Dk G8Dk JLLNk fGcGDfk G8Dk 5D_)fDk B%k "5DYiB)f]>k bDYD]B"Dbk ]c`bk f8B)]bk EDk D`&B)5cUDb/k

7B&c]kL]c`kLB]i&>kSSkfGcGDfkiGkf8B)]bkEDk"5iB5iGifDbAk

Test of SoundnessOk LB]i&>k SSk ifk c`k i`&B55D&Gk i`GD5"5DGcGiB`k B%k `cGiB`c]k "B]i&>k c`bk ifk G8D5D%B5Dk

fB)`bAkk


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5.2 5)5Bk ifk G8Dk ]c5UDfGk D?"]B>?D`Gk 8)Ek i`k jB5`;c]]k ;iG8k -D>k fD5Yi&D/k cb?iìfG5cGiYD/k 8Dc]G8k c`bk

Db)&cGiB`c]k i?"B5Gc`&Dk %B5k G8Dk jB)`G>Ak k 8Dk &iG>k "5Bb)&Dfk 4Z$k B%k G8Dk jB)`G>’fk 15Bffk 3c])Dk

WbbDbkc`bkc&&B??BbcGDfk4g/QQQkbci]>k&B??)GD5fk%B5k;B5-/k;8Bk&)55D`G]>k5DfibDkB)GfibDkG8Dk&iG>Ak

8ifki?Ec]c`&DkB%kU5DcGD5kD?"]B>?D`GkG8c`k8B)fiÙkcGk 5)5Bk)`bD5]i`DfkG8Dk`DDbk%B5kD?"8cfifkB%k

fG5cGDUi&k 8B)fiÙk U5B;G8k cGk 5)5Bk i`k B5bD5k GBk c]]B;k "DB"]Dk GBk ]iYDk c`bk;B5-k i`k G8Dk fc?Dk "]c&Dk

G8D5DE>k 5Db)&iÙk G8Dk `DDbk GBk G5cYD]k c`bk D`f)5iÙk bDYD]B"?D`Gk ifk &B`fifGD`Gk ;iG8k G8Dk fB&ic]/k

D&B`B?i&kc`bkD`Yi5B`?D`Gc]kfG5c`bfkB%kf)fGci`cE]DkbDYD]B"?D`GAkkkC`k&B`fibD5iÙkG8Dkbi5D&GiB`kB%k

fG5cGDUi&k8B)fiÙkU5B;G8ki`kG8DkjB)`G>/k;DkbBk&B`fibD5kG8cGk 5)5Bk5D"5DfD`GfkG8Dk?BfGkf)fGci`cE]Dk

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i`bi&cGDbki`kG8DkjB5Dk@G5cGDU>kL5D%D55Dbk,"GiB` VSQ4S9Ak 8D5Dkifk`BkK)fGi%i&cGiB`kB5kDYibD`&DkEcfDkGBk

f)""B5Gk G8ifk 5Db)&Dbk "5BYifiB`k %B5k 5)5Bk c`bk G8)f c &B`%]i&G D[ifGfk;iG8 G8Dk 5DR)i5D?D`Gfk B%k G8Dk

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`B;k"5B"BfDbkU5B;G8k %iU)5Dk B%k 6QQQkb;D]]iÙfk ifk&B`fibD5Dbk;8B]]>k i`cbDR)cGDk %B5k 5)5BkLB]i&>k

LL+ ifkG8D5D%B5Dk)`fB)`bAk

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G8DkjB)`G>kc`bk G8DkYD5>k8iU8k ]DYD]fkB%k i`_&B??)GiÙk GBk G8Dk&iG>Ak k C5Bì&c]]>/k"B]i&>kLL+kfDD-fk GBk

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G8cGk5Df)]Gfki`k&i5&ck4g/QQQkbci]>k&B??)GD5fkG5cYD]]iÙki`GBkG8Dk&iG>k%B5k;B5-Ak

5.6 ,)5k &]iD`Gfk "5B"Bfc]fk cGkei]]B;k15DD`k bD]iYD5k `DDbDbk8B)fiÙ/k i`&])biÙk c%%B5bcE]Dk 8B)fiÙkcfk

;D]]k cfk `D;k fG5cGDUi&k fB&ic]k c`bk "8>fi&c]k i`%5cfG5)&G)5Dk GBk G8Dk ;DfGk B%k G8Dk fDGG]D?D`Gk i`&])biÙk

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c`bk ^BfD]c`bk jJWk "c"D5Ak k 8Dk "5Dff)5Dk B`k G8Dk D[ifGiÙk 5Bcbk `DG;B5-k &c`k B`]>k EDk "5B"D5]>k

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BE]iUcGiB`fk c`bk %i`c`&ic]k &B`G5iE)GiB`fk GB;c5bfk G5c`f"B5Gk i`%5cfG5)&G)5Dk &c`k EDk )fDbk GBk &B?EcGk

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c5DcA

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Spatial Planning

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Action Plan

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Brief A390

Neighbourhood

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Cornwall Local Plan — Strategic Policies

Proposed Submission document March 2014

representation form

Representations can be submitted by email to [email protected] by post to:Cornwall Council — Local Plans TeamCarrick HouseSt Clement StreetTruroTR1 1EB

This form has three parts:Part A: Your personal detailsPart B: Previous representationsPart C: Your representation

Part A: Your personal detailsYou must complete Part A for your representations to be accepted. TheCouncil can not accept anonymous representations.

Regulation 22 of the Town and Country Planning (Local Planning)(England) Regulations 2012, requires all representations received to besubmitted to the Secretary of State. By completing this form andsubmitting it to the Council you are giving your consent to the processingof personal data by Cornwall Council and that any information received bythe Council, including personal data, may be put into the public domain,including on the Council’s website.

1. Personal details. 2. Agent details (if

_____________________

app1 ica b I e).Name

__________________

Stephen HarrisOrganisation Wainhomes (South Emery Planning

West) Holdings Ltd

______________________

Address line 1

______________________

2-4 South Park CourtAddress line 2

_____________________

Hobson StreetAddress line 3

_____________________

MacclesfieldAddress line 4

___________________ ____________________

Postcode

__________________

SK11 8B5Telephonenumber

_____________________ _____________________

Email address

____________________________

Preferred Email U Email Dcontact method Post U Post

Qi. Do you wish to be notified of future stages in the Local Planincluding submission, examination and adoption?Yes U3No U

6162

Typewritten Text

599


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 andwe are now consulting on this amended version, in its entirety as the draftwe propose to submit to the Secretary of State for Examination. If youwould like your previous views to be considered at the Examination it isimportant they are made as part of this consultation.

We are sensitive to the time and effort people made at the lastconsultation and we are happy to accept comments made previously.If you would like your comments to be held over for this consultation youmust tell us that is what you want.

Q2 Did you make comments on the Cornwall Local Plan Pre-SubmissionDraft undertaken March — April 2013?

Yes No El

If Yes;

Do you want your previous comments to be included as part of thisconsultation? (If you propose no changes to your comments no furtherinformation is required).

Yes No El


Yes No El

If Yes;



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

• Positively prepared• Justified• Effective

• Consistent with national policy

Legal complianceFor a Local Plan to be considered legally compliant, the following needs tobe determined:

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

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

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

• That the Local Plan complies with the Planning and CompulsoryPurchase 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 theLocal Plan and is adequate

• That the Habitats Regulations Assessment is carried out inaccordance with the Conservation of Habitats and SpeciesRegulations (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 examinationwhich it considers to be ‘sound’. Do you consider the Plan has metthese tests?Yes LINo


\E?C s- cJs S\vv-

Q4. Do you consider that the Local Plan meets the legal andprocedural requirements?Yes LINo


p c\

Q5. Please provide any comments on the Local Plan — StrategicPolicies. Please use a separate box for each policy.

Document Page number Policy numberCornwall Local Plan —

Strategic PoliciesSustainability AppraisalReport



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

No I do not wish to participate atthe examination in publicYes I wish to participate at theexamination in public

If you wish to be notified of the Submission of the Local Plan — StrategicPolicies please tick the boxTIf you wish to be notified of the publication of the recommendations of theindependent examination (Inspector’s Report) please tick the boxAIf you wish to be notified of the adoption of the Local Plan — StrategicPolicies please tick the boxL

Signature

_________________________

Date [2S/’1/I4

Cornwall Local Plan — Strategic PoliciesProposed Submission document March 2014representation form

Representations can be submitted by emailor by post to:Cornwall Council - Local Plans TeamCarrick HouseSt Clement StreetTruroTR1 1EB

to [email protected]




N ameOrganisation

Address line 1Address line 2Address line 3Address line 4PostcodeTelephonenumberEmail addressPreferredcontact method

1. Personal details.

-

Ltd

EmailDLfst D -

2.. Agent details (ifpplicaje).__ -

çphenHarrLsEmery Planning

4utHobson StreetMaccl esfi e I d

-

EmailD

Qi. Do you wish to be notified of future stages in the Local Planincludin9 submission, examination and adoption?YesNo 0




Q2 Did you make comments on the Cornwall Local Plan PreSubmissionDraft undertaken March — April 2013?

Yes No U

If Yes;


Yes No U


Yes 3” No

If Yes;





. Consistent with national policy










been complied with.

Q3 A local planning authority should submit a plan for examinationwhich it considers to be ‘sound’ Do you consider the Plan has metthese tests?Yes DNo


o:c\

Q4. Do you consider that the Local Plan meets the legal andprocedural requirements?Yes DNo


Sc ç.L- ;i—C’\ j5C 3\-.Q4



Stratjç PoliciesSustainability Appraisal

L

çet__ aac number PohcynumberCornwall Local Plan

—

Syc_PolidesSustainability Appraisal

-cp9-___—_—_



If YOU wish to be notified of the Submission of the Local Plan — StrategicPolicies please tick the box I,L(If you wish to be notified of the publication of the recommendations of theindependent examination (Inspector’s Report) please tick the box1..ITIf you wish to be notified of the adoption of the Local Plan — StrategicPolicies please tick the boxLD

Ll3ZZ1Signature j Date




Part A: Your personalYou must complete Part A for your representations to be accepted. TheCouncil can not accept anonymous representations.


