401 local plan – strategic policies · 2014-01-06 · 401 local plan – strategic policies...

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Local Plan – Strategic Policies Pre-submission 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 Clare Moody Organisation EMBB Address line 1 Trelay Address line 2 Stgennys Address line 3 Bude Address line 4 Postcode EX23 0NJ Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements?

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?

Please specify the reasons below

The plan is not sound because there is a major conflict between the policy of sustainability and the proposed growth of an unsustainable economy.

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.

Yes NoX

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Representations 401-450

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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

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Sustainability Appraisal Report

Add: “Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.” Background information: “A cohousing community is a type of intentional community composed of private homes supplemented by shared facilities. The community is planned, owned and managed by the residents – who also share activities which may include cooking, dining, child care, gardening, and governance of the community. Common facilities may include a kitchen, dining room, laundry, child care facilities, offices, internet access, guest rooms, and recreational features. Cohousing facilitates interaction among neighbours for social and practical benefits, economic and environmental benefits.” Evidence: An example is seen in Tan 6 (One Planet Development) in Wales. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 5 7


Add new paragraph 5: “Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.” Evidence: This kind of development, by its nature, is resilient and sustainable. There is already a pioneering cohousing development in North Cornwall, and Cornwall could become a leader in supporting such sustainable settlements.

Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

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Add at the end: “All farms and settlements, including farms and small settlements in AONBs, will be permitted to have sufficient renewable energy equipment installed to meet their own energy needs.” Evidence: This would meet national renewable energy policies, allow self-sufficiency at the local level, support the localism agenda, and encourage rural sustainable development. By only allowing sufficient equipment installed to meet the needs of the settlement, it would be low impact. Q4. Did you raise this issue earlier in the plan preparation process?

If yes, please specify at what stage: Q5. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

x

Yes I wish to participate at the examination in public

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. Completed forms should be submitted: by e-mail 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.

Yes NoX

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Name Beryl Hodge (Mrs) Organisation Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? Do not know


Please specify the reasons below Do not know

Yes No

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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

18.9 (2nd sentence) PP15 Remainder of Liskeard & Looe CNA


I do not think it is right to say in the Plan that Looe is able to support more house building than other settlements in the area just because it has a good range of facilities and a rail connection to Liskeard. The roads here are narrow and not fit for purpose and the recent Barratt estate is an eyesore on the hillside and damaging to tourism. Jobs are mostly seasonal and poorly paid so people living here will have to commute to larger towns like Liskeard, Bodmin or Plymouth for work. Therefore I ask you to please remove this sentence from the document because until we have carried the neighbourhood plan, which I’m told the town council is now working on, there is no way of knowing if extra development is appropriate or where it can be located. With thanks Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies


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

If yes, please specify at what stage: no

Yes No

Q5. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

no




403



Name James Shrubsole Organisation Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? As I have been unable to view the Town Framework for Liskeard this is an incomplete consultation, and I hope we will be invited to submit further comments when we have the benefit of a full set of documentation Nevertheless I do want to comment on those areas that are complete and available


Please specify the reasons below As above, it is difficult to see how this consultation can be wholly sound or effective if crucial documents are not yet available (i.e. the Town Framework for Liskeard and other towns). It is also very difficult to navigate around the documentation online, and the large number of links makes this more difficult. Could further consultation please be easier for all to access?

no

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1.27, 1.36 housing need Policy3


1. The figures for Liskeard - completions and commitments - given in the table, p.17 (320 new houses) appear to be incorrect and are different from those in the Town Framework background paper-Potential housing sites – (680 houses needed), meaning that the remaining requirement to reach 1000 houses by 2030 is 320 NOT 680 (your breakdown chart concludes that this figure is the correct one)

2. This represents a buffer of 13.6 years worth of building to meet the 2030 target – way above the 5 year buffer demanded, so we are already well above our need allocation.

3. I cannot see the usefulness of allocating possible sites for 9,000 houses in Liskeard – this is 21% of the total need for all of Cornwall! and encircles the entire town with areas of planning blight.

4. These are all green-field sites, many of them valuable farming land, and of landscape value, which if lost to housing, would diminish the ability to achieve so many other targets – i.e. protection of traditional/local jobs, especially agriculture in this good farming area- objective 9 part C – “supporting local food production” (& including greater requirement of allotment space as there is a long waiting list – policy 17 point4); preserving the character and landscape heritage of Liskeard and surroundings with our excellent green link to the mining heritage area to the North.

From so many standpoints in the underlying principles of the local plan, there should surely be a whittling down of the proposed sites –

A) We only need 320 more houses to meet our target for 20 years time! B) We don’t have any current employment prospects for the 680 units

already planned Many people already travel out of Liskeard for work (& will no doubt continue to do so) therefore any new housing needs to be close to our major A38 road network and the(much underplayed in your report) mainline rail station (more than 400,000 journeys begin or end at Liskeard per year). This makes both economic and environmental sense as your planning principles highlight. C) There is already extensive development to the North of the town (and

planning permission for a further 475 houses) which is furthest away from our existing transport links, & also causing further issues re sewerage, surface water drainage, and more traffic flow problems into the already weak network at the top end of the town centre.

D) This needs to be balanced by development to the South of the town (including S.West & S. East) around the A38 and station.

E) This would then actually fulfil your principles of feeding into existing transport links and promoting sustainable travel. Liskeard already has an excellent transport network, which could be utilised more effectively by focussing development to the S.W/South/S.E. end of town.

F) As has already been suggested, an alternative to an enhanced Moorswater junction, could be a full-flow junction on flat land in the vicinity of the Enterprise Centre from A38 to Station rd allowing good access for any development to the South and linking with our railway, and town centre without adding to the volume of through traffic. Indeed it could relieve present pressure around B3254/Barras Place/Pound St. This would appear to be an omission from the Town framework background paper on infrastructure, & certainly should be looked at alongside any Moorswater proposals.


1.d p126 PP15 Liskeard area network plan


“Retention and enhancement of heritage assets with physical linkage between Liskeard and the ….World Heritage Site”. Development of housing to the North of the town is incompatible with this principle in your plan and would completely destroy the emerging tourist/recreational potential of this side of Liskeard. The Portas bid recognised Liskeards quality hinterland as well as its historic centre; It has recently gained status as a “walking town”; it has just been voted 12th in a Times poll of 30 best towns in Britain; and CHAHPs are in process of designating a quiet, back-roads cycleway to our rich moorland and heritage sites including Golitha Falls and Cheesewring utilising the ancient sunken lanes and passing through medieval field structures and a proposed area of great landscape value just on the outskirts of our town. This route out of town is already heavily used by local residents to quickly and easily access the green countryside – walking, running groups, dogwalking, cycling, horse-riding. (policy 17 health and well-being point 2) You acknowledge this “..internationally famous … World Heritage status” followed by “Today we have a growing reputation in environmental protection” on p8 of the introduction to the whole plan. How can this be reconciled with potential large-scale development in this linkage area? Liskeard should have the opportunity to develop this aspect as part of the promotion of SE Cornwall tourism, which Cornwall council fully supports, and it is not incompatible with sensible development, providing the town is not completely encircled with proposed housing as shown on present documentation (town framework background paper potential housing sites

assessment app3 map) Liskeard has many assets and future planning should recognise and value these. With the new localism act, hopefully local people can work more closely with the council to achieve a mutually agreeable solution. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies





If yes, please specify at what stage: During Core strategy consultation in 2011/12 – also attended “focus group” meeting in Truro Q5. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

no

Yes I wish to participate at the

Yes

examination in public 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. Completed forms should be submitted: by e-mail 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.


404 RESPONSE TO LOCAL PLAN NAME Joan Kay Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. >85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years. Joan Kay

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Name James Nightingale Organisation Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? Yes



The plan is not sound because there is a major conflict between the policy of sustainability and the proposed growth of an unsustainable economy.

Yes NoX

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0 2


Delete: “the most sustainable approach to accommodating growth” Add: “a sustainable approach to accommodating the improvement of well-being”. Evidence: Continuing growth is not possible if it involves the use of resources beyond their sustainable limits. “Sustainable economic growth” is an illogical term. The economy cannot grow indefinitely on a finite planet. Growth of happiness and quality of life is more important than material wealth. The aim of wellbeing is increasingly accepted as the way forward for regional and national policies. This is a key objective, for example, in Planning Policy (Wales). Health and well-being are covered in this Cornwall Local Plan in Policy 17. Because these are so important, we suggest that Policy 17 is renumbered as Policy 2. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New paragraph before para 1

2


Add: “Unsustainable development will not be supported. All jobs and businesses must be sustainable and appropriate, and be demonstrated to be so. All developments must be low carbon, and have built-in resilience to withstand the decline of resources such as oil and gas, and changes such as sea level rise.”

Comments: Policy 1 is a presumption in favour of sustainable development; Policy 2 must make it clear that unsustainable development will not be supported. Unsustainable development would mean that Cornwall was being developed now at the expense of future generations, which is not acceptable. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

1, 2 and 4 2


After each target number (50,000 jobs, 420,000 sq m of employment floorspace, 42,250 homes) add: “(or a lower number if that is all that can be supported sustainably)”. Evidence: A Local Plan that contains figures that are outside the limits of the carrying capacity of Cornwall will not be sound. Complementary evidence on the sustainable carrying capacity of Cornwall should be provided. The target figures look too high against the Government statistical projections for households based on recent population and household census and other data. By 2020 in Cornwall they expect 255,240 households. This is an extra 24,000 households. The most recent figure for homeless people in Cornwall is 70 individuals. https://www.gov.uk/government/uploads/system/uploads/attachment _data/file/189965/AllTablesNonRegionalFinal__3_.xls Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

5 2


Delete “wherever possible” before “adaptation to climate change”. Evidence: Adaptation to climate change is always possible and there should not be an implication that it is not always necessary.


8 b iv 3

2 5


Delete: Policy 2, paragraph 8 b iv Delete: Policy 3, paragraph 5 Evidence: The aircraft industry is not sustainable and conflicts with Policy 1 and Policy 2 paragraph 3. References to it should be deleted. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

8b 2


Add new sub-paragraph: “Fostering the development of Cornish food, building on the strengths of the Cornish food industry, which is becoming very successful. Support local food outlets in preference to increasing numbers of supermarkets.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

1 3


This policy should be made more reflective of the sustainable development objective of the Plan and should be rewritten to show this. Evidence: Larger scale developments are not necessarily more sustainable and resilient than dispersed developments. Supporting larger scale developments may conflict with Policy 1, Policy 2 para 3, and Policy 17. Larger scale developments have specific problems including:

o Increased local traffic o Increased risk of flooding through increased surface coverage o Increased overcrowding at local schools o Difficult to provide appropriate health service coverage o Lack of local shops and poor ability for community to develop

strong community links (important for social resilience) Larger scale developments can be made more sustainable in urban areas by incorporating land for food-growing, natural wild areas, recreational areas and community buildings. Careful design of schemes can reduce the carbon

footprint of a site and improve social cohesion. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

3 3


Add: “Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.” Background information: “A cohousing community is a type of intentional community composed of private homes supplemented by shared facilities. The community is planned, owned and managed by the residents – who also share activities which may include cooking, dining, child care, gardening, and governance of the community. Common facilities may include a kitchen, dining room, laundry, child care facilities, offices, internet access, guest rooms, and recreational features. Cohousing facilitates interaction among neighbours for social and practical benefits, economic and environmental benefits.” Evidence: An example is seen in Tan 6 (One Planet Development) in Wales. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

2 4


Add words shown in inverted commas: Community facilities and local shops should, wherever possible, be retained “and new ones supported”. “The development of local crafts, local food and other industries and services that retain money in the local economy will be supported.” “New megastores will not be supported except in exceptional circumstances where it can be shown that:

o No existing jobs would be lost o A high proportion of goods sold will be locally produced o They are sited in existing town centres and will not compete with

existing local stores” Evidence:

o Tesco proposal at Machynlleth showed a net loss of 264 jobs o Cornwall’s economy is very leaky - particularly for food and

megastore purchases where all the profit goes out of county. o The local multiplier for Megastores has been shown to be only

1.6 compared to local shops where one study showed 10 x. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 5 5


Add new paragraph 5: “Low carbon skills; renewable energy construction, maintenance and repair; sustainable building trades.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 3 6


Add new paragraph 3: “Homes must be built to low carbon standards from now onwards, at least to Code 4 by 2014, moving towards zero carbon by 2016.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 5 7


Add new paragraph 5: “Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.” Evidence: This kind of development, by its nature, is resilient and sustainable. There is already a pioneering cohousing development in North Cornwall, and Cornwall could become a leader in supporting such sustainable settlements. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

10


Add: “A proportion of publicly-owned sites should be made available for allotments, communal food-growing, sports and recreational areas, wild natural areas, and

community facilities.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 4 13


Add new paragraph 4: “The design of all new buildings and settlements must take future resilience into account. Roofs should be south-facing or close to south-facing to enable solar panels to be added. Local food-growing areas should be included. Development Site assessments should take sea level rise, and surface flooding increases due to climate change, into account, and planning decisions will support a long-term aim to remove infrastructure and developments out of areas expected to be inundated within the next fifty years.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 7 14


Add new paragraph 7: “Economical and environmental barriers (such as natural willow walls) must be erected for all new developments over 5 houses by main roads, to protect dwellings from noise and particulate emissions from vehicles.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