1. Personal details. 2.. Agent details (ifpplicable).

Name L StepjenHarrOrganisation Wainhomes (South I Emery Planning

Address line 1 2-4 South Park CourtAddress line 2 Hobson Street

____

Address line 3 Macclesfield

________

Address line 4I

Postcode SK11 8BSTelephonenumber

__________-

_____

Email addressI

Preferred Email 0 1 Email 0contact method Post 0 Post

Qi. Do you wish to be notified of future stages in the Local Planincludin9 submission, examination and adoption?Yes 2TNo 0




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

Yes No U

If Yes;


Yes No U


Yes No U

If Yes;


s-’-- ccic\





Legal complianceFor a Local Plan to be considered legally compliant, the following needs tobe determined;








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

been complied with.

Q3 A local planning authority should submit a plan for examinationwhich it considers to be ‘sound’. Do you consider the Plan has metthese tests?Yes EJNo


Q4. Do youproceduralYes DNo

consider that the Local Plan meets the legal andrequirements?

s- ;\



Document Page number Policy numberCornwall Local Plan

— ISç•çfolicies__ 1

Sustainability Appraisal

L_________________Document Page number Policy numberCornwall Local Plan

— 1)Strategic_PoHcies i1’Sustainability Appraisal

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


If you wish to be notified of the Submission of the Local Plan — StrategicPolicies please tick the boxEYIf you wish to be notified of the publication of the recommendations of theindependent examination (Inspector’s Report) please tick the boxAIf you wish to be notified of the adoption of the Local Plan — StrategicPolicies please tick the boxD

Signature r - 1 Date

_____________






1.. Personal details. 2. Agent details (ifpplicable)__

Name Stepp__Organisation Wainhomes (South Emery Planning

t)Hi4dAddress line 1 2-4 South Park CourtAddress line 2 ‘ Hobson StreetAddress line 3 MacclesfieldAddress line 4

___

Postcode

_____

j SK11_8BSTelephone InumberEmail address

Preferred Email D Email 0contact method Lost__oj Lfpstrv -

Qi. Do you wish to be notified of future stages in the Local Planincludin9 submission, examination and adoption?Yes tNo C





Yes No U

If Yes;


Yes No U


Yes No U

If Yes;














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

been complied with.

Q3 A local planning authority should submit a plan for examinationwhich it considers to be ‘sound’. Do you consider the Plan has metthese tests?Yes 0No


--- c(Oc\

Q4. Do you consider that the Local Plan meets the legal andprocedural requirements?Yes 0No

Please spec:ify the reasons below



Strategic PoliciesSustainability AppraisalcPPrL_______

Document Page number Pohc numberCornwall Local Plan

—

(Dpl \Strategic PoliciesSustainability AppraisalReport -_______________


No I do not wish to participate at 1the examination in publicYes I wish to participate at theexamination in public

If you wish to be notified of the Submission of the Local Plan — StrategicPolicies please tick the boxi.LYIf you wish to be notified of the publication of the recommendations of theindependent examination (Inspector’s Report) please tick the boxAIf you wish to be notified of the adoption of the Local Plan — StrategicPolicies please tick the box

Signature r I Date I 1

Cornwall Local Plan — Strategic Policies

Proposed Submission document March 2014

representation form

Representations can be submitted by email to localplan©cornwall.gov.ukor by post to:Cornwall Council — Local Plans TeamCarrick HouseSt Clement StreetTruroTR1 1EB




1. Personal details. 2. Agent details (ifapplicable).

Name Stephen arMsOrganisation Wainhomes (South Emery Planning

WçjHolding LtdAddress line 1

____

2-4 South Park CourtAddress line 2 Hobson StreetAddress line 3

_______________

MacclesfieldAddress line 4

____________________ ______

Postcode

__________________

SK11 8BS

_________

Telephonenumber

_______________ ___________

Email address —

Preferred Email D Email Dcontact method Post ci Post

Qi. Do you wish to be notified of future stages in the Local Planincludin9 submission, examination and adoption’YesNo ci





Yes No D

If Yes;


Yes No EJ


Yes No 0

If Yes;


S V




• Consistent with national policy










been complied with.

Q3 A local planning authority should submit a plan for examinationwhich it considers to be ‘sound’. Do you consider the Plan has metthese tests?Yes DNo


.

Q4. Do you consider that the Local Plan meets the legal andprocedural requirements?Yes DNo


9 ç-


Document Page number Policy numberCornwall Local Plan

—


cn__ Pq number Policy numberCornwall Local Plan

-

c____._ -_______________ —--.

Sustainability Appraisal

P_L________________



If you wish to be notified of the Submission of the Local Plan — StrategicPolicies please tick the boxLEYIf you wish to be notified of the publication of the recommendations of theindependent examination (Inspector’s Report) please tick the box.1JIf you wish to be notified of thdoption of the Local Plan — StrategicPolicies please tick the box tLY

Signature L__ ________ j Date

______

d

d

d

Cornwall Council

Affordable Housing Team

Circuit House

St Clement Street

Truro

Cornwall

TR1 1DT

14/03/2014

EPP ref: L117-7570-SH-tc

2 – 4 South Park Court

Hobson Street

Macclesfield

Cheshire

SK11 8BS

T: 01625 433881

F: 01625 511457

[email protected]

www.emeryplanning.com

Dear Sir/Madam

Re: Affordable Housing SPD January 2014

Emery Planning Partnership is instructed by Wainhomes (South West) Holdings Ltd to submit

representations to the above consultation.

As the Council will be aware, our client is a key developer in the County and is an important

partner in delivering affordable housing across Cornwall.

The Purpose and Role of the SPD

The purpose of the SPD will provide detailed guidance on the Affordable Housing policies set out in

the Cornwall Local Plan. It states at paragraph 2.3.4that the SPD will be formally adopted once the

Cornwall Local Plan is adopted, which is stated as being during 2014. However, the Pre-Submission

consultation is due to commence on 17th March 2014. An adopted Local Plan is not possible until

mid-2015 in our view, if the Inspector considers that the plan is sound. In the interim the document

states that the SPD may be endorsed by elected Members and adopted as interim planning

guidance.

Paragraph 153 of the National Planning Policy Framework (the Framework) states:

“Each local planning authority should produce a Local Plan for its area. This can be

reviewed in whole or in part to respond flexibly to changing circumstances. Any

additional development plan documents should only be used where clearly justified.

Supplementary planning documents should be used where they can help applicants

Emery Planning Partnership Ltd

trading as Emery Planning

REG: 4471702 VAT: 758112726

Registered office: as above

http://www.emeryplanning.com/


make successful applications or aid infrastructure delivery, and should not be used to add unnecessarily to the financial burdens on development.”

The guidance is clear that the Local Plan is the main policy document and other documents can

be used where clearly justified. A role of the SPD is to supplement the local plan policy and this is

accepted in the draft SPD. Our principal concern is the weight that can be given to the SPD in

advance of the adoption of the local plan. In our view it should not be adopted for development

plan purposes because, until the Local Plan is found sound at Examination, the policies which the

SPD are based on are of limited weight themselves. To use those policies of limited weight, which

may be subject to changes, in an SPD which itself has not been publicly examined is simply not

appropriate.

On a more basic point, the document, at some 61 pages seems to be overcomplicating the

policies which are proposed to be in the Local Plan. We consider that the Council should look at

condensing the information in the SPD into a more useful and workable document.

Affordable Housing Need

It is clear from the draft SPD that there is a significant need for affordable housing and paragraph

3.5.6 states:

“To meet both existing and newly arising need the Council needs to secure the delivery

of 2,240 affordable homes annually. Were the Council to set a more achievable target

of reducing the existing backlog over a longer period of 10 years, the annual requirement would reduce to 1,770 affordable homes”.

However this is then reduced to a seemingly arbitrary 1,000 homes per annum as other interventions

can contribute to meeting the need (including reducing numbers of empty homes, reducing

under-occupancy of the council’s own stock, supporting the private rented sector). This is a

significant reduction and there is no evidence that the factors listed in paragraph 3.5.7 can deliver

affordable homes of the scale required. Further detailed evidence is required on the funding and

rate of past delivery of these interventions.

Reference is also made in part 2 of paragraph 3.3.3 to the existing backlog however the backlog is

not quantified. This needs to be specified.

As noted above, the assessment points towards an annual requirement of 1,770 to 2,240 affordable

homes, depending on whether the backlog is addressed over 5 years or 10 years. However, the

Framework has introduced the requirement to “boost significantly” the supply of housing (paragraph 47). Addressing the shortfall as soon as possible is consistent with this requirement. This is

reemphasised in the National Planning Policy Guidance which under the heading “How should

local planning authorities deal with past under-supply?” it states:

“Local planning authorities should aim to deal with any under-supply within the first five

years of the plan period where possible. Where this cannot be met in the first five

years, local planning authorities will need to work with neighbouring authorities under

the duty to cooperate.”

The need to address the backlog of affordable housing is even more pressing as these are Cornwall

residents who are in need of a home and a significant increase, rather than the suppression of

housing requirements as proposed in the draft Local Plan. Indeed, page 7 of the draft SPD states

that there are 26,500 households on the Homechoice register 23,000, of whom have a connection

to Cornwall. Delaying the delivery of new housing over a 10 year period is not justified and is

contrary to national policy.

2

The operation of the SPD

It should be noted that we will be submitting representations to the Cornwall Local Plan when it is

issued for consultation next week. This will include policies 8, 9, 10 and 11. However there are a

number of points that raise concern.

Policy 8

The starting point for AH is that it is required on all sites where there is a net increase of 2 units or

more and/or all sites of 0.2 hectare or above. We consider that this is a significant imposition on the

smaller developers in the County and may well result in lower delivery rates.

It is important to ensure that viability assessments are undertaken as part of the evidence base for

the emerging Local Plan and we reserve our position to debate this issue as part of the local plan

process. We will be making more detailed comments on the setting and application of the

thresholds in response to the next stage in consultation on the Local Plan.

Cornwall has been divided into 5 zones according to house price values, with Zone 1 being the

most expensive and Zone 5 the least. These are set out in detail in Appendix 3 to the SPD, defined

by parish boundaries. The settlements they include are summarised as:

Zone 1 – Rock, Fowey, Tredizzick, Gerrans/Portscatho

Zone 2 - St Ives, Padstow, St Merryn/Shop Constantine

Zone 3 – Falmouth and Penryn, Truro, Newquay, Mevagissey, Lostwithiel, Marazion

Zone 4 – Bodmin, Penzance, St Austell, Launceston, Bude, Saltash, Hayle, Wadebridge

Zone 5 - Camborne, Pool, Illogan, Redruth, Helston, Liskeard, Indian Queens, Fraddon,

Delabole

For sites allocated in the DPD in the identified main towns, or sites within or on the edge of the main

towns which contribute to the growth set out in LP Policy 3, Policy 8 of the LP applies:

Zones 1 and 2 subject to 50% AH provision, on site; and,

Zones 3, 4, 5 subject to 40% AH provision, on site.

The practicalities of the above requires further thought, as in subjecting the areas of higher value to

the higher percentage requirement, may actually mean that developers will not look to build in

those areas. Rather than increasing the level of affordable housing completions the opposite may

be the result. Therefore we question the different thresholds proposed in the above zones.

Policy 9

Policy 9 of the LP states that on sites outside existing built up areas all housing will need to

demonstrate that its primary purpose is to provide affordable housing to meet local needs.

However it accepts that the market housing can comprise up to 50% of the development (and up

to 60% of the land area). It also requires a viability appraisal unless it is evidently affordable housing

led, to show that the amount of market housing is the minimum required to facilitate the affordable

housing i.e. worked backwards from a 100% affordable scheme.

3

However in the absence of a 5 year land supply or the local plan being out of date sites outside

settlement boundaries should revert back to the percentages in Policy 8.

Policy 11 – Viability

Policy 11 of the LP allows for the targets set out above to be varied, where there is appropriate

evidence on viability. Viability is to be assessed by an Economic Viability Assessment (EVA).

The process for negotiating the Affordable Housing contribution described in section 7 on

Economic Viability is unnecessarily complex. The application of such a process to the majority of

development proposals will result in the lengthening of the already extensive pre-application stage

together with a prolonged period for determination once the application is made. This will frustrate

the delivery of both market and affordable housing and as such must be contrary to the aim to

boost housing supply which is set out in the Framework.

Local Plan Policy Guidance V2 (Economic Viability Appraisals and negotiation) states that in order

for a proposal with reduced provision to be supported it must be possible to adequately

demonstrate this clearly and transparently, including to the community and Councillors. We

disagree with this statement and any EVA should be private and confidential.

Local Plan Policy Guidance V4 – Cost recovery for assessing Economic Viability Appraisals and

paragraph 7.3.3 states that the Council will recover its costs incurred in assessing viability in certain

circumstances. We disagree with this as this should be part of the service provided as part of the

application fee.

Section 9 on Monitoring and Review acknowledges in 9.3 that there is a relationship between

viability, affordable housing contributions and CIL payments. The implications of this inter-

relationship which will come into play at a later date once the CIL charging schedule has been

through examination must be considered now, both in the preparation of the affordable housing

SPD and critically, as the Local Plan progresses to examination. It is vital that the responsibility

placed on Local Planning Authorities and described in paragraph 2.1.5 of the draft SPD is

demonstrated and evidenced.

Yours sincerely

Emery Planning

Stephen Harris BSc (Hons) MRTPI

Director

4

Cornwall Council Local Plan Proposed Submission Document

REPRESENTATIONS BY

WAINHOMES (SOUTH WEST) HOLDINGS LTD

EPP reference: REPS5-6412-SH-jb

April 2014

CONTENTS:

1. INTRODUCTION 1

2. GENERAL MATTERS 1

3. KEY TARGETS (POLICY 2) 2

4. POLICY 3 (ROLE AND FUNCTION OF PLACES) 10

5. POLICIES 8, 9 AND 11 (AFFORDABLE HOUSING) 11

6. PP6 TRURO AND ROSELAND COMMUNITY NETWORK AREA 12

7. PP9 ST AUSTELL AND MEVAGISSEY, COMMUNITY NETWORK AREA 12

8. POLICY PP11 BODMIN COMMUNITY NETWORK AREA 15

9. PP14 LAUNCESTON COMMUNITY NETWORK AREA 16

10. PP15 LISKEARD AND LOOE COMMUNITY NETWORK AREA 16

Cornwall Council Local Plan Proposed Submission Document Representations by Wainhomes (South West) Holdings Ltd

1. INTRODUCTION

1.1 Emery Planning Partnership is instructed by Wainhomes (South West) Holdings Limited to

submit representations to the Proposed Submission Document of the Local Plan (the Plan).

Wainhomes is a key developer within Cornwall and will be an important delivery partner

for the Council in providing its open market and affordable housing needs within the plan

period. Their landholdings and developments can also facilitate further mixed use

development including employment and social infrastructure.

1.2 These representations concentrate on the overarching policy issues such as the housing

requirement and its distribution as well as the specific Community Network Areas. We set

out our client’s interests to demonstrate a deliverable supply of sites.

1.3 We have made detailed representations at each stage of the local plan and wish to

participate at the Examination.

2. GENERAL MATTERS

Legal Compliance and Procedural Requirements

2.1 Our previous submissions raised concern with the Plan as we considered that it did not

provide a suitable framework for determining where, when and how the correct amount of

housing will be delivered. These concerns remain and given the guidance in the

Framework perhaps more so as the Local Plan should meet the various tests in paragraph

157. We do not repeat them here but it is clear that the Plan should be indicating broad

locations for strategic development on a key diagram, land-use designations on a

proposals map and allocate sites to promote development.

2.2 Since our previous representations, the NPPG has been issued. Under the heading What is

the role of a Local Plan?, paragraph 001 (Reference ID: 12-001-20140306) states:

“National planning policy places Local Plans at the heart of the planning

system, so it is essential that they are in place and kept up to date.

Local Plans set out a vision and a framework for the future

development of the area, addressing needs and opportunities in

relation to housing, the economy, community facilities and

infrastructure – as well as a basis for safeguarding the environment,

adapting to climate change and securing good design. They are also a

critical tool in guiding decisions about individual development

proposals, as Local Plans (together with any neighbourhood

plans that have been made) are the starting-point for

considering whether applications can be approved. It is important

for all areas to put an up to date plan in place to positively guide development decisions.”

REPS5-6412-SH-jb April 2014 Page 1 of 17


2.3 The Local Plan as proposed simply does not set out a vision and a framework for the

future development of the area and this fundamental component of any plan needs to be

revisited and set out.

2.4 Therefore at this stage in the process the Council should be identifying which sites they

consider are appropriate and including a housing trajectory as to how these sites will meet

the requirement over the plan period. The Plan does neither. The only way forward is for a

Local Plan to be prepared in accordance with the NPPF and NPPG.

Duty to co-operate

2.5 Whilst we note that the SHMA was undertaken jointly, we are unable to determine what

level of cooperation the Council has taken with other neighbouring authorities across the

broad range of issues contained in the Local Plan and how any specific actions have

informed plan preparation.

2.6 The importance of the duty is set out in the National Planning Practice Guidance (NPPG)

which states ‘it is unlikely that this (the duty) can be satisfied by consultation alone’

(Paragraph 010 ID: 9-010-20140306) and that ‘inspectors will assess the outcomes of the

co-operation and not just whether local planning authorities have approached others’

(Paragraph 011 ID: 9-011-20140306).

2.7 A number of plans, for example, Coventry, Hart, North West Leicestershire and Kirklees

Councils have noted that compliance with the duty needs to go beyond merely consulting

with neighbouring authorities, but should implement actions and have evidence of high

level agreements to tackle strategic issues, including housing. In this area many local

authorities adjoining Cornwall are significantly short of demonstrating a 5 year supply, for

example Plymouth, Torridge and North Devon. It is not clear from the evidence what the

outcomes of co-operation, if it took place, were, and how this has addressed strategic

matters, for example on housing.

3. KEY TARGETS (POLICY 2)

3.1 Part 4 of Policy 2 sets a 20 year requirement of 47,500 dwellings. This is an increase from

the 42,250 dwellings consulted upon in the last consultation. However our position

remains that the requirement of 47,500 dwellings does not meet paragraph 47 of the

Framework. There are a number of reasons why we come to this conclusion which are set

out below.

3.2 As set out in paragraph 159 of the Framework, there are two key components to

determine the housing requirement, these being the Strategic Housing Market Assessment

(SHMA) and the Strategic Housing Land Availability Assessment (SHLAA). In essence these



two documents should determine what the requirement is to meet the full objectively

based housing requirement and whether the council has sufficient land to meet that need.

3.3 We first assess the SHMA.

Strategic Housing Market Assessment (SHMA)

3.4 Since the last consultation the Council has commissioned a SHMA along with neighbouring

authorities Plymouth City Council, South Hams, West Devon, Dartmoor National Park

Authority. The SHMA was carried out by GVA and Edge Analytics.

3.5 Paragraph 159 of the NPPF advises that a SHMA should:

meet household and population projections, taking account of migration and

demographic change;

address the need for all types of housing, including affordable housing and the

needs of different groups in the community (such as, but not limited to, families

with children, older people, people with disabilities, service families and people

wishing to build their own homes); and

caters for housing demand and the scale of housing supply necessary to meet

this demand.

3.6 We now assess these key factors.

Housing Market Areas

3.7 Since the last consultation the 2013 SHMA has been published. Paragraph 47 of the NPPF

requires local planning authorities to “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”. The 2013 SHMA refers to the 19 community network areas (CNA) in

Cornwall which are Bodmin; Bude; Caradon; Camborne, Pool and Redruth; Camelford;

China Clay area; Cornwall Gateway; Falmouth and Penryn; Hayle and St Ives; Helston and

the Lizard; Launceston; Liskeard and Looe; Newquay and St Columb; West Penwith, St

Agnes and Perranporth; St Austell; St Blazey, Fowey and Lostwithiel; Truro and Roseland;

Wadebridge and Padstow.

3.8 The 2013 SHMA has carried the Community Network Areas forward rather than actually

assessing whether they are the correct housing market areas to use. From our experience

across the country housing market areas are geographically larger than the 19 Community

Network Areas in the Plan. For example, Wiltshire, which is also a unitary authority has 3

housing market areas which they use for the purposes of paragraph 47 of the NPPF.