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Add at the end: “All farms and settlements, including farms and small settlements in AONBs, will be permitted to have sufficient renewable energy equipment installed to meet their own energy needs.” Evidence: This would meet national renewable energy policies, allow self-sufficiency at the local level, support the localism agenda, and encourage rural sustainable development. By only allowing sufficient equipment installed to meet the needs of the settlement, it would be low impact. Please note: The box on page 31 is incorrect in stating Cornwall uses £500m worth of energy per year. It is actually around £1.6bn. (See REOC Cornwall’s energy

bill.) Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

17


(As mentioned above, we think that this should be policy number 2.) Add to the end of paragraph 1: “and climate change impacts such as storm surges and sea level rise.” Also, please ensure that the housing densities mentioned elsewhere are not in conflict with this policy. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

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Add (after “realised”): “The Council will only support energy recovery facilities where:

o The proposed technology is not incineration o The applicant has demonstrated actions to reduce waste arisings

and increase recycling of all materials in the waste stream to be treated

o Facilities also include high tech materials sorting plant o The plant is of low impact”


2 20


Add in front of present a-c: “A The proposal includes high tech sorting and cleaning plant through which all materials entering the site will pass B Organic residuals from the sorting plant are composted and/or put through appropriate anaerobic digestion plant to reduce their BOD”


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Add (after paragraph h.): “i Screen noisy activities near to housing with earth banks, willow walls or similar noise abatement measures.” Document Paragraph number Policy numberCornwall Local Plan – Strategic Policies

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Sustainability Appraisal Report Delete paragraph 6. Add (to replace the wording of paragraph 6): “Critical biodiversity should not be destroyed and important environmental and historical characteristics should not be sacrificed. The precautionary principle should always be followed, and critical natural capital should be preserved. Any mitigation agreed for non-statutory sites or non BAP species should provide additional habitat to that replaced.” Evidence: Mitigation of environmental assets may, in many circumstances, be contrary to existing legislation (e.g. the Habitats Directive) and environmental regulations. New work emerging from the Government shows the value to us all of natural capital which generally far outweighs the value of developments. We suggest the Council builds on national government work on Sustainable Development Indicators to develop appropriate Indicators for Cornwall and work with for example Defra’s Ecosystem Markets Task Force report April 2013. http://sd.defra.gov.uk/2013/04/realising-natures-value-ecosystem-markets-task-force-finalreport/?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+gov%2F sdscene+%28SD+Scene%29 Accepting money in exchange for damage to significant environmental heritage is unacceptable and should not be public policy.


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Change “take account of” to “follow”. Add at the end: “Development will not be supported on flood plains, areas likely to suffer increased surface flooding, or areas where an impact from sea level rise is predicted.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

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The Cornwall Transport Plan is not realistic as it is based on large traffic increases over the Plan period. The Transport Plan should be updated and only then used as the basis of this Core Strategy policy development. The new Transport Plan needs to take account of the new realities of resource depletion (especially the ongoing decline of the availability of oil) and the high and rising prices of transport fuels, which are already leading to a reduction in local transport fuel use. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

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Add: “New classified roads will not be supported.” Evidence: The era of low-cost fossil fuels for personal transport has come to an end. This means that new roads are very unlikely to prove viable investments.


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Add: “No new classified roads will be approved, and local roads for new developments will not put car use at the centre of the developments. Infrastructure such as electricity supply, water supply and sewerage must be sustainable, low impact and low carbon and sited taking account of predicted changes in flood levels from climate change assessments.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

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Delete: “Contributions will be used to mitigate the impacts of developments (including any cumulative impact).” Add: “Critical biodiversity should not be destroyed and important environmental and historical characteristics should not be sacrificed. The precautionary principle should always be followed, and critical natural capital should be preserved. Any mitigation agreed for non-statutory sites or non BAP species should provide additional habitat to that replaced.” Evidence: Mitigation of environmental assets may, in many circumstances, be contrary to existing legislation (e.g. the Habitats Directive). Accepting money in exchange for damage to significant environmental heritage is unacceptable and should not be public policy.




X



Yes NoX

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Name Malcolm Mort Organisation Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural? requirements? These comments refer to PP15 Liskeard and Looe Community Network Area I do not know if it meets the necessary legal / Government requirements as I am unaware of what these are.


Please specify the reasons below I have doubts about its effectiveness as I am yet to be convinced that all parts of the policy will be put together or carried out in a coordinated way. Cornwall Council does not seem even able to repair the roads which in many places are in a dreadful and dangerous pot-holed state (and therefore illegal).

Yes No

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18. PP15 Liskeard and Looe Comminity Network Area


I agree in outline with objectives 1 – 5 (page 123) but would like to add the following comments: Objectives 1: Economy and Jobs Housing should FOLLOW economic development, not the other way round as appears to happening at present. Because this has been the rule for many years now many of the housing already built cannot be sold, and others for which permission has been given (Trevecca area) are already delayed by two years therefore there seems no sense to plan further large developments at this time. Cornwall Council has driven employment and shoppers out of town centres by steadily increasing car parking fees, and by allowing the continued development of edge-of-town large retail outlets which do not charge customers for parking. This shows no logic in planning. Objective 2: Sustainable Development: All development needs to be coordinated between the departments of the Council. Planning in Liskeard over the years has been piece-meal, has lacked coordination, and many poor decisions have been made. Examples include: lack of consideration the needs of pedestrians by not including pavements on Charter Way or to the Premier Travel Inn; not building the footbridge mentioned above, not enabling public transport to access bulk housing on the east of Liskeard. This needs to change. Fine words have been spoken in development plans over the last twenty years, but still fundamental mistakes are being made, and departments within the Council do not seem to speak to each other. Objective 3: Sorting office: It would be better if this stays in the town centre because then

people can collect undelivered mail easily without having to drive to some location yet again on the edge of the town. Those without cars who live in the town will be severely inconvenienced. Such a change will INCREASE the need to travel. There is plenty of room for a pannier market in the existing cattle market and in the many exisiting shops. Indeed, the old supermarket on The Parade, empty for two years, is now being turned into a pannier market! The sentence regarding improved traffic flow from the A38 is confused and shows no understanding of the situation. What I presume it is meant to say is that access from the western part of the town to the A38 for travel in an easterly direction needs to be made. However, the possibility of planning for his was spoilt by the way that Highways Agency planned and built the Dobwalls Bypass, and more recently by planning permission that has been given for a house (with two more plots for sale) on the proposed route of any future access road. So much for joined up thinking, and lack of money. To make any future major alteration will now cost huge sums, and is therefore not likely to happen. Objective 4 Housing: When housing estates are started, developers must be made to FIRST construct the additional facilities they promise – they often do not do this, and then often say they are unable to complete pavements, or in the case of the eastern side of Liskeard, an important pedestrian bridge linking two areas of the huge sprawling Peppers Park estate. Housing Developments should be planned so that they are serviceable by public transport and accessible to public amenities. They should not put stress on local roads or other infrastructure. Paragraph 18.8: Liskeard’s housing totals are given as 1000, with an additional 1000 homes for the total of the rest of the area. Since 2010, permissions have been given as follows: 475 homes for Trevecca area, 300 approx homes for Peppers Park and other areas in the town Total 775. In addition, a firm called Brook Street Properties is reported to want to build 500 homes on the east of Liskeard, next to the Premier Travel Inn. Technically, this area is in the parish of Menheniot, but the homes really will form a large easterly extension of Liskeard, being very close to Morrisons Supermarket and the other out-of-town superstores in that area. If these houses are permitted, then Liskeard’s total should be reduced. If they are permitted and are regarded as falling in the parish of Menheniot, then this would leave a total of only 500 for the whole of the rest of the area, and a good many of these are taken up already with existing developments for example at Looe Barbican Hill, Widegates, St Ive, etc. When a final housing figure for PP15 is agreed, then additional sporadic development in addition to these totals MUST be refused. On the west side of Liskeard, plans are being discussed to build 47 houses on a small field known as ALT 13, a planned development which all local residents

feel is unsuited and inappropriate to that location, and which does not fit in with the design and layout of the existing roads and housing stock. Permission to build in field has previously been refused, and therefore there appears to be no grounds to allow building now. However, there are concerns that planners will agree to this development – it has been stated that facing legal challenges by developers is very expensive. If this is the case it is no way to plan because agreed plans can be reduced to tatters. A local example exists where permission had been granted for a small number of houses, but the developer has since increased this number in contravention to the planning permission, but no action has been taken. How can this be allowed? Traffic in the town is a constant problem. Schools and GP surgeries are full to capacity. Any plans to substantially increase the housing stock need to take all these capacity and infrastructure constraints into consideration. P126: This states that the provision of 12,400m of B1a office accommodation has been identified. There appears to be large of such accommodation now that can be used for such purposes in the form of many retail properties, some quite large. Also, until the price of car-parking can be resolved, people will be reluctant or unable to park in the town during the day. Q5. If your representation is seeking a change, do you 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 e-mail 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.


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Name Daniel Wimberley Organisation Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number

Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? Yes



The plan is not sound because there is a major conflict between the

Yes NoX

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policy of sustainability and the proposed growth of an unsustainable economy. Sustainabilty is not an optional add-on. Nor is it a buzz-word to add in to sentences to make them sound, well, sustainable! It is a definite concept with definite consequences, as you will see from this submission. It is also an ESSENTIAL part of any plan if it is to be considered “sound”. Why? Because planning for a future where we effectively steal the chance for a life as good as ours from our children is morally bankrupt.


0 2


Delete: “the most sustainable approach to accommodating growth” Add: “a sustainable approach to accommodating the improvement of well-being”. Evidence: Continuing growth is not possible if it involves the use of resources beyond their sustainable limits. Nearly all growth put forward is of this type. If you are proposing a type of growth which does NOT depend on increasing consumption, or better, if it is based on a REDUCING consumption of non-renewable resources, then please specify in the plan what exactly this would look like, or if not exactly, at least specify a clear direction of travel with quantifiable targets. For example, an efficient public transport system which provides for people’s travel needs necessarily consumes FEWER resources than an inefficient one based on more and more journeys being made privately. That is it contributes to a REDUCTION in economic activity. This is the OPPOSITE of what you appear to be advocating by using the above wording. “Sustainable economic growth” is an illogical term. The economy cannot grow indefinitely on a finite planet.

Growth of happiness and quality of life is more important than material wealth. The aim of wellbeing is increasingly accepted as the way forward for regional and national policies. This is a key objective, for example, in Planning Policy (Wales). Health and well-being are covered in this Cornwall Local Plan in Policy 17. Because these are so important, we suggest that Policy 17 is renumbered as Policy 2. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New paragraph before para 1

2


Add: “Unsustainable development will not be supported. All jobs and businesses must be sustainable and appropriate, and be demonstrated to be so. All developments must be low carbon, and have built-in resilience to withstand the decline of resources such as oil and gas, and changes such as sea level rise.” Comments: Policy 1 is a presumption in favour of sustainable development; Policy 2 must make it clear that unsustainable development will not be supported. Unsustainable development would mean that Cornwall was being developed now at the expense of future generations, which is not acceptable. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

1, 2 and 4 2


After each target number (50,000 jobs, 420,000 sq m of employment floorspace, 42,250 homes) add: “(or a lower number if that is all that can be supported sustainably)”. Evidence: A Local Plan that contains figures that are outside the limits of the carrying capacity of Cornwall will not be sound. Complementary evidence on the sustainable carrying capacity of Cornwall should be provided. The target figures look too high against the Government statistical projections for households based on recent population and household census and other data. By 2020 in Cornwall they expect 255,240 households. This is an extra

24,000 households. The most recent figure for homeless people in Cornwall is 70 individuals. https://www.gov.uk/government/uploads/system/uploads/attachment _data/file/189965/AllTablesNonRegionalFinal__3_.xls Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

5 2


Delete “wherever possible” before “adaptation to climate change”. Evidence: Adaptation to climate change is always possible and there should not be an implication that it is not always necessary.