Wiltshire does have smaller community areas as well but these are not used or intended to



be used for paragraph 47 purposes. We consider that further advice is obtained on this

important point in advance of the Examination.

Household Projections

3.9 Population and household projections are the starting point for assessing need

(Paragraph: 015 Reference ID: 2a-015-20140306 of NPPG). It also clarifies that the

projections may require adjustment to reflect factors affecting local demography and

household formation rates which are not captured in past trends, such as under-supply

and worsening affordability of housing.

3.10 The interim 2011 based projections which were published in April 2013 indicate an

increase in the number of households between 2011 and 2021 of 24,000. If this is

extrapolated over the plan period (2010-2021), then the requirement for Cornwall would

be 48,000 dwellings. However paragraph 015 (Reference ID: 2a-015-20140306) of NPPG

states that household projections do not reflect unmet housing need, local planning

authorities should take a view based on available evidence of the extent to which

household formation rates are or have been constrained by supply.

3.11 Therefore this is only the starting policy which is clear from the 2013 SHMA which then

adds in other factors such as economic growth.


3.12 That 2010 SHMA made an overall recommendation of 2,410 open market dwellings and

1,570 affordable homes per annum. The 2013 SHMA states that there will be a

requirement for between 47,300 and 71,980 dwellings between 2011/12 and 2030/31 to

meet the demands generated by new household formation and the labour force demands

of a growing local economy. It also states that there is an annual need of 2,241 affordable

properties required to meet newly arising need over the next five years as well as the

existing backlog.

3.13 In the report to the 27th November Cabinet, the recommendation to members was that

the Council amends the draft Local Plan and agrees the overall housing number and

associated distribution from one of two options, either a higher figure of 47,500 or a lower

figure of 42,250 dwellings. The officer report states:

“Officers believe that a target based on the housing need arising from

the basic demographic projections in our recent Strategic Housing

Market Assessment, of 47,500 is the lowest that could be robustly

defended at the Examination. It does not include any allowance for

meeting the backlog in affordable housing or meeting the needs

that might be required by higher aspirations for economic

growth; but relates to the projections stemming from demographic

change over the next 17 years. The level of growth this sets is still



significantly lower than past proposals and is broadly equivalent

to the current rate of house building across Cornwall, i.e. around 2,300 per year.”

3.14 The above does not clarify what the current backlog is and it clearly demonstrates the

requirement is significantly constrained.

3.15 In February 2014 there were 35,592 applicants on the Council’s Homechoice database.

This is a considerable number and by far the highest since 1997.

3.16 In addition, paragraph 3.9 of the SHMA confirms that the Council’s waiting list currently

has 7,313 households in significant need, 2,118 of which are currently living in social

rented accommodation. This leaves a total of 5,480 households classified as in

significant need within Cornwall.

3.17 The above is the need that exists now yet it is some 67% of the total requirement planned

for in the Plan to 2030. This is a clear indicator that 47,500 dwellings is too low and should

be increased significantly.

3.18 A number of other documents form part of the evidence base. We assess them below.

Housing Requirement for Cornwall October 2012

3.19 This report was prepared by Peter Brett Associates. Table 5.1 of that report sets out 7

different scenarios which lie within a range of 49,700 and 95,000 dwellings. It is clear the

requirement being consulted upon is below all these scenarios. We note that the report

discounts the 95,000 requirement so the upper end of the range is reduced to 68,600

dwellings.

3.20 Paragraph 5.2.5 states that suppressing housing provision below actual demand may

mean that lower income residents in need of a home lose out to wealthier in-migrants.

The lowest scenario E1 (49,700 dwellings) therefore needs to be balanced against what

the demographic information is showing and should the Council wish to pursue a growing

population and economic growth then they will need immigration to increase the

economically active population. Therefore the clear implication of this position is that the

lowest scenario would suppress housing provision.

3.21 Paragraph 5.2.7 then states that completion rates show that around 2,264 dwellings have

been delivered each year on average and the housebuilding industry could be expected to

continue to deliver at a similar level. We consider that this is a rather pessimistic

statement as the development industry has been operating in a planning vacuum with no

up to date development plan with allocations for a large proportion of the last 10 years. In

addition we have had a significant economic recession and with a plan until 2030 we

would fully expect the development industry to increase delivery. Indeed, paragraph 5.2.8



refers to “pent up demand” so it is clear that the previous build rates have not meet actual

demand. The only solution is for a higher requirement.

3.22 To take that previous point forward, the 2011-2012 AMR sets out the completions per

annum since 2001. For ease of reference these are set out in the table below.

01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11

2,485 2,639 2,183 2,495 2,084 2,612 3,179 2,877 2,473 2,060

3.23 This table demonstrates that the proposed requirement of 2,375 dwellings is actually

below what has been delivered in all but one of the years. In addition in those 10 years

there have been 25,087 completions, which equates to an average annual completion rate

of 2,508 dwellings. Both these calculations clearly demonstrate that the requirement will

suppress housing delivery and drive up prices. This will only increase the substantial

affordable housing need, which currently sits at 32,592 on the Homechoice register.

3.24 In addition it would clearly mean that the development industry would have to downsize

as the proposed requirement is lower than previous completions. Therefore rather than

the development industry being a key component for growth over the plan period which is

what the Government expects from Planning for Growth and the NPPF, the emerging plan

will be have the reverse effect.

Economic Projections

3.25 The Framework reflects the Planning for Growth (Ministerial Statement 23rd March 2011).

This sets out that the Government’s top priority in reforming the planning system is to

promote sustainable economic growth and jobs. The Government’s clear expectation is

that the answer to development and growth should wherever possible be ‘yes’ except

where this would compromise the key sustainable development principles set out in

national planning policy. It is important to note that residential development is capable of

being an economic benefit due to construction jobs and the supply chain to developers,

and the overall benefits to the economy that are to be achieved through providing the

correct level of housing sufficient to meet the needs of the population. However it is also

critically important to provide the necessary range of housing to meet those currently or

projected to be employed in Cornwall.

3.26 Paragraph 7 of the Framework is clear that a key part of sustainable development is

contributing to building a strong, responsive and competitive economy, by ensuring that

sufficient land of the right type is available in the right places and at the right time to



support growth and innovation; and by identifying and coordinating development

requirements, including the provision of infrastructure.

3.27 Paragraph 2.13 of the SHMA states that there are a range of economic forecasts presented

within the Main SHMA Report. For Cornwall this shows a range in levels of job forecast

with the two latest forecasts suggesting that total employment will grow by between

30,800 jobs (Experian, 2013) and 39,700 jobs (LEFM, 2012). Crucially for the housing

requirement this level of growth is slightly below the level of jobs generated over recent

years. Therefore it is a highly probable and realistic forecast.

3.28 Indeed, an example of the plan for increased economic activity is the Newquay Aerohub.

It is referred to as England's only aerospace focused Enterprise Zone, with significant

development land and access to investment. The Aerohub has been established for

businesses related to the aerospace and aviation industry, advanced engineering and

marine, energy and environment related development. This is also investment in the

creation of the Aerospace Learning Centre. The intention is for the Aerohub to deliver over

700 jobs in direct aerospace and a further 375 in the wider economy over the next five

years.

3.29 From this one example it is clear that new housing must be provided as the specialised

jobs that are to be created are likely to increase immigration to Cornwall.

3.30 The Plan as currently drafted is in direct conflict with the Government’s agenda for growth

due to it having a lower requirement that has been historically delivered and is based on

lower immigration when new economic developments such as the Aerohub will require

immigration for the specialised jobs.

The Council’s consideration of the requirement

3.31 At the 15th October 2013 meeting of the Environment Heritage and Planning Portfolio

Advisory Committee, members were unable to decide the housing requirement to proceed

with and instead resolved to consider two options for the overall housing requirement

within the pre-submission draft Local Plan of 42,250 dwellings or 47,500 dwellings.

3.32 At the 15th November Environment Heritage and Planning Portfolio Advisory Committee,

the same issues that were debated at the October meeting were considered. A decision

could not be made and the Committee resolved that the matter is considered by the

Cabinet at their meeting on 27th November 2013.

3.33 In the report to the 27th November Cabinet, the recommendation to members was that

the Council amends the draft Local Plan and agrees the overall housing number and

associated distribution from one of two options, either a higher figure of 47,500 or a lower

figure of 42,250 dwellings. The officer report states:



“Officers believe that a target based on the housing need arising from

the basic demographic projections in our recent Strategic Housing

Market Assessment, of 47,500 is the lowest that could be robustly

defended at the Examination. It does not include any allowance for

meeting the backlog in affordable housing or meeting the needs that

might be required by higher aspirations for economic growth; but

relates to the projections stemming from demographic change over the

next 17 years. The level of growth this sets is still significantly lower

than past proposals and is broadly equivalent to the current rate of

house building across Cornwall, i.e. around 2,300 per year.”

3.34 This shows that even the 47,500 dwelling requirement is not sound and officers are clearly

indicating a much higher requirement.

Conclusion

3.35 Under the heading “Can local planning authorities apply constraints to the assessment of

development needs?”, paragraph 004 (Reference ID: 2a-004-20140306) of the NPPG

states:

“The assessment of development needs is an objective assessment of need based on facts and unbiased evidence. Plan makers should not apply constraints to the overall assessment of need, such as limitations imposed by the supply of land for new development, historic under performance, viability, infrastructure or environmental constraints. However, these considerations will need to be addressed when bringing evidence bases together to identify specific policies within development plans.”

3.36 The only conclusion that we can draw is that the plan is directly contrary to the NPPG and

paragraph 47 which requires local planning authorities “to ensure that their Local Plan

meets the full, objectively assessed needs for market and affordable housing in the

housing market area”. The graph below sets out how this requirement relates to the

evidence base.





3.37 The requirement that the Council should be proceeding with should be in the region of

71,980 dwellings. This correlates very well with the requirement of 66,000 dwellings that

we advanced in the previous consultations and the RSS Proposed Changes of 68,200

dwellings. This is because:

This would be within the mid to upper range of the documents in the evidence

base.

It would be higher than previous delivery. However as we note above the

development industry has been operating without an adopted development plan

as well as a deep economic recession. As the Plan is to 2030 we would expect

those rates to increase and crucially the SHLAA states that there is capacity for

105,605 additional homes over the period 2013 – 2028. Therefore the higher

requirement can be easily met.

The higher level of delivery that now proposed has resulted in a 32,592 waiting

list on Homechoice, therefore it is counterintuitive to now propose a lower level

of growth.

3.38 As can be seen from the way that the Council has debated the housing requirement in the

various meetings over the last 6 to 7 months, there is no doubt that the Council has

sought to artificially constrain the housing requirement and have chosen a requirement

that they consider is the absolute minimum it can proceed with to be found sound by the

Examination Inspector.

4. POLICY 3 (ROLE AND FUNCTION OF PLACES)

4.1 Policy 3 seeks to guide the location of development. However the policy, when read in

conjunction with Table 1 is not sound as there is no settlement hierarchy set out. There

are a number of documents in the evidence base that deal with the settlements, these

being:

The Cornwall Towns Study;

The Role and Future of Smaller Settlements in Cornwall;

Community Network Area Profiles and Neighbourhood (LSOA) Profiles;

Place Based Plans; and,

Settlements: Hierarchy and Settlement Categories - 2012 update.

4.2 The conclusions of those documents are not set out in Policy 3, although we do recognise

that each CNA has its own policy which makes reference to but is not clear on the

quantum of development that each settlement should accommodate. For a strategic


http://www.cornwall.gov.uk/media/3638172/Cornwall_Towns_Study.pdf

http://www.cornwall.gov.uk/media/3638173/cornwall-smaller-settlements-final-report-101209-pdf-version.pdf

http://www.cornwall.gov.uk/media/3640460/Settlement-Strategy-Update-Final.pdf


policies plan this is required as this will guide the Allocations DPD or Neighbourhood Plans.

The main issue that may result is that without any clear guidance at the strategic level

there is a possibility that the subsequent plans will not provide the required level of

development for each settlement.

4.3 We also consider that Table 1 needs significant revisions to meet the housing requirement

we advocate in Policy 2 above.

5. POLICIES 8, 9 AND 11 (AFFORDABLE HOUSING)

5.1 Our representations to the Affordable Housing SPD are enclosed as Appendix EP1. These

representations were submitted on 14th March 2014 and our position remains as set out in

those submission and we do not repeat them here.

5.2 In addition, the Council must strike the right balance between affordable housing and CIL.

They have sought to do this through the Housing Strategic Viability Appraisal (HSVA). This

tests a range of scenarios and these are summarised in the box at paragraph 9.4 of the

main CIL consultation document. Paragraph 9.4 states that higher affordable housing

thresholds have been set as these are negotiable, whereas CIL is non negotiable. Policy 8

of the Draft Local Plan accords with this in that the affordable housing requirements are

set as targets.

5.3 However paragraph 7.6 of the CIL consultation document states that there is a funding

shortfall of £510m for critical and necessary projects for transport, education, green and

blue infrastructure, post 16 education and skills, health, emergency services and flooding

infrastructure. Paragraph 7.6 then advises that CIL is expected to raise some £62m over

the local plan period. This still leaves a funding shortfall of some £448m to be found from

other sources.

5.4 Therefore the point we wish to raise at this stage is whether it is prudent to seek what is

the maximum amount of CIL assessed in the HSVA when there is such a significant

funding gap to actually deliver these projects at the expense of a lower affordable housing

threshold when affordable housing delivery is paramount and a key community objective.

5.5 Paragraph 7.23 of the HVSA uses St Austell as a specific example. This states that

anything above 20% affordable housing with £40 CIL on smaller urban schemes and 25%

affordable housing with £70 on larger greenfield sites is unlikely to be viable. However the

target for affordable housing in St Austell is set in Policy 8 as 40%. This was a belated

change to the affordable housing requirement for St Austell which was 30% in the

committee draft the Pre-Submission Draft. Therefore on the evidence in the HSVA, St

Austell would never achieve a target of 40% affordable housing. Therefore a lower target

of 30% may well be necessary for zones 3, 4 and 5.



6. PP6 TRURO AND ROSELAND COMMUNITY NETWORK AREA

6.1 Policy PP6 proposes 3,900 dwellings between 2010 and 2030. Of that overall figure, 3,000

are proposed in and adjacent to Truro. Clearly Truro should take a significant proportion

of the overall development. However only 900 dwellings are proposed within the

remainder of the Community Network Area. Figure 10 identifies 12 smaller settlements

within this CNA. However the Plan is silent on how much development should be located in

each of the villages and we question whether 900 dwellings (of which 336 are completed

or committed) is sufficient to meet the needs of each of these villages.

6.2 Clearly some villages are more sustainable than others. Probus is defined as a Category D

settlement which is defined as a smaller settlement that performs an important role in

their local areas, i.e. ‘rural service centres’. The full list of Category D settlements are

Grampound, Probus, Shortlanesend, St Mawes, Tregony, Trispen and Veryan. Of these

Probus scores the highest.

6.3 The Category E settlements are those that include either a primary school or a general

store and are Chacewater, Devoran, Grampound Road, Ladock and St Just in Roseland.

6.4 In addition, Truro has been unable to deliver its housing requirements. Therefore a more

dispersed strategy is more likely to lead to the delivery of the requirement within the plan

period and on that basis greater recognition should be given to the other settlements in

the Truro CNA whilst retaining Truro as the main focus.

7. PP9 ST AUSTELL AND MEVAGISSEY, COMMUNITY NETWORK AREA

7.1 This wider CNA covers three separate CNAs, these being:

St Austell;

St Blazey, Fowey and Lostwithiel; and,

China Clay.

7.2 We have a number of land interests for allocation in this area which are as follows:

Land at Treverbyn Road, St Austell;

Land at Charlestown;

Portpean Road, St Austell;

Meanear Road, St Austell;

Mount Crescent, Par; and,

Tredenham Farm, St Blazey.



Housing Requirement

7.3 Table 1 of the Plan shows the distribution of the housing requirement. A number of points

arise.

7.4 First, St Austell should be given a greater proportion of the requirement as it is a

strategically significant town and is a key employment and service centre for the County.

This would be a continuation of the policies in the development plan and the evidence

base for the now abandoned Restormel Core Strategy and the draft RSS. However based

on Table 1, there is a residual requirement of 240 dwellings. This level of development for

the remaining 16 years of the plan period (15 dwellings per annum) is simply untenable

and unsustainable for the largest town in Cornwall. It is significantly below the past

completion rates (some 213 per annum) and requires a significant upward revision.

7.5 The table below shows the imbalance of the provision given to St Austell than to the other

main towns.

Housing Req Camborne/Pool/Illogan/Redruth 4,500 Falmouth/Penryn 2,600 Truro (inc Threemilestone) 3,000 St Austell 2,000 Newquay 3,550 Penzance 2,150 Bodmin 3,000

7.6 Page 85 of the Plan states that the annual completion rate in the St Austell and

Mevagissey CNA is 213 dwellings. The Plan as drafted would provide for 100 dwellings per

annum. This is a clear conflict with the Framework.

7.7 In addition, the delivery of new affordable housing has not kept pace with the level of

housing need established in the Housing Requirement Study in St Austell. Between

2006/07 and 2010/11, 208 affordable units were completed which leaves a shortfall of 723

affordable homes in the St Austell area.

7.8 What is clear is that St Austell must grow and to do this the only option available is for

greenfield urban extensions to the town. We support this as there is limited previously

developed land within the urban area. It is now recognised in the Plan as paragraph 12.24

states that the growth of St Austell is likely to occur on the edge of the town but outside

the St Austell CNA. The boundary of the St Austell CNA is not well defined in the Plan and

this needs to be rectified. Our client’s land interests appended to this statement sets out a

number of deliverable sites that would be sustainable urban extensions to the town.



7.9 Our submissions to the previous drafts stated that the Council should be identifying

strategic sites to meet the housing requirement. Our client’s specific strategic interest is

located to the north of the town centre. This site was the subject of a public inquiry in

December 2010 and the decision was issued in October 2011. Although the appeal was

dismissed the decision found the site to be acceptable with no site specific reasons for

refusal. That scheme proposed 1,300 dwellings and we consider that this level of

development remains appropriate although the site can be phased.

7.10 The Statement of Common Ground for that appeal between the Council and our client

confirmed that the site is well located to the town centre and is a sustainable location for

development. This fully accords with the test in the Framework which has a presumption

in favour of sustainable development.

7.11 We consider that the merits of the site go further and it is not just another greenfield

urban extension on the edge of a large town which can be considered sustainable. In

addition to its excellent proximity to St Austell town centre, it also has excellent access to

the rail and bus stations, Poltair School, Cornwall College and existing employment areas

immediately to the north, east and south. For ease of reference the key distances are:

Current bus service provision within the vicinity of the proposed development

site is excellent, with numerous bus stops located along Treverbyn and

Tregonissey Road situated within 400 metres walking distance.

The St Austell bus station and rail station are situated within 400m of the site’s

southern boundary. The rail station connects St Austell to Penzance, Truro,

Plymouth, Exeter, Bristol and London.

The town centre is located some 500m of the site’s southern boundary. The

northern boundary is some 2100m away. Therefore, the whole of the site is

within a 25 minute walk of the town centre. This is one of the unique

advantages of this site.

Cornwall College and Poltair School are immediately adjacent to the site. The

land provides the potential for the expansion of Cornwall College.

7.12 Therefore the sustainability and locational advantages of this site with a new population

within walking and cycling distance of these key facilities will assist with their vitality and

viability, particularly the redeveloped town centre. The proposed improvements to

infrastructure would reinforce and improve the sustainability further. The employment land

being provided would also accord with the Government’s Planning for Growth agenda

which is encapsulated in the Framework and the Employment Land Study which

recognises the need for better located employment sites in the CNA.



7.13 Therefore the land should therefore be identified as a strategic site in the Local Plan for:

“residential development of up to 1300 dwellings; up to 9000 square metres of floor space (B1, B2 and B8), ancillary retail floor space (use

classes A1, A2 and A5); leisure (A3 and A4); 60 bed care home (C2);

primary school (D1); strategic landscaping and public open space; community transport hub and an extension to Cornwall College.”