8 b iv 3

2 5


Delete: Policy 2, paragraph 8 b iv Delete: Policy 3, paragraph 5 Evidence: The aircraft industry is not sustainable and conflicts with Policy 1 and Policy 2 paragraph 3. References to it should be deleted. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

8b 2


Add new sub-paragraph: “Fostering the development of Cornish food, building on the strengths of the Cornish food industry, which is becoming very successful. Support local food outlets in preference to increasing numbers of supermarkets.” Document Paragraph number Policy number

Cornwall Local Plan – Strategic Policies

1 3


This policy should be made more reflective of the sustainable development objective of the Plan and should be rewritten to show this. Evidence: Larger scale developments are not necessarily more sustainable and resilient than dispersed developments. Supporting larger scale developments may conflict with Policy 1, Policy 2 para 3, and Policy 17. Larger scale developments have specific problems including:

o Increased local traffic o Increased risk of flooding through increased surface coverage o Increased overcrowding at local schools o Difficult to provide appropriate health service coverage o Lack of local shops and poor ability for community to develop

strong community links (important for social resilience) Larger scale developments can be made more sustainable in urban areas by incorporating land for food-growing, natural wild areas, recreational areas and community buildings. Careful design of schemes can reduce the carbon footprint of a site and improve social cohesion. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

3 3


Add: “Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.” Background information: “A cohousing community is a type of intentional community composed of private homes supplemented by shared facilities. The community is planned, owned and managed by the residents – who also share activities which may include cooking, dining, child care, gardening, and governance of the community. Common facilities may include a kitchen, dining room, laundry, child care facilities, offices, internet access, guest rooms, and recreational features. Cohousing facilitates interaction among neighbours which gives rise to social, economic and environmental benefits.” Evidence: An example is seen in Tan 6 (One Planet Development) in Wales. Document Paragraph number Policy number

Cornwall Local Plan – Strategic Policies

2 4


Add words shown in inverted commas: Community facilities and local shops should, wherever possible, be retained “and new ones supported”. “The development of local crafts, local food and other industries and services that retain money in the local economy will be supported.” “New megastores will not be supported except in exceptional circumstances where it can be shown that:

o No existing jobs would be lost o A high proportion of goods sold will be locally produced o They are sited in existing town centres and will not compete with

existing local stores” Evidence:

o Tesco proposal at Machynlleth showed a net loss of 264 jobs o Cornwall’s economy is very leaky - particularly for food and

megastore purchases where all the profit goes out of county. o The local multiplier for Megastores has been shown to be only

1.6 compared to local shops where one study showed 10 x. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 5 5


Add new paragraph 5: “Low carbon skills; renewable energy construction, maintenance and repair; sustainable building trades.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 3 6


Add new paragraph 3: “Homes must be built to low carbon standards from now onwards, at least to Code 4 by 2014, moving towards zero carbon by 2016.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 5 7


Add new paragraph 5: “Small, local settlements (hamlets, eco-villages, cohousing groups and residential farms) living as close-knit communities, growing their own food and making better use of land and places, will be supported.” Evidence: This kind of development, by its nature, is resilient and sustainable. There is already a pioneering cohousing development in North Cornwall, and Cornwall could become a leader in supporting such sustainable settlements. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

10


Add: “A proportion of publicly-owned sites should be made available for allotments, communal food-growing, sports and recreational areas, wild natural areas, and community facilities.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 4 13


Add new paragraph 4: “The design of all new buildings and settlements must take future resilience into account. Roofs should be south-facing or close to south-facing to enable solar panels to be added. Local food-growing areas should be included. Development Site assessments should take sea level rise, and surface flooding increases due to climate change, into account, and planning decisions will support a long-term aim to remove infrastructure and developments out of areas expected to be inundated within the next fifty years.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

New para 7 14


Add new paragraph 7: “Economical and environmental barriers (such as natural willow walls) must be erected for all new developments over 5 houses by main roads, to protect dwellings from noise and particulate emissions from vehicles.”


3 15


Add at the end: “All farms and settlements, including farms and small settlements in AONBs, will be permitted to have sufficient renewable energy equipment installed to meet their own energy needs.” Evidence: This would meet national renewable energy policies, allow self-sufficiency at the local level, support the localism agenda, and encourage rural sustainable development. By only allowing sufficient equipment installed to meet the needs of the settlement, it would be low impact. Please note: The box on page 31 is incorrect in stating Cornwall uses £500m worth of energy per year. It is actually around £1.6bn. (See REOC Cornwall’s energy bill.) Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

17


(As mentioned above, we think that this should be policy number 2.) Add to the end of paragraph 1: “and climate change impacts such as storm surges and sea level rise.” Also, please ensure that the housing densities mentioned elsewhere are not in conflict with this policy. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

1 20


Add (after “realised”): “The Council will only support energy recovery facilities where:

o The proposed technology is not incineration o The applicant has demonstrated actions to reduce waste arisings

and increase recycling of all materials in the waste stream to be treated

o Facilities also include high tech materials sorting plant o The plant is of low impact”


2 20


Add in front of present a-c: “A The proposal includes high tech sorting and cleaning plant through which all materials entering the site will pass B Cleaned and checked organic residuals from the sorting plant are composted and/or put through appropriate anaerobic digestion plant to reduce their BOD” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

2 21


Add (after paragraph h.): “i Screen noisy activities near to housing with earth banks, willow walls or similar noise abatement measures.” Document Paragraph number Policy numberCornwall Local Plan – Strategic Policies

6 25

Sustainability Appraisal Report Delete paragraph 6. Add (to replace the wording of paragraph 6): “Critical biodiversity should not be destroyed and important environmental and historical characteristics should not be sacrificed. The default position should be that the precautionary principle should always be followed, alternatively clear and specific reasons must be given for not following it. Critical natural capital should be preserved. Any mitigation agreed for non-statutory sites or non BAP species should provide additional habitat to that replaced.”

Evidence: Mitigation of environmental assets may, in many circumstances, be contrary to existing legislation (e.g. the Habitats Directive) and environmental regulations. New work emerging from the Government shows the value to us all of natural capital which generally far outweighs the value of developments. We suggest the Council builds on national government work on Sustainable Development Indicators to develop appropriate Indicators for Cornwall and work with for example Defra’s Ecosystem Markets Task Force report April 2013. http://sd.defra.gov.uk/2013/04/realising-natures-value-ecosystem-markets-task-force-finalreport/?utm_source=feedburner&utm_medium=feed&utm_campaign=Feed%3A+gov%2F sdscene+%28SD+Scene%29 Accepting money in exchange for damage to significant environmental heritage is unacceptable and should not be public policy. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

1 26


Change “take account of” to “follow”. Add at the end: “Development will not be supported on flood plains, areas likely to suffer increased surface flooding, or areas where an impact from sea level rise is predicted.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

1 27


The Cornwall Transport Plan is not realistic as it is based on large traffic increases over the Plan period. The Transport Plan should be updated and only then used as the basis of this Core Strategy policy development. The new Transport Plan needs to take account of the new realities of resource depletion (especially the ongoing decline of the availability of oil) and the high and rising prices of transport fuels, which are already leading to a reduction in local

transport fuel use. To fail to take account of these matters is to be to fail the people of Cornwall by condemning them to ever-increasing transport costs and to allow the planning for an obsolete scenario to squeeze out planning for transport sustainability. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

3 27


Add: “New classified roads will not be supported.” Evidence: The era of low-cost fossil fuels for personal transport has come to an end. This means that new roads are very unlikely to prove viable investments.


1 28


Add: “No new classified roads will be approved, and local roads for new developments will not put car use at the centre of the developments. Infrastructure such as electricity supply, water supply and sewerage must be sustainable, low impact and low carbon and sited taking account of predicted changes in flood levels from climate change assessments.” Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

2 28


Delete:

“Contributions will be used to mitigate the impacts of developments (including any cumulative impact).” Add: “Critical biodiversity should not be destroyed and important environmental and historical characteristics should not be sacrificed. The precautionary principle should always be followed, and critical natural capital should be preserved. Any mitigation agreed for non-statutory sites or non BAP species should provide additional habitat to that replaced.” Evidence: Mitigation of environmental assets may, in many circumstances, be contrary to existing legislation (e.g. the Habitats Directive). Accepting money in exchange for damage to significant environmental heritage is unacceptable and should not be public policy. Q4. Did you raise this issue earlier in the plan preparation process?


x


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. Completed forms should be submitted: by e-mail to: [email protected]

Yes NoX

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.


408 By E-mail 19TH April 2013 Commentary on the Local Plan: 2012-2030 Strategic Policies pre-submission version. Thank you for the opportunity to comment on this crucially important plan. Please ensure our comments are properly recorded and fully considered. In short, this ‘Local Plan’ is unfit for purpose. Unfortunately, it does nothing to

establish the contingency planning required for an uncertain world. Unpredictable climate change, resource depletion, environmental and cultural stress all demand a newer, more radical approach and not the old business-as-usual policies of suburban residential communities distanced from places of work, consumption and leisure linked by private motorised transport. The chance for the Council to lead a debate about the kind of Cornwall we could build. Using the huge quantities of previously used industrial sites resultant from the county’s historic activities. This rare if not unique opportunity should be used as a source of positive contribution, protecting this productive Greenfield land, which provides opportunity for local food production and associated local employment. Rather disappointingly the draft document fails to emphasise and enforce precise policy, in the language necessary to halt predatory developer claims, of which we are all are aware. allowing cases where the gaining of permission to build where they choose, maximising their profitability, as opposed to where the need actually exists. Therefore the benefits are one sided. More often they are on Greenfield sites and often in places where vast amounts of Brownfield could be used, claiming they are too expensive, whilst huge profits are now being recorded, yet this fact appears to be overlooked and in many cases reduced. Greater scrutiny is urgently needed. The cumulative effect of vague policy language is too expensive a cost to the towns and County. Compulsory purchase legislation could be applied to acquire some of the many Brownfield sites, dealing with the lack of required supply as a County. That supply should be locally measured, not as a county thereby applying a truly local measurement of need. Building in St Austell because the need exits in another part of the duchy has need of supply, does nothing to address the other area’s their local needs. Nor is it sustainable. The proposed 42,250 figure was created by adding to the Planning Policy Advisory Panels 38,000 recommended figure. Because a few others claimed to want more, is unacceptable, reallocation from within the proposed figure would have been the appropriate method, the Localism act would have been demonstrated by such an action. When applied across the Duchy that extra 4,250 multiplied by the 6 years (5+20% rule)

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The NET effect is : Making the county more vulnerable to appeals, by increasing the numbers required to satisfy this supply criteria, weakening Cornwall Councils position. By the added numbers. It will be most interesting to read the comments from Falmouth, Newquay and Bodmin, town and parish councils to the draft plan This plan lacks a long-term vision. It fails properly to assess the long-term consequences of continuing a never-ending cycle of housing and population-led growth. It fails to provide evidence to justify its supposed economic benefits. Witnessed by the continued existence of need even after 20 years and the building of 41,320 homes in Cornwall in that period. It fails to enumerate the longer term costs of pursuing the sterile strategies of the last half-century. It fails to identify those particular aspects of the Cornish context which call for special consideration, instead applying one-size-fits-all policies. Finally, it is abysmally complacent about the major challenges which we as a society face in coming years because of a more generalised failure of policy-makers at all levels to address climate change. Particularly when In 2007 the then County Council commissioned a Quality of Life survey. Among other questions, this asked residents in Cornwall what they felt were the biggest threats to the natural environment. Almost two thirds identified housing development as one of the ‘greatest threats to the natural environment’ while over a half cited a growing population as another major threat. At the same time more than two thirds thought that the rising level of traffic was the third threat the environment faced. What therefore does it say about living in a democracy when these concerns are so bluntly dismissed in the Local Plan? The actual timing of this consultation is at best crazy, or at worst negligent, due to Council members being distracted during necessary activities in connection to Local Elections. The dates clash during election campaigns is unfortunate, to say the least. Yours sincerely. Stephen & Hazel Henry

409 Blisland Parish Council considers this document too long and it should be standard practice for all consultations to have an executive summary. S Harris Parish Clerk

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410

RESPONSE TO LOCAL PLAN

NAME..........REBECCA BRYANT...................................................................... Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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411 RESPONSE TO LOCAL PLAN

NAME: MARGARET DAVIES

Please note my objections to the local plan

Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim

. In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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412

Name Robert Bown Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years

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413



Name Hadrian Pigott Organisation Penzance Seafront Forum Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? The Penzance Seafront Forum (PzSF) steering group has representatives from the following local organisations: The Chamber of Commerce, The Civic Society, the Penzance & District Tourist Association, Friends of Penzance Harbour, Friends of Jubilee Pool, Friends of the Earth, Transition Penwith, the Penzance Harbour Users Association, Penzance Sailing Club. Most of these members attended and contributed to the AECOM plan process and a great many positive and imaginative ideas were put forward and encompassed in that plan. There has been no serious engagement with the local community since then, and much of the AECOM plan has been whittled away. We do not believe that the procedural requirements have been met for the Local Plan Pre-submission document, specifically with regard to the P1 West Penwith Community Network Area. We are currently approaching local elections and the consultation period for the Local Plan Strategic Policies largely coincides with the purdah period associated with this, making discussion with and action by any local representatives impossible. The current version of the plan should not be submitted to the Secretary of State until the community is properly consulted. This process should begin once the local elections are completed, and we believe that Cornwall Council should suspend sending the plan for approval until it has met with the community and its representatives to explain the content and reasoning of the plan.