7.14 Part 5b of Policy PP9 allocates the land at West Carclaze/Baal Pit for 1,700 dwellings and

Par Docks for 550 dwellings. The policy also refers to the re-use of derelict or despoiled

land. However the reality is that the former China Clay sites are greenfield sites as they

are subject to restoration conditions. The timing of any restoration should not be an issue

with these sites coming forward as implied in the policy. In any case, the reality is that

meeting St Austell’s housing and employment needs at such locations is not as sustainable

as locating development that is contiguous with the urban area. Notwithstanding the

locational aspects of these sites, we have significant reservations questions over their

viability and deliverability.

8. POLICY PP11 BODMIN COMMUNITY NETWORK AREA

8.1 We support the identification of Bodmin as the key settlement in the CNA and that it

should be the focus for new development. This is a continuation of the policies in the

development plan and the evidence base for the abandoned Restormel Core Strategy and

the draft RSS. It is also supported by the evidence base for this Core Strategy which

identifies Bodmin as a Category A settlement, i.e. strategically significant towns which are

the main employment and service centres for the County.

8.2 We agree with Policy PP9 that Bodmin will continue to grow and to do this the only option

available is for greenfield urban extensions to the town. The issue for the Core Strategy is

the level of development and two options in the previous draft were 1,000 dwellings and

5,000 dwellings. The figure now being advanced is 3,000 dwellings. We consider that this

requirement is broadly correct for a town of Bodmin’s size on that requirement. However,

and crucially:

that requirement is predicated on the suitability of the 47,500 dwelling

requirement for Cornwall. We have set out our concerns with the requirement in

our representations to Policy 2; and,

is based on a step change in delivery and new infrastructure so this overall

requirement may not be deliverable.



9. PP14 LAUNCESTON COMMUNITY NETWORK AREA

9.1 We agree that the 8 objectives identified require Launceston to grow and to do this the

only option available is for greenfield urban extensions to the town. We note that the

‘Town Framework Plan’ identifies a number of preferred sites to meet the future housing

needs.

9.2 As Launceston is the key settlement in the CNA then it should be the focus for new

development. This is recognised in the Settlements: Hierarchy and Settlement Categories

Background Paper which identifies it as the highest scoring Category B settlement in the

CNA. Category B settlements are towns that are locally significant and contain a good

range of housing, employment, and community facilities and services.

9.3 The requirement for the CNA is 1,900 dwellings, of which 1,500 would be developed at

Launceston town. We have set out our concerns with the 47,500 dwelling requirement in

Section 3 of these representations, therefore Launceston should be delivering a greater

number of dwellings over the plan period as the residual requirement to 2030 is some 512

dwellings. This does not reflect the scale and role of the town and is a significant reduction

in the number of completions since 1991 (approx 190) to the 95 dwellings per annum now

proposed.

9.4 Our client controls two areas of land to the south of Launceston which is identified in the

proposed KUE4 allocation. The first is the land east of Hurdon Way which has an extant

consent and is being built. The second is (Withnoe Farm) which is located to the east of

the land which now has a resolution to grant planning permission (PA11/00339) for 290 to

330 dwellings. Therefore some 500 dwellings are already committed in this location so it is

clearly the most appropriate site for the town to expand and can provide some 150

dwellings.

10. PP15 LISKEARD AND LOOE COMMUNITY NETWORK AREA

10.1 Policy PP15 proposes 2,000 dwellings between 2010 and 2030. Of that overall figure of

2,000, 1,000 are proposed in and adjacent to Liskeard with 1,000 dwellings within the



each of the villages and we question whether 1,000 dwellings (of which 649 are completed


10.2 We do recognise that the allocation will be dealt with through a subsequent Allocations

Plan. Clearly some villages are more sustainable than others. Dobwalls is defined as a

Category D settlement which is defined as a smaller settlement that perform an important



role in their local areas, i.e. ‘rural service centres’ so is an obvious candidate to meet the

housing need in the CNA.


Local Plan Strategic Policies Presubmission document representation form Please return to Cornwall Council by 5.00pm on 22 April 2013 Please complete a separate sheet for each representation you wish to make (All representations will become public)

1111.... PPPPeeeerrrrssssoooonnnnaaaallll ddddeeeettttaaaaiiiillllssss.... 2222.... AAAAggggeeeennnntttt ddddeeeettttaaaaiiiillllssss ((((iiiiffff aaaapppppppplllliiiiccccaaaabbbblllleeee))))....

NNNNaaaammmmeeee OOOOrrrrggggaaaannnniiiissssaaaattttiiiioooonnnn

AAAAddddddddrrrreeeessssssss lllliiiinnnneeee 1111 AAAAddddddddrrrreeeessssssss lllliiiinnnneeee 2222 AAAAddddddddrrrreeeessssssss lllliiiinnnneeee 3333 AAAAddddddddrrrreeeessssssss lllliiiinnnneeee 4444 PPPPoooossssttttccccooooddddeeee TTTTeeeelllleeeepppphhhhoooonnnneeee nnnnuuuummmmbbbbeeeerrrr EEEEmmmmaaaaiiiillll aaaaddddddddrrrreeeessssssss

Wainhomes (South West) Holdings Ltd

Stephen Harris Emery Planning Partnership

24 South Park Court Hobson Street Macclesfield

SK11 8BS


No. Please see Section 2 of the attached report.

Q2. A local planning authority should submit a plan for examination which it considers to be ‘sound’ namely that it is; positively prepared, justified, effective and is consistent with national policy. Do you consider the Plan has met these tests?

Yes No


Please see the attached report

6162

Typewritten Text

599

6162

Typewritten Text

Q3. Please set out below any concerns you have with the Local Plan including any change(s) you consider necessary to address these concerns.

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

Please state which paragraph or policy your change refers to and specify the reasons below:

Document Paragraph number Policy number Cornwall Local Plan Strategic Policies

2


Please see section 3 of the attached report


3




8




PP6




PP9




PP11




PP14




PP15



Q4. Did you raise this issue earlier in the plan preparation process?

Yes No

If yes, please specify at what stage:

Options stage and Preferred Approach stage


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


Completed forms should be submitted:

by email to: [email protected] by post to: Cornwall Council Local Plans Team Carrick House St Clement Street Truro TR1 1EB

Please submit any views to Cornwall Council using the above methods by 5:00pm on 22 April 2013.

Next steps The representations received during this formal round of consultation will be reported to and considered by the Council. Any significant changes will be consulted on prior to consideration by the planning inspectorate, who will appoint an inspector to conduct an examination in public.

Cornwall CouncilLocal Plan Pre Submission Consultation

REPRESENTATIONS BY�

WAINHOMES (SOUTH WEST) HOLDINGS LTD�

EPP reference: REPS2-6412-SH-jb

April 2013

CONTENTS:

1.� INTRODUCTION 1�

2.� GENERAL MATTERS 1�

3.� LEVELS OF HOUSING GROWTH AND SETTLEMENT HIERARCHY�(POLICY 2 AND POLICY 3) 2�

4.� POLICY 8 AFFORDABLE HOUSING 7�

5.� PP9 ST AUSTELL AND MEVAGISSEY, CHINA CLAY, ST BLAZEY,�FOWEY AND LOSTWITHIEL COMMUNITY NETWORK AREA 8�

6.� POLICY PP11 BODMIN COMMUNITY NETWORK AREA 10�

7.� PP14 LAUNCESTON COMMUNITY NETWORK AREA 11�

8.� PP6 TRURO AND ROSELAND COMMUNITY NETWORK AREA 12�

9.� PP15 LISKEARD AND LOOE COMMUNITY NETWORK AREA 12�

Cornwall Council Local Plan Pre Submission Draft March 2013 Representations by Wainhomes (South West) Holdings Ltd

1.� INTRODUCTION

1.1 Emery Planning Partnership is instructed by Wainhomes (South West) Holdings Limited to

submit representations to the Pre-Submission Draft of the Local Plan (the Plan).

Wainhomes is a key developer within Cornwall and will be an important delivery partner

for the Council in providing its open market and affordable housing needs over the next 20

years. Their landholdings and developments can also facilitate further mixed use

development including employment and social infrastructure.

1.2 These representations concentrate on the overarching policy issues such as the housing

requirement and its distribution as well as the specific Community Network Areas. We set

out our client’s interests to demonstrate a deliverable supply of sites.

2.� GENERAL MATTERS

Legal Compliance and Procedural Requirements

2.1 Our previous submissions raised concern with the Plan as we considered that it did not

provide a suitable framework for determining where, when and how the correct amount of

housing will be delivered. These concerns remain and given the guidance in the NPPF

perhaps more so as the Local Plan should meet the various tests in paragraph 157. We do

not repeat them here but it is clear that the Plan should be indicating broad locations for

strategic development on a key diagram, land-use designations on a proposals map and

allocate sites to promote development.

2.2 Therefore at this stage in the process the Council should be identifying which sites they

consider are appropriate and including a housing trajectory as to how these sites will meet

the requirement over the plan period. The Plan does neither. The only way forward is a

further consultation with preferred allocations which can then be taken into account in the

next stage of the Plan.

2.3 There is also an issue due to the Strategic Housing Market Assessment not being finalised

and taken into account in the plan. The SHMA is a fundamental part of any plan yet the

housing requirement has been prepared without an up to date study. The SHMA is being

undertaken in collaboration with Plymouth City Council, South Hams District Council, West

Devon Borough Council and Dartmoor National Park. The publication of the SHMA will

have cross boundary issues particularly with regard to the housing requirement. Therefore

the Plan cannot be legally complaint as the Sustainability Appraisal is based on a

requirement that is not sound and there has yet to be any cross boundary working on the

outcome of the SHMA.



Plan Period

2.4 The proposed plan period is 2010 to 2030 which we support. This accords with paragraph

157 of the NPPF which advocates a time horizon of at least 15 years.

2.5 We will examine the housing requirement in greater detail in subsequent sections.

However it is important that any shortfalls from before 2010 are accounted for and then

met in the new plan period.

3.� LEVELS OF HOUSING GROWTH AND SETTLEMENT HIERARCHY (POLICY 2 AND POLICY 3)

3.1 The Core Strategy Preferred Options dated January 2012 set a minimum 20 year target of

48,000 homes. This was the middle option from the three housing options set out at the

Issues and Options stage in April 2011, which were:

• Low – 38,000 dwellings - 1,900 dwellings per annum;

• Medium – 48,000 - 2,400 dwellings per annum; and,

• High – 57,000 - 2,850 dwellings per annum.

3.2 In our representations dated March 2012 we set out the evidence to justify the high option

along with meeting the accumulated backlog resulting in a requirement of 66,000

dwellings. Since that consultation closed the Government has issued the NPPF which

provides the guidance on determining what the housing requirement should be. Paragraph

159 states that local planning authorities should have a clear understanding of housing

needs in their area. Paragraph 47 also requires local planning authorities to meet their full,

objectively assessed needs.

3.3 We consider that the evolution of the Plan through the committee system of the Council

demonstrates that it does not have a clear understanding of its housing need. The

resulting requirement of 42,250 dwellings is not sound and we set out the reasons for this

position below.

3.4 There are two key components to determine the housing requirement, these being the

Strategic Housing Market Assessment and the Strategic Housing Land Availability

Assessment. In essence these two documents should determine what the requirement is

to meet the full objectively based housing requirement and whether the council has

sufficient land to meet that need.

Strategic Housing Market Assessment (SHMA)

3.5 Paragraph 159 of the NPPF advises that a SHMA should:



• meet household and population projections, taking account of migration and

demographic change;

• address the need for all types of housing, including affordable housing and the

needs of different groups in the community (such as, but not limited to, families

with children, older people, people with disabilities, service families and people

wishing to build their own homes); and

• caters for housing demand and the scale of housing supply necessary to meet

this demand.

3.6 These are three different but important components. We assess each in turn.

Household Projections

3.7 The interim 2011 based projections which were published in April 2013 indicate an

increase in the number of households between 2011 and 2021 of 24,000. If this is

extrapolated over the plan period (2010-2021), then the requirement for Cornwall would

be 48,000 dwellings. Housing projections should be the starting point when determining

the requirement and should be the minimum going forward as there are two other

components to assess, these being affordable housing need and housing demand.


3.8 At the last consultation stage the Cornwall SHMA (July 2010) was deemed by the Council

to be out of date and at that stage we stated that it should be reviewed urgently.

However, an up to date SHMA is not available as it is yet to be completed. This calls the

soundness of the plan into question when a fundamental building block is missing. Indeed

the SHLAA is yet to be finalised as yet although the previous versions were clear that there

is a significant supply of developable and deliverable land across Cornwall so the

availability of land is not a constraint to determining the housing requirement.

3.9 That 2010 SHMA made an overall recommendation of 2,410 open market dwellings and

1,570 affordable homes per annum. We cannot see how the updated SHMA can make a

significant change to these conclusions. Indeed, the latest information available is that

there are 26,000 households on the Homechoice register that requires affordable housing.

That is a need that exists now yet it is some 60% of the total requirement planned for in

the Plan to 2030. This is a clear indicator that 42,250 dwellings is too low and should be

increased significantly.

Backlog

3.10 The backlog in affordable housing is one of the factors included within the 2010 SHMA in

determining the level of housing need for the next 20 years.



3.11 The SHMA quantifies this in paragraph 7.27, which states:

“Current housing need in Cornwall is therefore estimated to be 8,075.

This number constitutes Core Output 4 required by the Practice

Guidance. It is worth stressing that this is a conservative estimate (i.e.

is likely to be an undercount) as there will undoubtedly be households

in housing need that have not registered themselves with Cornwall

Homechoice.”

3.12 From our reading of the Plan this backlog has not been included and it should be as that

need remains as evidenced in the Homechoice register.

Housing Demand

3.13 A number of other documents form part of the evidence base. We assess them below.

Housing Requirement for Cornwall October 2012

3.14 This report was prepared by Peter Brett Associates. Table 5.1 of that report sets out 7

different scenarios which lie within a range of 49,700 and 95,000 dwellings. It is clear the

requirement of 42,250 dwellings being consulted upon is well below all these scenarios.

We note that the report discounts the 95,000 requirement so the upper end of the range

is reduced to 68,600 dwellings.

3.15 Paragraph 5.2.5 states that suppressing housing provision below actual demand may

mean that lower income residents in need of a home lose out to wealthier in-migrants.

The lowest scenario E1 (49,700 dwellings) therefore needs to be balanced against what

the demographic information is showing and should the Council wish to pursue a growing

population and economic growth then they will need immigration to increase the

economically active population. Therefore the clear implication of this position is that the

lowest scenario would suppress housing provision.

3.16 Paragraph 5.2.7 then states that completion rates show that around 2,264 dwellings have

been delivered each year on average and the housebuilding industry could be expected to

continue to deliver at a similar level. We consider that this is a rather pessimistic

statement as the development industry has been operating in a planning vacuum with no

up to date development plan with allocations for a large proportion of the last 10 years. In

addition we have had a significant economic recession and with a plan until 2030 we

would fully expect the development industry to increase delivery. Indeed, paragraph 5.2.8

refers to “pent up demand” so it is clear that the previous build rates have not meet actual

demand. The only solution is for a higher requirement.

3.17 To take that previous point forward, the 2011-2012 AMR sets out the completions per

annum since 2001. For ease of reference these are set out in the table below.



01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11

2,485 2,639 2,183 2,495 2,084 2,612 3,179 2,877 2,473 2,060

3.18 This table demonstrates that the proposed requirement of 2,100 dwellings is actually

below what has been delivered in all but one of the years. In addition in those 10 years

there have been 25,087 completions, which equates to an average annual completion rate

of 2,508 dwellings. Both these calculations clearly demonstrate that the requirement will

suppress housing delivery and drive up prices. This will only increase the substantial

affordable housing need, which currently sits at 26,000 on the Homechoice register.

3.19 In addition it would clearly mean that the development industry would have to downsize

as the proposed requirement is lower than previous completions. Therefore rather than

the development industry being a key component for growth over the plan period which is

what the Government expects from Planning for Growth and the NPPF, the emerging plan

will be have the reverse effect.

Economic Projections

3.20 Section 4 of the Housing Growth and Distribution Pre Submission Version assesses the

economic projections. Three different figures are advanced in Figure 7, which are 49,700,

68,600 and 95,000 dwellings.

3.21 The NPPF reflects the Planning for Growth (Ministerial Statement 23rd March 2011). This

sets out that the Government’s top priority in reforming the planning system is to promote

sustainable economic growth and jobs. The Government’s clear expectation is that the

answer to development and growth should wherever possible be ‘yes’ except where this

would compromise the key sustainable development principles set out in national planning

policy. It is important to note that residential development is capable of being an

economic benefit due to construction jobs and the supply chain to developers, and the

overall benefits to the economy that are to be achieved through providing the correct level

of housing sufficient to meet the needs of the population. However it is also critically

important to provide the necessary range of housing to meet those currently or projected

to be employed in Cornwall.

3.22 Paragraph 7 of the NPPF is clear that a key part of sustainable development is contributing

to building a strong, responsive and competitive economy, by ensuring that sufficient land

of the right type is available in the right places and at the right time to support growth and

innovation; and by identifying and coordinating development requirements, including the

provision of infrastructure.



3.23 An example of the plan for increased economic activity is the Newquay Aerohub. It is

referred to as England's only aerospace focused Enterprise Zone, with significant

development land and access to investment. The Aerohub has been established for

businesses related to the aerospace and aviation industry, advanced engineering and

marine, energy and environment related development. This is also investment in the

creation of the Aerospace Learning Centre. The intention is for the Aerohub to deliver over

700 jobs in direct aerospace and a further 375 in the wider economy over the next five

years.

3.24 From this one example it is clear from the proposasls for the Aerohub that new housing

must be provided as the specialised jobs that are to be created are likely to increase

immigration to Cornwall.

3.25 The Plan as currently drafted is in direct conflict with the Government’s agenda for growth

due to it having a lower requirement that has been historically delivered and s based on

lower immigration when new economic developments such as the Aerohub will require

immigrationfor the specialised jobs.

Housing Growth and Distribution Pre Submission Version

3.26 This paper seeks to pull together the various evidence documents. The graph on page 1 of

the Executive Summary (see below) shows how the proposed requirement is totally

inadequate for the future of Cornwall as it is outside the range of 3 of the key parts of the

evidence base, at the lowest end of the fourth and in the lower quartile of the last. The

only conclusion that we can draw is that the plan is directly contrary to paragraph 47

which requires local planning authorities “to ensure that their Local Plan meets the full,

objectively assessed needs for market and affordable housing in the housing market area”.



3.27 The requirement that the Council should be proceeding with should be in the region of

66,000 dwellings which is the figure that we advanced at the last consultation. This is

because:

• This would be within the mid to upper range of 4 of the documents in the

evidence base.

• It would be higher than previous delivery. However as we note above the

development industry has been operating without an adopted development plan

as well as a deep economic recession. As the Plan is to 2030 we would expect

those rates to increase.

• The higher level of delivery that now proposed has resulted in a 26,000 waiting

list on Homechoice, therefore it is counterintuitive to now propose a lower level

of growth.

4.� POLICY 8 AFFORDABLE HOUSING

4.1 The Council must strike the right balance between affordable housing and CIL. They have

sought to do this through the Housing Strategic Viability Appraisal (HSVA). This tests a

range of scenarios and these are summarised in the box at paragraph 9.4 of the main CIL

consultation document. Paragraph 9.4 states that higher affordable housing thresholds

have been set as these are negotiable, whereas CIL is non negotiable. Policy 8 of the Draft

Local Plan accords with this in that the affordable housing requirements are set as targets.

4.2 However paragraph 7.6 of the CIL consultation document states that there is a funding

shortfall of £510m for critical and necessary projects for transport, education, green and

blue infrastructure, post 16 education and skills, health, emergency services and flooding

infrastructure. Paragraph 7.6 then advises that CIL is expected to raise some £62m over

the local plan period. This still leaves a funding shortfall of some £448m to be found from

other sources.

4.3 Therefore the point we wish to raise at this stage is whether it is prudent to seek what is

the maximum amount of CIL assessed in the HSVA when there is such a significant

funding gap to actually deliver these projects at the expense of a lower affordable housing

threshold when affordable housing delivery is paramount and a key community objective.