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Please specify the reasons below Many of the positive achievements of the AECOM consultation have been lost. As there has been no similar engagement with the community since, the ideas and ambitions of the community have been obscured by a lack of vision. What has not been lost is the fact that there is an actively engaged community here in Penzance, that has been working hard on ideas and actions to improve the town. Cornwall Council has not justified its Plan to the local community, and there must be further detailed consultation in order for the plan to reflect the needs and ambitions of the town and surrounding area. The plan cannot be called effective as it does not consider the complex development and regeneration needs of the town and does not lay out an effective policy for the next 20 years. 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

Point 8 P1 West Penwith Community Network Area

Policy 2 Paras 4.1, 4.4, 4.5, 4.6, 4.7. 4.15. 4.16

No


The original AECOM plan made the Penzance harbour area a centre for regeneration, and included the development of the Harbour Car Park and the creation of a Penzance Marina. The Penzance Harbour Users Association (PHUA) have been promoting their harbour expansion ideas to the east of the Albert Pier, tying them into (as Phase 1) the much needed harbour sea defences with an off-shore breakwater to protect the existing harbour and provide year round protected moorings for the Scillonian on the Lighthouse Pier. These ideas are now well understood and widely supported in the town. The economic potential of such a development is significant. It is hoped that after the upcoming local elections what has been known to date as the PHUA Marina Scheme becomes the Penzance Marina Project, with more support and resources from other local organisations being pooled to progress this ambitious proposal. Under General Policies (2.7) the draft Local Plan suggests ‘Realising the development potential of Cornwall’s maritime sector will be critical to the region’s future, long term prosperity.‘ yet there is no mention in the Plan of the potential of the widely supported Penzance Marina project, which has been removed from the current Development Framework plan, with no explanation to the community. There is plenty of discussion of the potential of Penzance Harbour, but without expanding the area of the harbour, there is little space for development. To leave the Penzance Marina proposal out of the Local Plan is extremely short sighted. The regeneration potential of marinas is well documented and understood; Penzance is the missing link in the coastal leisure cruising circuit and is missing out on a significant boost to its economy, employment and identity. The potential of developing the harbour in this direction must be part of the Local Plan and the next 20 years of policy in the region. A significant redevelopment of the harbour including a marina may also open up the opportunity for injecting future resilience into the transport network of the region in terms of coastal freight for example. The P1 West Penwith Community Network Area document suggests specific objectives to ‘broaden and diversify the local economy..through developing and promoting opportunities and employment prospects within the marine economies...developing high end tourism and the area’s natural assets…developing a strategy for the harbours and waterfront of Penzance and Newlyn’. The Plan goes on to stress that there are ‘significant opportunities [for Penzance and Newlyn] to diversify their marine related activities to maximise the unique opportunities of the wider Mount’s Bay.’ Yet there are no concrete suggestions for how to achieve this. There are however strong indications that in order to strengthen the town’s retail profile, the Harbour Car Park is designated for development. The Penzance Seafront Forum does not object to development of the Harbour Car Park in principle, provided the car parking provision is maintained to cater for the increased retail offer. We would of course look for a high quality development that integrates well with the town centre and harbour. And this is the point; the development of the Harbour Car park cannot be taken in isolation. This is land ‘immediately adjacent to the town centre’, but it is also land immediately adjacent to the existing drying harbour (the site of the AECOM Marina) and the potential reclaim land and site for the PHUA Penzance Marina, and the omission of the Marina proposals from the Plan means that the car park site can be developed without anticipating such a future development. This will effectively destroy the chances of the Marina project.

The Penzance Marina Project must be included in the Local Plan before it is submitted to the Secretary of State. An additional paragraph should be added to Point 8 of Policy 2, reading: ‘supporting the economic regeneration of Penzance as a retail, business and leisure centre including the potential expansion of Penzance Harbour and the creation of a Penzance Marina, whilst developing its role as an travel interchange taking advantage of its position on the transport network (road, rail, sea, air).’ Hadrian Pigott Chairman, Penzance Seafront Forum 21st April 2013 Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies







If yes, please specify at what stage: Many members of the Penzance Seafront Forum were participants in the AECOM consultation, and have been actively engaged with shaping the town’s development since. Dave Slatter is well informed and well aware of the ambitions of the town with regard to the harbour and potential marina. Q5. 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



Yes

414


NAME_Michelle Tellam Lawrence________

PLEASE NOTE MY OBJECTIONS TO THE LOCAL PLAN

I believe this plan is unsustainable and will be damaging to Cornwall’s environment, economy and culture. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim. In Cornwall planning application are three times above the average in Britain and 85% of all applications are approved compared to 75% in the rest of the country. This is growth for growth’s sake and cannot be justified. The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years! This trend means that Cornwall's population will approach one million by the end of this century. This is too high a price to pay and is unnecessary. CoSERG has produced fact-based evidence, based on analysis of recent and current growth trends that shows the housing figure over the period of the plan should only be 29,000. We cannot justify building houses on Greenfield sites this must stop.

PLEASE NOTE MY RESPONSE WHICH IS FOR 29,000 HOUSES FOR CORNWALL OVER THE NEXT 20 YEARS.

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415 Strategic Policy Team Cornwall Council Carrick House St Clement Street TRURO TR1 1EB 19 April 2013 Our Ref: Local Plan Your Ref: Strategic Policies 2010‐2030 Dear Sir / Madam Cornwall Local Plan – Strategic Policies 2010‐2030 Thank you for inviting Sport England to comment on the Cornwall Strategic Policies 2010‐2030 document. Sport England is the Government agency responsible for delivering the Government’s sporting objectives. Maximising the investment into sport and recreation through the land use planning system is one of our priorities. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields. The new Sport England Strategy 2012‐17 sets a challenge to:

• See more people taking on and keeping a sporting habit for life • Create more opportunities for young people • Nurture and develop talent • Provide the right facilities in the right places • Support local authorities and unlock local funding • Ensure real opportunities for communities

Sport England has considered the consultation in the light of Sport England’s Planning for Sport & Active Recreation: Objectives & Opportunities (Interim Statement 2005). The overall thrust of the statement is that a planned approach to the provision of facilities and opportunities for sport is necessary in order to ensure the sport and recreational needs of local communities are met. Sport England believes that sport has an important role in modern society and in creating sustainable and balanced communities. Sport and physical activity is high on the Government’s national agenda as it cuts across a number of current topics that include health, social inclusion, regeneration and anti social behaviour. The importance of sport should be recognised as a key component of local plans, and not considered in isolation. The following comments are provided within the context of:

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• The National Planning Policy Framework (DCLG, 2012). • Sport England’s “Planning for Sport & Active Recreation: Objectives & Opportunities (Interim Statement” (2005). • Sport England’s web based “Planning Contributions Kitbag” (2013).

1. COMMENT – Local Plan & Evidence Base POLICY 4 – SHOPPING, SERVICES AND COMMUNITY FACILITIES The National Planning Policy Framework (NPPF) published in March 2012 (replacing PPS12 & PPG17) states: Para 73 – Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to health and well‐being of communities. Planning policies should be based on up‐to‐date assessment of the needs for open space, sport and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. Information gained from the assessments should be used to determine what open space, sports and recreational provision is required. We note that there is a Playing Pitch Strategy (2010) which covers the local plan spatial area and supports effective planning policies for protection and creating new sites. It is not clear whether works are on‐going to implement the strategy with action plans and monitored. After 3 years without regular review, the Council will need to consider carrying out this work again to keep the evidence base for playing pitches robust and up to date. Sport England is currently working on a revised methodology for the production of Playing Pitch Strategies and this will be published later this year. Sport England’s view is that, in order to meet the requirements of the National Planning Policy Framework (NPPF) (formerly PPS12 and PPG17), this should include a strategy (supply and demand analysis with qualitative issues included) covering the need for indoor and outdoor sports facilities (including swimming pools, sports halls and other non playing pitch sports). Sport England will be working this year on producing a Technical Guide for Assessing Needs & Opportunities regarding sport to accompany the NPPF. 2. SUPPORT – Planning Obligations/Community Infrastructure Levy (CIL) to Sport POLICY 3 – ROLE AND FUNCTION OF PLACES Sport England supports use of planning obligations/community infrastructure levy (CIL) as a way of securing the provision of new or enhanced places for sport and a contribution towards their future maintenance, to meet the needs arising from new development. This does need to be based on a robust NPPF evidence base. This includes indoor sports facilities (swimming pools, sports halls, etc) as well as playing fields and multi use games courts. All new dwellings in Cornwall in the plan period (up to 2030 and beyond) should provide for new or enhance existing sport and recreation facilities to help create opportunities for physical activity whilst having a major positive impact on health and mental wellbeing.

Planning Policy Objective 8: ‘Providing for Sport Through New Development’ ‐To promote the use of planning obligations as a way of securing the provision of new or enhanced places for sport and a contribution towards their future maintenance, to meet the needs arising from new development. 3. COMMENT – Protection of Sport & Recreation including playing fields POLICY 1 – PRESUMPTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT Sport England acknowledges that the NPPF is promoting “sustainable development” to avoid delays in the planning process (linked to economic growth). Thatsaid, the NPPF also says that for open space, sport & recreation land & buildings (including playing fields) paragraph 74: Paragraph 74. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

●● an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or ●● the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or ●● the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

The adopted Local Plan should have a policy that reflects this approach to protecting sport and recreation facilities including playing pitches in Cornwall. 4. COMMENT – Active Design POLICY 13 – DESIGN Sport England believes that being active should be an intrinsic part of everyone’s life pattern. The master planning of new housing proposal has a vital role in providing easy access to a choice of opportunities for sport and physical activity to suit all age groups for making new communities more active and healthy. Sport England commissioned David Lock & Associates to investigate the contribution that masterplanning can make to create new environments that maximise opportunities for participation in sport and physical activity. This work including a developer’s checklist has been completed and can be accessed via www.sportengland.org . Through an analysis of the current health agenda and urban design principles and good practice, the term ACTIVE DESIGN has been adopted to describe ways in which master planning can promote healthy environments through creating healthy environments through creating conditions for participation in sport and physical activity and the use of active travel modes (walking and cycling). Three overlapping Active Design objectives have been identified that should be promoted by master plans: improving accessibility; enhancing amenity and increasing awareness.

Sport England would encourage the developers to design future proposals in Cornwall in line with the Active Design principles. I trust that the above comments can be taken into account prior to the production of a final adopted Local Plan for Cornwall. Yours faithfully

Gary Parsons MSc MRTPI Planning Manager

T: 020 7273 1861 M: 07711 086487 F: 01460 77263 E: [email protected]

Creating a sporting habit for life

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Ashlands House, Ashlands, Crewkerne, Somerset, TA18 7LQ

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NAME__Michael LeFevre_____________________________


I believe this plan is unsustainable and will be damaging to Cornwall’s environment, economy and culture. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim. In Cornwall planning application are three times above the average in Britain and 85% of all applications are approved compared to 75% in the rest of the country. This is growth for growth’s sake and cannot be justified. The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years! This trend means that Cornwall's population will approach one million by the end of this century. This is too high a price to pay and is unnecessary. CoSERG has produced fact‐based evidence, based on analysis of recent and current growth trends that shows the housing figure over the period of the plan should only be 29,000. We cannot justify building houses on Greenfield sites this must stop.


‐‐‐‐

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Name Andrew Asbury Laraine Southwood Organisation Falmouth Exeter Plus Terence O’Rourke Address line 1 Tremough campus Everdene House Address line 2 Treliver Road Deansleigh Road Address line 3 Penryn Bournemouth Address line 4 Cornwall Postcode TR10 9EZ BH7 7DU Telephone number

01202 421142

Email address [email protected] Q1. Do you consider that the Local Plan meets the legal and procedural requirements?



Reference in the local plan to “CUC”, as it relates to education facilities at Tremough Camus, should be amended to reflect current arrangements. Falmouth Exeter Plus is the service delivery partner of Falmouth University and the University of Exeter. It delivers shared higher education services and facilities for the universities in Cornwall.

No

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Although reference in the document to the universities (Falmouth University and University of Exeter) is welcomed, it is considered that the reference is not reflective of the important contribution that the universities make to the economy, and consequently the document must be amended to properly support the universities’ ambitions for a growing, sustainable contribution to the Cornwall, and wider economy. Further examples of where the plan is deficient are set out below with reference to tests of soundness. Positively prepared Paragraph 158 of the NPPF states that each LPA should ensure that the Local Plan is based on adequate, up to date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Regarding infrastructure, paragraph 162 states that LPA’s should work with providers to ‘assess the quality and capacity of infrastructure for … education’. The evidence base does not appear to be robust and up to date with regard to the current and potential future role and function of the universities. In this regard the local plan does not meet objectively assessed development and infrastructure requirements and is therefore unsound. Consistent with national policy Paragraph 7 of the NPPF states that the planning system should perform economic, social and environmental roles in order to contribute towards achieving sustainable development. Cornwall Council has not given adequate recognition in the Local Plan to the important economic role that Tremough campus performs in helping to deliver sustainable development eg through ensuring that sufficient land is available for growth at the campus, properly identifying and protecting a local service that reflects the communities needs, and through the role the universities play in the academic contribution of mitigating and adapting to climate change. In accordance with the principles of sustainable development, LPA’s must seek opportunities to meet the development needs of their area (para 14 NPPF). In this regard it is essential that the important status of the campus is fully recognised as a key strategic priority, and that the potential for the campus to expand to the north is also identified. The potential for the university to develop both within the existing campus and to the north must be fully recognised at this strategic level, given the strong contribution that the universities make to the economy and to sustainable development. Paragraph 17 of the NPPF states that plan-making should pro-actively drive and support sustainable economic development. In order to comply with this the local plan should be amended as set out above. The universities need the flexibility to be able grow to meet education demands and to stay competitive. In accordance with paragraph 19 of the NPPF, the plan must not impede sustainable growth by failing to properly recognise this need. Therefore, in order to be consistent with paragraph 19 of the NPPF, the plan must give proper recognition to the campus’ potential need to expand. Paragraph 21 of the NPPF states that in drawing up Local Plans, LPA’s should plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries. Demand for research space associated with the high technology sector is growing at the campus, and this should be recognised in preparing the local plan.


PP5 Falmouth and Penryn Community network area


The objectives and supporting text should be improved to properly reflect the contribution that the universities make to the economy, and to explain that in order to stay competitive Tremough campus must be given the flexibility to develop both within and beyond its current boundary. There should be a separate objective to support the universities at Tremough. There should be a separate policy to support the education, research/business and community role provided by the campus. The policy should include the potential for expansion to the north. The policy should identify Tremough Campus as a strategic priority and refer to the amended key diagram. This would be consistent with the Monitoring Framework table page 141 which refers to the delivery of ‘strategic proposals’ at the campus. The reference to ‘CUC’ should be deleted and replaced by reference to the universities at Tremough Campus. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

P 5 Jobs and skills


Criterion 4 lacks clarity. A separate criterion should be provided for Tremough campus that fully supports the universities contribution to the economy, and in particular its contribution towards sustainable development. 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

Key diagram


The key diagram should show Tremough campus as a key strategic priority, with potential for growth. The words “CUC” and the blue arrows should be replaced with the strategic priority blue circle around the campus. The site should be referenced as “Falmouth University and University of Exeter at Tremough Campus”.




yes



No

418 Our ref: Cornwall LDF Your ref: Cornwall Council Strategic Policy Team Carrick House St Clement Street Truro Cornwall TR1 1EB Via email: [email protected]

Ian Parsons Asset Manager 1st Floor Ash House Falcon Road Sowton Industrial Estate Exeter EX2 7LB Direct Line: 01392 312555 22 April 2013

Dear Sir/Madam Cornwall Local Plan Strategic Policies 2010-2030: Pre-submission consultation March 2013 Thank you for providing the Highways Agency with the opportunity to comment on the above document. We understand this to be the third round of consultation on this part of the Local Plan, previously known as the Core Strategy, and sets out the main planning approach and policies for Cornwall that will manage development to 2030. The Agency is keen to ensure that the Local Plan takes account the need for transport and land use planning to be closely integrated and that the principles of sustainable travel are reflected in development. The Agency is responsible for operating, maintaining and improving the Strategic Road Network (SRN). In Cornwall the SRN comprises the A30 and A38, and as such our representations set out below reflect this. Policy 1 Presumption in Favour of Sustainable Development In line with the NPPF the Agency fully supports the presumption in favour of sustainable development. Policy 2 Key targets and spatial strategy The Agency supports the growth set out in Policy 2 and recognises the need for development to support Cornwall’s economy in a sustainable manner. Policy 3 Role and function of places Generally the Agency acknowledges that the hierarchy of places for development in terms of scale and mix offers the most opportunity for sustainable development, concentrating development in places that offer the most services and facilities. Policy 27 Transport and Accessibility The Agency supports the overall aim of Policy 27 to ensure a resilient and reliable transport system for people goods and services and supports the criteria laid out in

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the wording of the policy. Of particular importance are the requirement that development provides accessible and convenient cycle and pedestrian routes, public transport and road routes within and in the immediate vicinity of the development, provides travel plans to mitigate the development impact, has no adverse impact on the SRN that cant be managed or mitigated, safeguards strategic transport opportunities including land round existing facilities for expansion and provide public transport solutions including park and ride where it would remove transport from the network and is economically viable. The Agency supports point 6 in particular: Not significantly adversely impact on the local or strategic road network that cannot be managed or mitigated. I am aware from discussing with Cornwall Council officers that the transport modelling being carried out to inform the Local Plan is indicating the section of the A30 between Carland Cross and Chiverton in particular is shown to require mitigation to avoid an adverse impact. As such I can confirm the Agency is very keen to work with the Council to identify feasible and affordable improvements. Policy 28 Infrastructure Infrastructure is fundamental to the growth strategy for Cornwall and the Agency reiterates that new development should be supported by appropriate infrastructure provided in a timely manner. The acknowledgement of the importance of working with providers and delivery agencies such as ourselves is welcomed, to keep an up to date infrastructure delivery plan to enable proposals in accordance with the spatial objectives to be brought forward. The Agency supports the CIL as a way of assisting with the delivery of necessary infrastructure and very importantly from our perspective to mitigate the adverse impact of developments and their cumulative impact on the SRN. Community Network Areas The Agency welcomes the Community Network Areas (CNAs) as a focus for debate and engagement at a more local level although recognises that most of the objectives that are of concern to us are within the main policies of the plan. The Agency has made previous comments in relation to specific Community Network Areas, but would reiterate that generally we are very supportive of the measures and proposals planned in order to facilitate both economic growth and to meet existing local need. As previous comments made relating to the Local Plan have said, it is important that whilst the CNAs deal with local issues, that when they are being considered more regional issues such as infrastructure are considered with a more over arching joined up approach. This seems to have been reflected more in the latest version of the Local Plan. The Agency therefore particularly welcomes the continuation of the grouping of China Clay, St Austell and St Blazey, Fowey and Lostwithiel CNAs to enable better management of the growth needs of St Austell, acknowledging the need for a broader approach unconstrained by artificial boundaries. While the approach is formalised in this context the principles of it should be applied elsewhere in Cornwall as required and where it is sensible to do so. The Agency has no comments to make on specific development aspirations within the CNAs as these generally follow the pattern described in Policy 3 whereby the majority of development is concentrated round the larger settlements with the most services and amenity and therefore in principle, most suitable to accommodate growth. It is important to note however that all development that is likely to generate traffic will need a robust evidence base to demonstrate that there is no adverse

impact on the SRN or if there is that mitigation works will be in place to alleviate any issues. Monitoring framework The Agency is encouraged by the monitoring framework set out in the Local Plan. It is important that the progress in achieving plan objectives and therefore delivering the vision is measured in order to review part or parts(s) of the Local Plan if it becomes apparent that there are issues. The Agency would like to reiterate that all new development should include sound supporting documentation including a robust Transport Assessment and a Travel Plan. To this end the Agency is always open to discussions relating to particular sites or development and would encourage applicants to seek these discussions at the earliest opportunity. Should you have any queries, please do not hesitate to contact me. Yours sincerely Approved for issue - IP Ian Parsons NDD South West – Asset Manager Email: [email protected] Cc: Chris Harding, Halcrow Sally Parish, Highways Agency

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�NAME Mr Harvey Kurzfield��


�I believe this plan is unsustainable and will be damaging to Cornwall’s

environment, economy and culture. Since 1960 Cornwall's population has grown

by 60%. This rapid population growth has clearly not produced the economic

benefits its supporters claim.��In Cornwall planning application are three times

above the average in Britain and 85% of all applications are approved compared

to 75% in the rest of the country. This is growth for growth’s sake and cannot be

justified. The current plans proposed by Cornwall Council mean we will have to

build the equivalent of five new Truros in the next 20 years! This trend means

that Cornwall's population will approach one million by the end of this

century.��This is too high a price to pay and is unnecessary. CoSERG has

produced fact-based evidence, based on analysis of recent and current growth

trends that shows the housing figure over the period of the plan should only be

29,000.��We cannot justify building houses on Greenfield sites this must stop.

There are plenty of brown-field sites still available in Cornwall which developers

should be forced to use before going anywhere near green field sites. Our MP, Mr

George Eustice, has also stated this at several public meetings. The issue of

empty and second homes should also be explored.


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420 RESPONSE TO LOCAL PLAN

NAME.......Anita Janes......................................................................... Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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�NAME Mrs Jacqueline Kurzfield��


�Along with many other Penponds residents I believe this plan is

unsustainable and will be damaging to Cornwall’s environment, economy and

culture. Since 1960 Cornwall's population has grown by 60%. This rapid

population growth has clearly not produced the economic benefits its supporters

claim.��In Cornwall planning application are three times above the average in

Britain and 85% of all applications are approved compared to 75% in the rest of

the country. This is growth for growth’s sake and cannot be justified. The current

plans proposed by Cornwall Council mean we will have to build the equivalent of

five new towns in the next 20 years! This trend means that Cornwall's population

will approach one million by the end of this century.��This is too high a price to

pay and is unnecessary. CoSERG has produced fact-based evidence, based on

analysis of recent and current growth trends that shows the housing figure over

the period of the plan should only be 29,000.��We cannot justify building

houses on Greenfield sites this must stop.

There are plenty of brown-field sites still available in Cornwall which developers

should be forced to use before going anywhere near green field sites. Our MP, Mr

George Eustice, has also stated this at several public meetings. The issue of

empty and second homes should also be explored. Too many empty homes have

been left apparently abandoned and we believe that these properties should be

compulsorily purchased and put to good use.

PLEASE NOTE MY RESPONSE IS FOR A MAXIMUM OF 29,000 HOUSES FOR CORNWALL OVER THE NEXT 20 YEARS.

Less, yes, but no more!

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423 Cornwall Council

Local Plans Team Carrick House St Clement Street Truro TR1 1EB By e-mail to: [email protected]

Ref: 2013/Local Plan Representations

18th April 2013 Dear Sirs

Re: REPRESENTATIONS REGARDING INNADEQUATE CONSULTATION PROCESS AND LACK OF VISION FOR PENZANCE ON THE PART OF THE LPA WITHIN THE PRE-SUBMISSION DRAFT OF THE LOCAL PLAN FOR CORNWALL TO 2030

We wish to make the following representations regarding the Pre-Submission Draft of the Cornwall Local Plan:

1. We would seriously question the content of the plan regarding Penzance-Newlyn and by extension, the wider West Penwith Community Network Area – ie a complete lack of vision on the part of the LPA (which further, does not reflect earlier consultation input from the Community)

2. We believe the consultation process is fundamentally flawed, due both to the timing of this final consultation stage and the incompleteness of the information. The community has been denied the right and proper opportunity to fairly question the content of the Plan, in particular, the democratic process of engagement with locally elected members has been constrained (due to the timing in conjunction with purdah for local elections) and by a lack of clear explanation and assistance for the General Public on the part of the LPA to understand the complex nature of Planning and the potential impacts of the Plan on the Community.

We believe that, in the very least, the process should be curtailed in order for greater time to be given to the community after the completion of the election process, to engage with representatives. Further, that Cornwall Council must meet with the community and its representatives to clearly explain the reasoning behind the plan and its import and impact for the area over the plan period. With the above in mind, we would note the following detailed issues arising from the Draft:

Comments on Pre-Submission Draft: Strategic Policies:

1.01 The document states that the Local Plan, Core Strategies document must be read in conjunction with the entire suite of documentation, including NPPF, Supplementary Planning Documents, Neighbourhood Plans and Development Plans. We would note however, that there is no Development Plan for Penzance-Newlyn (or indeed the majority of the towns in Cornwall) and

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therefore the intentions of the “Plan” cannot be sufficiently understood to permit satisfactory engagement.

1.02 The deadline for submission of comments and representations is 22nd April at the end of a 6 week period, most of which was during the purdah period resulting from the local elections. Further, no direct engagement with community has taken place at this stage of the process and inadequate consultation earlier in the process has left a community without a clear understanding of the Plan’s intentions (eg- what happened to the AECOM plans and community input?).

1.03 Cornwall council purports that the Local Plan will: - Support the Economy - Enable self-sufficient and resilient communities - Promote good health and wellbeing - Make the most of our environment

The complete lack of any vision for Penzance-Newlyn does not provide an adequate framework for these “core principles” to become reality. The AECOM process highlighted a number of exciting propositions for the area and sought to capitalise on the assets of the harbour in Penzance to reinforce the marine leisure sector within the spectacular backdrop of Mount’s Bay. Even in the watered down version of the consultation Penzance was described as a “Creative Maritime Town”. Despite this, there is no plan for the improvement of the harbour facilities at Penzance and the much supported marina scheme for Penzance makes no appearance whatsoever (and has been removed from the latest draft Development Framework- not included in this Local Plan).

1.04 The Key Targets and Spatial Strategy for Cornwall (Policy 2) Leaves

Penzance-Newlyn out in the Cold. CC recognises the impact of the distance from London on the County and the limitations of a peninsular geography, and yet the Council seeks to reinforce these very damaging circumstances of geography for the far west of the County. Key targets include strengthening north and mid Cornwall for employment and development opportunities, whilst the far west of the county appears to be left to atrophy and die without any Vision or intended support for the community to sustain itself.

1.05 Whilst Penzance-Newlyn is one of the largest and most populous urban centres in the County, it does not figure in the key targets or Spatial Strategy at all, as is evidenced by the following list from pages 12-13 of the Core Strategies Document:

- Support the economic regeneration of Camborne Pool and Redruth…..

- Support the role of Bodmin as a strategic employment location….. - Allocate mixed use development opportunities at Carglaze and

Par…. - St Austell, St Blazey and the China Clay Regeneration Area,

support for development……. - Support Newquay Airport and Aerohub…. - Support Truro’s wider role as an economic and service centre….. - Support economic development in Southeast Cornwall……. - Strengthening the role of Launceston and Saltash as gateways to

Cornwall through economic growth… - Provide for marine business and maximise the economic

growth….of the proximity to Combined Universities in Falmouth

Where does Penzance-Newlyn or indeed West Penwith figure in the key targets and Spatial Strategy? Quite simply- IT DOESN’T Outside of this strategy, St Ives has the “Tate Effect” and Hayle has the on-going commitment of ING and the development of the historic harbours etc. Meanwhile Penzance has lost the majority of its former administrative function (to Camborne and Truro (along with a considerable number of jobs), suffers a declining retail environment, a lack of effective management and ambition for the harbour with a dominant tenant that does not permit Penzance to capitalise on the leisure benefits of the harbour. Cornwall Council has a myopic view of Penzance Harbour as the link to the Isles of Scilly and nothing else. This is simply not good enough. The rural areas of West Penwith suffers a decline in farming and the fishing industry presents a similar story for the coastal areas (most notably Newlyn). The infrastructure of the town is literally being left to fall into the sea with the promenade in a perilous state, as is the south pier, due a lack of maintenance over a protracted period and access to the harbour is precarious when the wind is from the Southeast. Reference is made within the Local Plan to “The Maritime Strategy” however this document is short on tangible proposals for the area. There must be a greater emphasis on the potential of the sea to deliver regeneration for the far-west of the county and this requires active engagement and tangible support from Cornwall Council which appears to not be forthcoming over the period to 2030.