4.4 Paragraph 7.23 of the HVSA uses St Austell as a specific example. This states that

anything above 20% affordable housing with £40 CIL on smaller urban schemes and 25%

affordable housing with £70 on larger greenfield sites is unlikely to be viable. However the

target for affordable housing in St Austell is set in Policy 8 as 40%. This was a belated

change to the affordable housing requirement for St Austell which was 30% in the



committee draft the Pre-Submission Draft. Therefore on the evidence in the HSVA, St

Austell would never achieve a target of 40% affordable housing. Therefore a lower target

of 30% may well be necessary for bands 4 and 5.

5.� PP9 ST AUSTELL AND MEVAGISSEY, CHINA CLAY, ST BLAZEY, FOWEY AND LOSTWITHIEL COMMUNITY NETWORK AREA

5.1 This wider CNA covers three separate CNAs, these being:

• St Austell;

• St Blazey, Fowey and Lostwithiel; and,

• China Clay.

5.2 We have a number of land interests for allocation in this area which are as follows:

• Land at Treverbyn Road, St Austell;

• Land at Charlestown;

• Portpean Road, St Austell;

• Meanear Road, St Austell;

• Mount Crescent, Par; and,

• Tredenham Farm, St Blazey.

Housing Requirement

5.3 Table 1 of the Plan shows the distribution of the housing requirement. A number of points

arise.

5.4 First, St Austell should be given a greater proportion of the requirement as it is a

strategically significant town and is a key employment and service centre for the County.

This would be a continuation of the policies in the development plan and the evidence

base for the now abandoned Restormel Core Strategy and the draft RSS. The table below

shows the imbalance of the provision given to St Austell.

Housing Req

Camborne/Pool/Illogan/Redruth 4,000

Falmouth/Penryn 3,200

Truro (inc Threemilestone) 2,200

St Austell 1,700

Newquay 3,000

Penzance 1,400

Bodmin 3,000

5.5 Page 97 of the Plan states that the annual completion rate in the St Austell and

Mevagissey CNA is 213 dwellings. The Plan as drafted would provide for 85 dwellings per

annum. This is a clear conflict with NPPF.



5.6 In addition, the delivery of new affordable housing has not kept pace with the level of

housing need established in the Housing Requirement Study in St Austell. Between

2006/07 and 2010/11, 208 affordable units were completed which leaves a shortfall of 723

affordable homes in the St Austell area.

5.7 What is clear is that St Austell must grow and to do this the only option available is for

greenfield urban extensions to the town. We support this as there is limited previously

developed land within the urban area. It is now recognised in the Plan as paragraph 12.21

states that the growth of St Austell is likely to occur on the edge of the town but outside

the St Austell CNA. The boundary of the St Austell CNA is not well defined in the Plan and

this needs to be rectified. However the CNAs are defined our position is that land

contiguous with the urban area is required. Our client’s land interests appended to this

statement sets out a number of deliverable sites that would be sustainable urban

extensions to the town.

5.8 Our submissions to the previous drafts stated that the Council should be identifying

strategic sites to meet the housing requirement. Our client’s specific strategic interest is

located to the north of the town centre. This site was the subject of a public inquiry in

December 2010 and the decision was issued in October 2011. Although the appeal was

dismissed the decision found the site to be acceptable with no site specific reasons for

refusal. That scheme proposed 1,300 dwellings and we consider that this level of

development remains appropriate although the site can be phased.

5.9 The Statement of Common Ground for that appeal between the Council and our client

confirmed that the site is well located to the town centre and is a sustainable location for

development. This fully accords with the test in NPPF which has a presumption in favour

of sustainable development.

5.10 We consider that the merits of the site go further and it is not just another greenfield

urban extension on the edge of a large town which can be considered sustainable. In

addition to its excellent proximity to St Austell town centre, it also has excellent access to

the rail and bus stations, Poltair School, Cornwall College and existing employment areas

immediately to the north, east and south. For ease of reference the key distances are:

• Current bus service provision within the vicinity of the proposed development

site is excellent, with numerous bus stops located along Treverbyn and

Tregonissey Road situated within 400 metres walking distance.

• The St Austell bus station and rail station are situated within 400m of the site’s

southern boundary. The rail station connects St Austell to Penzance, Truro,

Plymouth, Exeter, Bristol and London.



• The town centre is located some 500m of the site’s southern boundary. The

northern boundary is some 2100m away. Therefore, the whole of the site is

within a 25 minute walk of the town centre. This is one of the unique

advantages of this site.

• Cornwall College and Poltair School are immediately adjacent to the site. The

land provides the potential for the expansion of Cornwall College.

5.11 Therefore the sustainability and locational advantages of this site with a new population

within walking and cycling distance of these key facilities will assist with their vitality and

viability, particularly the redeveloped town centre. The proposed improvements to

infrastructure would reinforce and improve the sustainability further. The employment land

being provided would also accord with the Government’s Planning for Growth agenda

which is encapsulated in NPPF and the Employment Land Study which recognises the need

for better located employment sites in the CNA.

5.12 Therefore the land should therefore be identified as a strategic site in the Core Strategy

for:

“residential development of up to 1300 dwellings; up to 9000 square

metres of floor space (B1, B2 and B8), ancillary retail floor space (use

classes A1, A2 and A5); leisure (A3 and A4); 60 bed care home (C2);

primary school (D1); strategic landscaping and public open space; community transport hub and an extension to Cornwall College.”

5.13 Part 5b of Policy PP9 allocates the land at West Carclaze/Baal Pit for 1,750 dwellings and

Par Docks for 550 dwellings. The policy also refers to the re-use of derelict or despoiled

land. However the reality is that the former China Clay sites are greenfield sites as they

are subject to restoration conditions. The timing of any restoration should not be an issue

with these sites coming forward as implied in the policy. In any case, the reality is that

meeting St Austell’s housing and employment needs at such locations is not as sustainable

as locating development that is contiguous with the urban area. Notwithstanding the

locational aspects of these sites, we have significant reservations questions over their

viability and deliverability.

6.� POLICY PP11 BODMIN COMMUNITY NETWORK AREA

6.1 We support the identification of Bodmin as the key settlement in the CNA and that it

should be the focus for new development. This is a continuation of the policies in the

development plan and the evidence base for the abandoned Restormel Core Strategy and

the draft RSS. It is also supported by the evidence base for this Core Strategy which

identifies Bodmin as a Category A settlement, i.e. strategically significant towns which are

the main employment and service centres for the County.



6.2 We agree with Policy PP9 that Bodmin will continue to grow and to do this the only option

available is for greenfield urban extensions to the town. The issue for the Core Strategy is

the level of development and two options in the previous draft were 1,000 dwellings and

5,000 dwellings. The figure now being advanced is 3,000 dwellings. We consider that this

requirement is broadly correct for a town of Bodmin’s size. However:

• that requirement is predicated on the suitability of the 42,250 dwelling

requirement for Cornwall. We have set out our concerns with the 42,250

dwelling requirement; and,

• is based on a step change in delivery and new infrastructure so this overall

requirement may not be deliverable.

7.� PP14 LAUNCESTON COMMUNITY NETWORK AREA

7.1 We agree that the 8 objectives identified require Launceston to grow and to do this the

only option available is for greenfield urban extensions to the town. We note that the

‘Town Framework Plan’ identifies a number of preferred sites to meet the future housing

needs.

7.2 As Launceston is the key settlement in the CNA then it should be the focus for new

development. This is recognised in the Settlements: Hierarchy and Settlement Categories

Background Paper which identifies it as the highest scoring Category B settlement in the

CNA. Category B settlements are towns that are locally significant and contain a good

range of housing, employment, and community facilities and services.

7.3 The requirement for the CNA is 1,500 dwellings, of which 1,100 would be developed at

Launceston town. This is a reduction from the 1,900 dwellings in the Preferred Approach.

We have set out our concerns with the 42,250 dwelling requirement in Section 3 of these

representations, therefore Launceston should be delivering a greater number of dwellings

over the plan period as the residual requirement to 2030 is some 326 dwellings. This does

not reflect the scale and role of the town and is a significant reduction in the number of

completions since 1991 (approx 190) to the 75 dwellings per annum now proposed.

7.4 Our client controls two areas of land to the south of Launceston which is identified in the

proposed KUE4 allocation. The first is the land east of Hurdon Way which has an extant

consent and is being built. The second is (Withnoe Farm) which is located to the east of

the land which now has a resolution to grant planning permission (PA11/00339) for 290 to

330 dwellings. Therefore some 500 dwellings are already committed in this location so it is

clearly the most appropriate site for the town to expand and can provide some 150

dwellings.



8.� PP6 TRURO AND ROSELAND COMMUNITY NETWORK AREA


3,000, 2,200 are proposed in and adjacent to Truro city. Clearly Truro should take the

significant proportion of the overall development. However only 800 dwellings are

proposed within the remainder of the Community Network Area. Figure 10 identifies 12

smaller settlements within this CNA. However the Plan is silent on how much development

should be located in each of the villages and we question whether 800 dwellings (of which

403 are completed or committed) is sufficient to meet the needs of each of these villages.

8.2 Clearly some villages are more sustainable than others. Probus is defined as a Category D

settlement which is defined as a smaller settlement that performs an important role in

their local areas, i.e. ‘rural service centres’. The full list of Category D settlements are

Grampound, Probus, Shortlanesend, St Mawes, Tregony, Trispen and Veryan. Of these

Probus scores the highest.

8.3 The Category E settlements are those that include either a primary school or a general

store and are Chacewater, Devoran, Grampound Road, Ladock and St Just in Roseland.

8.4 In addition, Truro has been unable to deliver its housing requirements. Therefore a more

dispersed strategy is more likely to lead to the delivery of the requirement within the plan

period and on that basis greater recognition should be given to the other settlements in

the Truro CNA whilst retaining Truro as the main focus.

9.� PP15 LISKEARD AND LOOE COMMUNITY NETWORK AREA


2,000, 1,000 are proposed in and adjacent to Liskeard with 1,000 dwellings within the



each of the villages and we question whether 1,000 dwellings (of which 649 are completed


9.2 We do recognise that the allocation will be dealt with through a subsequent Allocations

Plan. Clearly some villages are more sustainable than others. Dobwalls is defined as a

Category D settlement which is defined as a smaller settlement that perform an important

role in their local areas, i.e. ‘rural service centres’ so is an obvious candidate to meet the

housing need in the CNA.