1.06 Policy 5- Jobs and Skills refers (amongst other points) to:

- The role of tourism and the need to enhance the quality of employment and the length of the season…..

- Realising the development potential of Cornwall’s maritime sector will be critical to the region’s future long term prosperity…….

Whilst provision of new workplace has been identified in the plan for the Penzance-Newlyn area no specific provision for enhancing these 2 fundamental assets of the area have been considered. There is no development plan for the harbour to capitalise on the maritime nature of the place and there is no framework to enhance the quality and/or length of the tourist season. In the meantime, Penzance continues to crumble whilst its publically owned built assets are sold off to the highest bidder with little care, understanding or recognition of what might be best for the town. Cornwall Council provides no inward investment to the town and this appears to be the case for the foreseeable future. 1.07 The Transport Framework

CC purports to encourage the sustainability of local life to avoid the need to travel and to have sufficient services located close by. Clearly the Council’s strategy of centralising services in Camborne and Truro does not support this. Further, reference is made to the strategic importance of the rail service centre at Penzance and yet the Shoreline Management Plan (2) talks of the railway retreating from Penzance back to St Erth. At the very least there must be a commitment to investigating alternatives for maintaining the rail link into the town. Summary: In light of the above, we do not believe that the Local Plan satisfies the requirements for the future of Penzance- Newlyn and the West Penwith CAN.

We do not believe that the consultation process has been carried out effectively or with the democratic process at its heart. We call upon Cornwall Council and the elected representatives of the Penzance-Newlyn area to press for a re-think. As it stands, the “one-Cornwall” mantra has a hollow ring to it. Yours sincerely, Penny Young

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NAME......Mr J Sacree..........................................................................

Please note my objections to the local plan


. In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 regards Mr J Sacreé Gwithian Towans resident

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NAME.......Jeffrey Philip Collins......................................................................... Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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CALSTOCK PARISH COUNCIL Miss Sue Lemon Clerk to the Council email:[email protected] Cornwall Council Local Plan 22 April 2013 Dear Sir/Madam Please see the Calstock Parish Council response to the consultation for the Local Plan. Our Councillors feel that the whole document is not subjective enough and therefore meaningless. There does not seem to be any real action being taken in this plan and it appears that the Parish really needs to do its own Local Plan to ensure that our area is protected. Yours sincerely Sue Lemon Clerk to the Council

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Name Richard Higman/Kathy Pemberton

Organisation Padstow Town Council Address line 1 Unit 5B Trecerus Ind Est Address line 2 Padstow Address line 3 Address line 4 Postcode PL28 8RW Telephone number 01841 532296 Email address [email protected] Q1. Do you consider that the Local Plan meets the legal and procedural requirements? Difficult to comment on legality and procedural matters. Would assume Cornwall Council would have ensured that these requirements have been met.


Please specify the reasons below Again difficult to comment, would assume this is done correctly. Difficult to comment on whether the plan is “effective” as this won’t be possible to ascertain until things are done. Don’t understand what “positively prepared” is.

Yes No

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Can’t comment on whether it is consistent with national policy, but would presume Cornwall Council officers have met this test. 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

Page 7: Figure 1 Hierarchy of Planning Documents


Would be good to see the diagram also depict the bottom up approach too? Not just top/down approach. Local Plans can also inform strategic and national policy. General Comment: As with most policies – would be good to say “how” things are going to be achieved ...not just “what”. Padstow Town Council has struggled with support from CC in developing their NDPs. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

Policy 8


Good to see there is a mix. However, where possible in order to encourage a sense of community and place affordable housing should be provided for local people with emphasis on rented housing. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

PP10: Wadebridge and Padstow Community Network Area (Pages 106 to 108)


Suggest footnotes are included outlining source of key facts/figures (on these pages but also throughout the document)

Request that on page 108 that Padstow is mentioned in its own right and not just put in with surrounding parishes. Although not as large as Wadebridge it does different from the surrounding parishes. It is a town, is a working

harbour (fishing/tourism) and a major tourist attraction, there are issues with 2nd homes, large areas are ANOB so not possible to expand/increase house numbers.

Don’t think specific mention should be made of any NDOs (13.10) in place at present. Other Councils are working on NDPS/NDOs therefore the document would be out of date. Perhaps an appendix to the Local Plan which could be reviewed/updated on an annual basis to reflect latest NDPS/NDOs.

Should emphasise for Padstow’s need for affordable rental. Page 106: Objective 4 Environment: Need to take into account ANOB,

Padstow is surrounded by ANOB. 13.2: What is meant by “regeneration approach”. Padstow is also an access to the Camel Trail...not just Wadebridge. We see

large number of visitors both going from Padstow to Wabebridge and vice-versa.


Page 45


Natural Environment: Essential to protect Cornwall as a tourist destination which means green areas (particularly coastal) protection of ANOB and green belt. Not to overdevelop as this could impact on both the national and economic environment. Tourism is a huge part of what Cornwall is for a number of reasons, jobs (economy), issues around housing (i.e. often local people can’t afford to live in most sought after areas), national and historical environment. This needs to be more reflective in policy. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

Page 135


Monitoring Framework: Appreciate high level performance indicators in order to test delivery of the Local Plan. However, would like performance indicators at Community Network Level, with this information reported on a quarterly basis/annual basis in order that at a local level it will be possible to challenge the plan’s “effectiveness” (this will also help in answering Q2 of this questionnaire) and not just managed/reviewed at a corporate level in CC. Q4. Did you raise this issue earlier in the plan preparation process?

If yes, please specify at what stage: No, as far as I’m aware this is the first consultation on the matter.

Yes No

Q5. If your representation is seeking a change, do you wish to participate at the examination in public? Possibly, be good if you could explain what this participation would entail. No I do not wish to participate at the examination in public




428 RESPONSE TO LOCAL PLAN NAME.......William & June Powell......................................................................... Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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RESPONSE TO LOCAL PLAN NAME.....Keith and Valerie Jenkin........................................................................... Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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NAME...Trevor Newborn Please note my objections to the local plan as a resident and caring member of the Campaign for Protection of Rural England (CPRE) Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years. Regards, Trevor Newborn

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Name Arnaud Ruetsch Organisation Penzance & District

Tourism Association

Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? The Penzance & District Tourism Association has been involved from day one in the creation of the Penzance Sea front Forum and as thus our representative members have participated to the AECOM plan where, I must say, many great ideas regarding Penzance’s sea front have come up. The purpose of the AECOM was to develop a strategy for the next 20 to 50 years. We do not believe that the procedural requirements have been met for the Local Plan Pre‐submission document, specifically with regard to the P1 West Penwith Community Network Area. No organisation in Penzance has been consulted since and we are surprised to notice that the consultation period coincide with the election period, limiting involvements of any elected representative. The view of the PDTA is that the plan should be put on hold until further discussions with local organisations and consultation with the community has taken place.


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There has been no consultation what so ever with the Penzance community since the St Johns Hall exhibition in the summer of 2010 – and this was an exhibition not a proper consultation or real engagement. All the hard work produced during the AECOM program has been simply brushed aside without any explanations. The new plan does not reflect the ambitions of Penzance and is in fact detrimental to the future development of the Penzance sea front as it doesn’t take account of the aspirations of the Penzance community to improve the maritime aspect of the town. We feel the actual plan will cut short any chance of developments toward that goal. 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 2 Paras 4.1, 4.4, 4.5, 4.6, 4.7. 4.15. 4.16


The following points have been compiled by the Penzance Seafront Forum, and the PDTA supports them completely. The original AECOM plan made the Penzance harbour area a centre for regeneration, and included the development of the Harbour Car park and the creation of a Penzance Marina. The Penzance Harbour Users Association (PHUA) have been promoting their harbour expansion ideas to the east of the Albert Pier, tying them into (as Phase 1) the much needed harbour sea defences with an off‐shore breakwater to protect the existing harbour and provide year round protected moorings for the Scillonian on the Lighthouse Pier. These ideas are now well understood and widely supported in the town. The economic potential of such a development is significant. It is hoped that after the upcoming local elections what has to date been known as the PHUA Marina Scheme becomes the Penzance Marina Project, with more support and resources from other local organisations being pooled to progress

No

this ambitious proposal. Under General Policies para 2.7 the draft Local Plan suggests ‘Realising the development potential of Cornwall’s maritime sector will be critical to the region’s future, long term prosperity.‘ yet there is no mention in the plan of the potential of the widely supported Penzance Marina project, which has been removed from the current Development Framework plan, with no explanation to the community. There is plenty of discussion of the potential of Penzance Harbour, but without expanding the area of the harbour, there is little space for development. To leave the Penzance Marina proposal out of the Local Plan is extremely short sighted. The regeneration potential of marinas is well documented and understood; Penzance is the missing link in the coastal leisure cruising circuit and is missing out on a significant boost to its economy, employment and identity. The potential of developing the harbour in this direction must be part of the Local Plan and the next 20 years of policy in the region. A significant redevelopment of the harbour including a marina may also open up the opportunity for injecting future resilience into the transport network of the region in terms of coastal freight for example. The P1 West Penwith Community Network Area document suggests specific objectives to ‘broaden and diversify the local economy..through developing and promoting opportunities and employment prospects within the marine economies...developing high end tourism and the area’s natural assets…developing a strategy for the harbours and waterfront of Penzance and Newlyn’. The Plan goes on to stress that there are ‘significant opportunities [for Penzance and Newlyn] to diversify their marine related activities to maximise the unique opportunities of the wider Mount’s Bay.’ Yet there are no concrete suggestions for how to achieve this. There are however strong indications that in order to strengthen the town’s retail profile, the Harbour Car Park is designated for development. The Penzance Seafront Forum does not object to development of the Harbour Car Park in principle, provided the car parking provision is maintained to cater for the increased retail offer. We would of course look for a high quality development that integrates well with the town centre and harbour. However, the development of the Harbour Car park cannot be taken in isolation. This is land ‘immediately adjacent to the town centre’, but it is also land immediately adjacent to the existing harbour and the potential reclaim land and site for the Penzance Marina, and the omission of the Marina proposals from the Plan means that the car park site can be developed without anticipating such a future development. This will effectively destroy the chances of the Marina project. The Penzance Marina Project must be included in the Local Plan before it is submitted to the Secretary of State. An additional paragraph should be added to Point 8 of Policy 2, reading: ‘supporting the economic regeneration of Penzance as a retail, business and leisure centre including the potential expansion of Penzance Harbour and the creation of a Penzance

Marina, whilst developing its role as an travel interchange taking advantage of its position on the transport network (road, rail, sea, air).’ Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies







If yes, please specify at what stage: The PDTA has been involved in the discussions during the AECOM plan process in all matters regarding Penzance since the beginning. As members of the Seafront Forum we have been supporting its work regarding the development of the harbour. Q5. 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



Yes

432


NAME PETER&JUDY LUSTED

Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim


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433 Illogan Parish Council would like to make the following comments: Objective 8 – Environment ‘For CPIR to be renowned as a destination for cultural and heritage related tourism; in doing so acting as the hub for experiencing the World Heritage Site. Maintain the separate identities of Camborne, Pool, Illogan and Redruth, whilst utilizing their collective strength’ - to note that Illogan has two Areas of Outstanding Natural Beauty as well as a number of “green fingers”, which should be a priority for any Local Plan for this area to enable this objective to be achieved. Objective 2 – Housing of the Local Plan, the Council recommend that attention is drawn to: (a) the level of wages in Cornwall as a whole which excludes the majority of the indigenous population from purchasing a house, and especially younger parishioners, and (b) the drain on resources from retirees moving to Cornwall who, after a number of years, need part- or full-time care within the County, making the current proposals unsustainable.

Kind Regards Sarah Sarah Willsher Clerk to Illogan Parish Council Unit 2 Wheal Agar Tolvaddon Energy Park Tolvaddon Camborne TR14 0HX Tel: 01209 711433

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NAME.Kevin Hobson............................................................................... Please note my objections to the local plan



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435 Sirs,

Cornwall Council claims to be 'green' and 'sustainable' but this is mere propaganda as it is promoting levels of housing growth which are based on figures from Whitehall which reflect speculative builders' wishes and not local needs. I believe that Mebyon Kernow's proposed figure of 30,000-35,000 for 2010 - 2030 is far more apropriate, although personally I would prefer a lower figure - say 25,000. It is a matter of record that Dick Cole, Chair of Mebyon Kernow, as Chair of the Planning Policy Panel, opposed their targets which started as high as 54,000 and argued strongly for policy to be based on local needs, not speculative building. He was successful in getting the allocation for Camborne-Redruth reduced by 2,000 - 2,500 but the Conservatives, Independents and Liberal Democrats voted in full Council for the numbers for Newquay,Bodmin and Falmouth to be increased. I am not sure if St Austell has been finalised, but I know that Dick Cole has been arguing for a low figure in line with local needs. There is a wealth of well researched literature by respected academics which supports Mebyon Kernow's position on housing provision. It is a shameful reflection on the Conservatives, Independents and Liberal Democrats on Cornwall Council that they accept unquestioningly orders handed down to them from Westminster and Whitehall and appear incapable of independent political thought. Yours sincerely Paul A R Dunbar

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Mrs G Hatton Clerk

Website: www.mawganparishcouncil.org.uk

Cornwall Council Local Plan Team Carrick House St Clement Street TRURO TR1 1EB

22nd April 2013

Dear Sirs Cornwall Local Plan Thank you for the opportunity to comment on the proposed Cornwall Local Plan. Mawgan Parish Council is supportive of a Cornwall Plan in general, in order to prevent the misuse by developers of the National Planning Framework, which is all that is in force at present to regulate planning. However, it feels that all the statements and policies have a ‘get-out’ clause within them so that Cornwall Council can do what it wants if needs be and they are also too passive. They all use the words ‘could’ or ‘should’ in order to give the electorate a false sense of satisfaction but such words are not strong enough and can easily be worked round. These words should be replaced by ‘must’ so that there is no doubt that the policy is guaranteed to be upheld. Yours faithfully

Clerk.

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Local Plan – Strategic Policies Pre-submission 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.


Name Brian Perman Organisation Friends of Pendower Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? We are a community group on the Roseland dedicated to the protection and conservation of Pendower and Carne Beaches. We have 800 members. We feel the Plan needs to be strengthened in regard to Cornwall's Areas of Outstanding Natural Beauty 1. The Plan should specifically include all the policies and actions set out the AONB management Plan. 2. The Plan should include all the saved policies of the former Area Authorities relating to landscape and planning within the AONBs 3.The Plan should specify that all planning applications within the AONB must demonstrate that all these requirements are met. Environmental impact assessments should be included in all such applications. 4.The onus should be on a developer to prove that an application meets the criteria, rather than placing the onus on the public to prove that it doesn’t. Unless this practice is adopted planning applications will invariably favour developers above the interests of the wider public. Planning Officers and Planning Committees should also be required to demonstrate that their decisions meet the requirements of the policies and actions listed above. 5.These concerns are also relevant in Specific Policies (PPP 6 – p.82) as there is insufficient clarity about which policies apply to Truro/Kenwyn and which to the Roseland. Indeed, the Truro and the Roseland area includes places such as Chacewater and Carnon Downs as well as the Roseland: these areas are very different from the Roseland (eg in terms of public transport and travel to work areas).

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We are concerned that the Plan does not emphasise sufficiently the importance of preserving and maintaining Cornwall's unique landscapes. These landscapes make a vital contribution to the Cornish economy and this needs to be clearly stated.


2 15


It appears that newly applied technology will make small-scale hydro much more viable than before - see http://www.archimedeshydroscrew.com/. In landscape sensitive areas, it makes much more sense to prefer the idea of small hydro developments (lots of old mill sites on the Roseland) to wind turbines. In Policy 15, there should be a new paragraph 1(d) which supports "small-scale hydro generation in existing and former river mill and tidal mill sites".

Document Paragraph number Policy number Cornwall Local Plan – 3 15

Not yet

Strategic Policies Sustainability Appraisal Report

We agree with need to protect AONB against the visual effects of inappropriate development on adjacent land. This protection needs to be extended to apply to all land visible from an AONB, so that all visual impacts on the AONB can be considered in the context of the protections offered by AONB status and unacceptable visual impacts on the protected landscape of the AONB can be prevented. It is not sufficient to apply these protections to areas "adjacent" to AONBs. The protections need to apply to "developments which will be visible" from AONBs - any lesser extent of protection is not logical. Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies

16


This is about preventing development which harms existing and future renewable energy developments, but at present it is limited to future strategic developments. It needs to be extended to also state "New developments will not be allowed if they will hinder the development of new renewable energy installations in existing and former river mill and tidal mill sites."


2 23


Conserving the landscape and scenic beauty of the Cornwall AONBs should be given greater weight in the consideration of development proposals; the policy should state that any development should be: • appropriately located, of an appropriate scale and address landscape sensitivity and capacity; • compatible with the distinctive character of the location described by the Landscape Character Assessment, with particular regard to the setting of settlements and the rural landscape; and • designed to respect the locally distinctive quality of place, dark skies and tranquillity.

No development should be permitted in or outside an AONBs which would damage its natural beauty, character and special qualities.

Q4. Did you raise these issues earlier in the plan preparation process?

If yes, please specify at what stage:

Q5. 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 we wish to participate at the examination in public

x


No

438



Name Janet Pearson Organisation Address line 1

Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? I support The Penzance Seafront Forum (PzSF) steering group which has representatives from the following local organisations: The Chamber of Commerce, The Civic Society, the Penzance & District Tourist Association, Friends of Penzance Harbour, Friends of Jubilee Pool, Friends of the Earth, Transition Penwith, the Penzance Harbour Users Association, Penzance Sailing Club. Most of these members attended and contributed to the AECOM plan process and a great many positive and imaginative ideas were put forward and encompassed in that plan. I do not believe that the procedural requirements have been met for the Local Plan Pre-submission document, specifically with regard to the P1 West Penwith Community Network Area. There has been no serious engagement with the local community since then, and much of the AECOM plan has been whittled away. We are currently approaching local elections and the consultation period for the Local Plan Strategic Policies largely coincides with the purdah period associated with this, making discussion with and action by any local representatives impossible. The current version of the plan should not be submitted to the Secretary of State until the community is properly consulted. This process should begin once the local elections are completed, and I believe that Cornwall Council should suspend sending the plan for approval until it has meet with the community and its representatives to explain the content and reasoning of the plan.

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Please specify the reasons below Much of the positive achievements of the AECOM consultation has been lost. As there has been no similar engagement with the community since, the ideas and ambitions of the community have been obscured by a lack of vision. Cornwall Council has not justified its Plan to the local community, and there must be further detailed consultation in order for the plan to reflect the needs and ambitions of the town and surrounding area. The plan cannot be called effective as it does not consider the complex development and regeneration needs of the town and does not lay out an effective policy for the next 20 years. 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 2 Paras 4.1, 4.4, 4.5, 4.6, 4.7. 4.15. 4.16

Sustainability Appraisal

No

Report The original AECOM plan made the Penzance harbour area a centre for regeneration, and included the development of the Harbour Car park and the creation of a Penzance Marina. The Penzance Harbour Users Association (PHUA) have been promoting their harbour expansion ideas to the east of the Albert Pier, tying them into (as Phase 1) the much needed harbour sea defences with an off-shore breakwater to protect the existing harbour and provide year round protected moorings for the Scillonian on the Lighthouse Pier. These ideas are now well understood and widely supported in the town. The economic potential of such a development is significant. It is hoped that after the upcoming local elections what has to date been known as the PHUA Marina Scheme becomes the Penzance Marina Project, with more support and resources from other local organisations being pooled to progress this ambitious proposal. Under General Policies para 2.7 the draft Local Plan suggests ‘Realising the development potential of Cornwall’s maritime sector will be critical to the region’s future, long term prosperity.‘ yet there is no mention in the plan of the potential of the widely supported Penzance Marina project, which has been removed from the current Development Framework plan, with no explanation to the community. There is plenty of discussion of the potential of Penzance Harbour, but without expanding the area of the harbour, there is little space for development. To leave the Penzance Marina proposal out of the Local Plan is extremely short sighted. The regeneration potential of marinas is well documented and understood; Penzance is the missing link in the coastal leisure cruising circuit and is missing out on a significant boost to its economy, employment and identity. The potential of developing the harbour in this direction must be part of the Local Plan and the next 20 years of policy in the region. A significant redevelopment of the harbour including a marina may also open up the opportunity for injecting future resilience into the transport network of the region in terms of coastal freight for example. The P1 West Penwith Community Network Area document suggests specific objectives to ‘broaden and diversify the local economy..through developing and promoting opportunities and employment prospects within the marine economies...developing high end tourism and the area’s natural assets…developing a strategy for the harbours and waterfront of Penzance and Newlyn’. The Plan goes on to stress that there are ‘significant opportunities [for Penzance and Newlyn] to diversify their marine related activities to maximise the unique opportunities of the wider Mount’s Bay.’ Yet there are no concrete suggestions for how to achieve this. There are however strong indications that in order to strengthen the town’s retail profile, the Harbour Car Park is designated for development. The Penzance Seafront Forum does not object to development of the Harbour Car Park in principle, provided the car parking provision is maintained to cater for the increased retail offer. We would of course look for a high quality development that integrates well with the town centre and harbour. However, the development of the Harbour Car park cannot be taken in isolation. This is land ‘immediately adjacent to the town centre’, but it is also land immediately adjacent to the existing harbour and the potential reclaim land and site for the Penzance Marina, and the omission of the Marina proposals from the Plan means that the car park site can be developed without anticipating such a future development. This will effectively destroy the chances of the Marina project.

The Penzance Marina Project must be included in the Local Plan before it is submitted to the Secretary of State. An additional paragraph should be added to Point 8 of Policy 2, reading: ‘supporting the economic regeneration of Penzance as a retail, business and leisure centre including the potential expansion of Penzance Harbour and the creation of a Penzance Marina, whilst developing its role as an travel interchange taking advantage of its position on the transport network (rail, sea, air).’ Document Paragraph number Policy number Cornwall Local Plan – Strategic Policies







If yes, please specify at what stage: Many members of the Penzance Seafront Forum were participants in the AECOM consultation, and have been actively engaged with shaping the town’s development since. Dave Slatter is well informed and well aware of the ambitions of the town with regard to the harbour and potential marina. Q5. If your representation is seeking a change, do you wish to participate at the examination in public? No I do not wish to participate at the examination in public

No




Yes

439



Name Tim Timms – Representative:

Organisation 1 Organisation 2

Transition Penwith Penwith Environmental Network

Address line 1 Address line 2 Address line 3 Address line 4 Postcode Telephone number Email address Q1. Do you consider that the Local Plan meets the legal and procedural requirements? Transition Penwith and Penwith Environmental Network have a significant membership that realises the importance of local planning issues. The memberships of these organisations do not believe that the procedural requirements have been met for the Local Plan Pre-submission document, specifically with regard to the P1 West Penwith Community Network Area. The current version of the plan should not be submitted to the Secretary of State. We believe the community needs to be properly consulted. This can begin once the local elections are completed. We believe that Cornwall Council should suspend sending the plan for approval until it has met with the community and its representatives to explain the content and reasoning of the plan.



No

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Much of the positive achievements of the AECOM consultation have been lost. As there has been no similar engagement with the community since, the ideas and ambitions of the community have been obscured by a lack of vision. Cornwall Council has not justified its Plan to the local community, and there must be further detailed consultation in order for the plan to reflect the needs and ambitions of the town and surrounding area. The plan cannot be called effective as it does not consider the complex development and regeneration needs of the town and does not lay out an effective policy for the next 20 years. 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 2 Paras 4.1, 4.4, 4.5, 4.6, 4.7. 4.15. 4.16


The original AECOM plan made the Penzance harbour area a centre for regeneration, and included the development of the Harbour Car park and the creation of a Penzance Marina. The Penzance Harbour Users Association (PHUA) have been promoting their harbour expansion ideas to the east of the Albert Pier, tying them into (as Phase 1) the much needed harbour sea defences with an off-shore breakwater to protect the existing harbour and provide year round protected moorings for the Scillonian on the Lighthouse Pier. These ideas are now well understood and widely supported in the town. The economic potential of such a development is significant. It is hoped that after the upcoming local elections what has to date been known as the PHUA Marina Scheme becomes the Penzance Marina Project, with more support and resources from other local organisations being pooled to progress this ambitious proposal. Under General Policies para 2.7 the draft Local Plan suggests ‘Realising the development potential of Cornwall’s maritime sector will be critical to the region’s future, long term prosperity.‘ yet there is no mention in the plan of the potential of the widely supported Penzance Marina project, which has been removed from the current Development Framework plan, with no explanation to the community. There is plenty of discussion of the potential of Penzance Harbour, but without expanding the area of the harbour, there is little space for development. To leave the Penzance Marina proposal out of the Local Plan is extremely short sighted. The

regeneration potential of marinas is well documented and understood; Penzance is the missing link in the coastal leisure cruising circuit and is missing out on a significant boost to its economy, employment and identity. The potential of developing the harbour in this direction must be part of the Local Plan and the next 20 years of policy in the region. A significant redevelopment of the harbour including a marina may also open up the opportunity for injecting future resilience into the transport network of the region in terms of coastal freight for example. The P1 West Penwith Community Network Area document suggests specific objectives to ‘broaden and diversify the local economy..through developing and promoting opportunities and employment prospects within the marine economies...developing high end tourism and the area’s natural assets…developing a strategy for the harbours and waterfront of Penzance and Newlyn’. The Plan goes on to stress that there are ‘significant opportunities [for Penzance and Newlyn] to diversify their marine related activities to maximise the unique opportunities of the wider Mount’s Bay.’ Yet there are no concrete suggestions for how to achieve this. There are however strong indications that in order to strengthen the town’s retail profile, the Harbour Car Park is designated for development. The development of the Harbour Car park cannot be taken in isolation. This is land immediately adjacent to the existing harbour and the potential reclaim land and site for the Penzance Marina, and the omission of the Marina proposals from the Plan means that the car park site can be developed without anticipating such a future development. This too hasty plan will effectively destroy the chances of the Marina project. The Penzance Marina Project must be included in the Local Plan before it is submitted to the Secretary of State. An additional paragraph should be added to Point 8 of Policy 2, reading: ‘supporting the economic regeneration of Penzance as a retail, business and leisure centre including the potential expansion of Penzance Harbour and the creation of a Penzance Marina, whilst developing its role as an travel interchange taking advantage of its position on the transport network (road, rail, sea, air).’ Q4. Did you raise this issue earlier in the plan preparation process?

If yes, please specify at what stage: Transition Penwith members attended the July 2010 public exhibition of the Area Framework Plan which worked up the original AECOM proposals. In 2011

Yes

Transition Penwith became a founding member organisation of Penzance Seafront Forum and have been actively engaged with shaping the town’s development since. Dave Slatter is well informed and well aware of the ambitions of the town with regard to the harbour and potential marina. Q5. 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



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NAME - Alan Sanders




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NAME Mrs RJ Charman________________________________




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RESPONSE TO LOCAL PLAN NAME Mrs Vida Perrin Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 The housing figure for the CPR area is one of the highest but yet this is one of the most deprived areas of the County, not to mention the most built up area. The housing need figures used (ie 1,397 Band E) are critically flawed. I have completed a test submission and I was put in Band E. This basically means that pretty much anyone can go on the Homechoice register and that data can then be used to create more housing. The reality is that no-one in band E is ever likely to qualify for any such housing but that wont stop it being built. . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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443 Looking at the Plan from a local perspective I hope that the Council will take note of the recent spate of serious landslips in the Looe area. Hannafore, for example, was completely cut off when the only access road was completely blocked by a four foot wall of rocks and earth. It was quickly but only partially cleared and today, months later, remains partially blocked which suggests that a further collapse is considered possible. A few yards away a footpath by Looe harbour has been closed due to unstable cliffs which points to the general area as being at risk. This is another reason, as if being an area of outstanding natural beauty and a holiday destination wasn't enough, that this part of Cornwall is not suitable for significant housing development. Even if the land on which the houses are built is solid, rain running off from the developments could create problems for properties downstream. It might be coincidence but the multiple landslips at St. Martin's Road and Sandplace Road, the latter one with fatal consequences, have followed a large development higher up the hill in St. Martin's Road. Looking at the Plan from a broader perspective I appreciate that your remit does not extend beyond the county border but to understand the housing situation in Cornwall and decide what best needs to be done it is essential to step back and look at the big picture. We need to look at what is happening nationally and to put that in some historical context. Has there been a housing shortage in the past? If so did the attempted solution solve it? If not, why not? The year 1945 makes a good starting point. Following the war we had a housing shortage but happily a government which knew how to solve it. We had to build houses, lots of them, and that would solve the shortage. This was so obvious it hardly needed saying. Successive governments, backed up by private developers, proceeded to build on a large scale. Through into the 1950s the building continued but still there was a shortage so they carried on. In came the 1960s, 1970s, 1980s and 1990s. Decade after decade of massive house building yet against all expectations the shortage persisted. Even 13 years into the new century we are still building and still no end in sight for this shortage. Over those 67 years we have built some 16 million new homes. With an average occupancy rate of around 2.5 people per property that is enough to house 40 million people. Not all of these houses are additions to the housing stock, some having replaced older properties, but nevertheless it still represents a phenomenal increase in a relatively short period. Yet, if anything, the shortage is now worse than when we started building. Senior government ministers, first New Labour, now Coalition, tell us they can barely sleep at night for the worry about young people denied the right to a house and garden. Something must be done about it they say. We must build millions more homes, that's bound to solve the shortage. There is no single reason why the shortage has not gone away. Partly it is because with more homes the population can spread out and avoid sharing. Partly it is due to increased longevity and a higher divorce rate which leads to extra households. Increasingly though it is due to migration. Our loss of control over our borders means that as fast as we build new homes they will fill up, directly or indirectly with new people, migrants drawn into the country by, amongst other things, the availability of

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housing. This means that we can build another 16 million homes and still make no progress in dealing with the shortage. At the risk of being politically incorrect, we no longer have a shortage of housing but an excess of people. On top of that the Government is working in the opposite direction to Cornwall Council in particular with regard to affordable housing. In the recent budget, plans were announced to try and rig the housing market by pumping billions of pounds of tax payers money into mortgages at low interest rates which as history has shown will only serve to push house prices up and make them even less affordable. The Government is aware of this but wants houses to be as expensive as possible in the hope that home owners will be tricked into thinking they are wealthier and feel encouraged to resume reckless levels of borrowing to boost the economy. This sadly means that all the best efforts of Cornwall Council are doomed to failure. As the south of England becomes increasingly over developed and over populated we will see a rising number of people seeking pleasanter and less densely populated areas such as Cornwall which will only serve to increase demand and prices in the county and fill as many houses as you can build. At a national level this house building will fuel unsustainable population growth and further exacerbate our already dangerous dependency on imported food and energy. That is another matter altogether but one in which house building plays a critical part. This short sighted drive to boost economic activity and enrich developers and landowners could have catastrophic unintended consequences when political instability in any one of a number of trouble spots leads to disruption of food and energy imports. This is an issue beyond the direct responsibilities of Cornwall Council but if enough councils start expressing concerns about the long term consequences of massive house building central government might be persuaded to take heed. Keith Forsdick

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NAME_John Michael Trott




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NAME..W H Turner Please note my objections to the local plan Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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NAME_ Sylvia Trott___________________________________




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NAME___R.J. Charman




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448 NAME Stephen Murley Please note my objections to the local plan I agree with Cornwall CPRE’s stance on housing in Cornwall but am not against sensible well-built manageable numbers of housing which don’t rob us of green fields. What’s important is to meet local people’s needs first, probably redefine the definition of what a local person is to make sure you really deal with people who have been here generations first before those who just thought it was a nice place to live. Population is only ever going to go up, and the government don’t address that issue but you can do your part to keep the countryside as the countryside. Build too many houses and you loose why people want to live here, and you add to all the other amounts of money for infrastructure that we all have to pay for. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim . In Cornwall planning application are three times above the average in Britain. 85% of all applications are approved compared to 75% in the rest of the country . The current plans proposed by Cornwall Council mean we will have to build the equivalent of five new Truros in the next 20 years, this trend means that Cornwall's population will approach one million . This is too high a price to pay, to deal with current growth trends fact based evidence based on long term studies by CoSerg determine the figure required is 29,000 . Please note my response which is for 29,000 houses for Cornwall over the next 20 years.

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449 Cornwall Local Plan: Strategic Policies ‐ A Response Name: Craig Carey‐Clinch Comments and Objections in relation to the Cornwall Local Plan; Strategic policies. Please note that I wish to take part in the Examination in Public when it takes place. General remarks on the Plan The plan lacks specifics in relation to actual developments planned and their locations. The consultation questionnaire also seems to be carefully crafted to avoid the issue of housing and the appropriate level of development between 2010 and 2030. Respondents are not encouraged to comment on this issue. Hence my response in a letter format. I believe this plan is unsustainable and will be damaging to Cornwall’s environment, economy and culture. Since 1960 Cornwall's population has grown by 60%. This rapid population growth has clearly not produced the economic benefits its supporters claim. In short, this ‘Local Plan’ is unfit for purpose. It is short on detail and big on sweeping concepts which seem to have little relationship to the kind of pragmatic and evidence led planning that is needed. It does nothing to establish the contingency planning required for an uncertain world. Resource depletion, environmental and cultural stress all demand a newer, more radical approach and not a continuance of ‘business‐as‐usual’ policies of suburban residential communities distanced from places of work, with both leisure and utility reached mainly by private motorised transport due to public transport provision that does not cater for individual need. The proposed plan misses the opportunity for the Council to lead a debate about the kind of Cornwall we should build, using the huge quantities of previously used industrial sites resultant from the county’s historic activities. This would avoid the need to build on productive Greenfield land, which currently provides local food production and associated local employment. Greenfield site development will destroy many local communities and lead to little more than characterless urban sprawl, which in itself can give rise to social problems, particularly as no feasible plans are put forward to radically increase employment once these houses are built. The plan talks about job creation and jobs are often used to justify house building. But this is a false prospectus – when the houses are built and those who built them are unable to find other work, we have done nothing to actually create real economic growth and sustainable long term jobs. One only has to look at Ireland to see the results of predatory housing development in rural areas which was not linked to wider employment sustainability policies. The economic crash of 2008 meant that these became deserts of abandoned rural housing estates. The Local Plan fails to state actual house building proposals in a way that can be understood and reacted to, so that local citizens can comment on proposals from developers, some of which experience shows will be predatory. This will allow developers to go a long way towards gaining permissions to build where they choose, so maximising their profitability, as opposed to building where local need actually exists. As we are well aware, the preference

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of developers is to build on Greenfield sites, claiming that brownfield development is too expensive – while at the same time recording large profits from their businesses. This factor appears to be overlooked by the Council. Greater scrutiny is urgently needed. The proposed 42,250 figure was created by adding to the Planning Policy Advisory Panels 38,000 recommended figure. Because a few others claimed to want more is an unacceptable way to create public policy on housing. The final figure should have been arrived at using proper evidence, not a lottery of ‘horse traded’ numbers where the hand of powerful lobbying by developers could clearly be seen. Indeed, the process by which the 42,250 houses figure was reached deserves investigation – particularly in relation to the links between Council officers and housing developers. This plan lacks a long‐term vision. It fails properly to assess the long‐term consequences of continuing a never‐ending cycle of housing and population‐led growth. It fails to provide evidence to justify its supposed economic benefits. In 2007 the then County Council commissioned a Quality of Life survey. Among other questions, this asked residents in Cornwall what they felt were the biggest threats to the natural environment. Almost two thirds identified housing development as one of the ‘greatest threats to the natural environment’ while over a half cited a growing population as another major threat. At the same time more than two thirds thought that the rising level of traffic was the third threat the environment faced. What therefore does it say about living in a democracy when these concerns are so bluntly dismissed in the Local Plan? In Cornwall, planning applications are three times above the average in Britain and 85% of all applications are approved compared to 75% in the rest of the country. This is growth for growth’s sake and cannot be justified. The current plans proposed by Cornwall Council mean we will have to build what is in effect the equivalent of five new Truros in the next 20 years. This trend means that Cornwall's population will approach one million by the end of this century. The negative environmental and social consequences of unfettered growth such as this is clear to predict. The Cornish Social and Economic Research Group (CoSERG) has produced fact‐based evidence, based on analysis of recent and current growth trends that shows the housing figure over the period of the plan should only be 29,000. We cannot justify building houses on Greenfield sites by any sensible measure and this must stop. PLEASE NOTE MY RESPONSE WHICH IS FOR 29,000 HOUSES FOR CORNWALL OVER THE NEXT

20 YEARS. Penponds As mentioned above, the Local Plan proposals lack specifics, but for Camborne Pool and Redruth, 4,500 new houses are planned by 2030. Although specific plans for housing locations are not included, the last consultation in March 2012 revealed a developer plan to fill in the green space between Penponds/Treswithian and Camborne with new housing. A link road was also planned to replace parts of Boundervean lane and running past Cogegoes to Treswithian.

It is my strong suspicion that the Local Plan Strategic Policies are masking that fact that this 2012 proposal is still sitting quietly on a table in an office somewhere at Lys Kernow. The current works to ‘develop’ the A30 roundabouts at Treswithian provide strong evidence of this. The Council also admits that this development is to facilitate new housing. I completely oppose any such greenfield development in the Penponds and Treswithian area for the following reasons:

Penponds is a VILLAGE with a fine character and an important social history, not

least Trevithick. Penponds Church is a fine example of its type and was hailed by

Betjeman himself, who described it as a ‘true gem’ and its character relies on its

rural setting. Penponds therefore is part of Cornwall’s heritage and its character

needs to be preserved, not swallowed up by faceless urban sprawl which will

destroy Penponds identity.

The area to the north and east of Penponds, land adjacent to Treswithian, plus the

valley to the west is an area of important farmland and natural beauty which offers

an important Cornish rural vista from the old A30 route west via Connor Downs. Any

development here would be highly damaging to this visual and natural environment.

The area has been subject to mining activity, as shown on old maps. A line of shafts

were sunk in fields adjacent to Cogegoes Farm. This calls into question the possibility

of any kind of development on this land at economically viable cost.

Traffic and noise levels would vastly increase both on a new link road and also in

Penponds Village itself, which cannot sustainably manage an increase in traffic due

to the narrow, mostly single track, road through the village.

The 2012 proposals were for so‐called ‘eco’ developments. This is nothing more than

cynical ‘greenwashing’ by developers. How can housing development that eats into

greenfield agricultural land, increases the number of cars on the roads and the need

for individual travel, be in any way shape or form be called ‘eco’? Such eco

developments are indicated for urban areas, where transport and utility links

already exist ‐not for rural sites.

The suspected plan for Penponds and Treswithian merely highlights my concern that

predictions of growth have been made with little in the way of supporting evidence

which sets out how economic growth plans will secure the employment for the

residents of all these extra houses, or provide for their transport needs. As

mentioned above, it is not the case that houses are built and jobs magically appear.

House building itself only creates temporary economic benefits, not long term

growth on its own.

Therefore, in summary, housing developments for the much more limited genuine local need should be restricted to entirely brown field sites and be linked to employment growth and other genuinely local factors – in other words, only built as employment and genuine LOCAL (not imported) social needs emerge.

Yours faithfully, Craig Carey‐Clinch

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NAME___E.P. Bennet




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