Comments and Representations from Lanner Parish Council
1.1 These comments have been ratified by Lanner Parish Council following a seminar held by Mining Villages Regeneration Group of which Lanner Parish Council is a member.
2.1 Although the draft Plan represents an improvement on the previous consultation draft, Planning Future Cornwall, it remains deeply unsatisfactory. We need to have a Local Plan in place which we understand, have confidence in and indeed of which we are proud; a plan driven by the need to improve the wealth and well-being of those who live here rather than those who want to come here; a plan which focuses more on resilience rather than growth for growth’s sake. Where growth takes place it should be employment driven and have adequate infrastructure in place. A strong plan for our urban areas is fine but we also need a strong plan for our rural areas which seem to have very little role in this document other than being something that isn’t urban. The plan should be for the people of Cornwall not Cornwall Council – growth appears to be driven by activities where there are external subsidies/funding. This Plan looks bereft of original ideas, ignores most of the county’s fundamental assets, is analytically suspect, is poorly presented and is going to help create more problems than it solves.
2.2 In short, we find this not so much a land use plan, but rather a development charter. The whole concept of planning appears to have been subjugated to a desire to build houses. As such, it falls short of the community’s expectations and requirements.
2.3 Lanner Parish Council would welcome the opportunity to develop the points raised in this document at any examination in public of the Plan.
3.1 Not for the first time, Cornwall Council has produced a document – an important, prospective quasi-legal document at that – where style is prioritised over the substance: the grammar, punctuation and general sense of some passages suggest proof reading is an acceptable cost cutting measure. It isn’t.
3.2 The use of “facts,” written on Post-Its in the document, is sometimes contradictory and often of little help in understanding the arguments. The Key Facts which introduce the individual CNA policies, though consistent in their presentation, do not provide the basis for a useful reasoning of the policies advanced (more on that later).
Here are two examples which show themselves early on:
1.12 “For many years the Council has sought to promote higher incomes” – it would have been interesting to see what success the Council has had in that. It is also interesting that the level of incomes to regional or national averages is not to be used as a measure of success for this Plan: nor indeed is the EU average (such an important economic indicator to Cornwall over the past 20 years) . There is then the usual running down of tourism because it is “dependent on seasonal employment”. Why is full time seasonal work less desirable than year round part time work which is all that’s being generated at present (unless it’s voluntary work!)? The rest of this section then makes no sense at all even grammatically and perpetuates confusion between cause and effect, symptoms and illness.
1.13 “Changes in the population present major challenges” – why not look to an ageing population as an employment opportunity rather than a threat? Cornwall could learn a lot from Florida!!
3.3 Here are some Key Facts: Cornwall’s GDP is currently 71% of the EU average and 62% of the UK average. Since Objective One arrived in 1999 when GDP was 66% of the EU average we’ve seen straight-line growth relative to the EU of only 1% every 3 years. Where would we be without EU poverty related grants? If and when Cornwall reaches 75% of the average EU GDP then special funding will cease. How will that affect inward investment? Shouldn’t comparative incomes and GDP be a continual measurement of success or otherwise and the potential trigger for a radical change in planning policies within the Plan period?
Tourism provides 24% of Cornwall’s GDP and 1 in 5 jobs. With food and drink production it accounts for 45% of the economy. 82% of Cornwall’s land mass is farmed. There is little in the Plan to suggest these facts are in the forefront of the planner’s thinking.
VISION AND OBJECTIVES
4.1 There are probably no issues arising from Policy 1 that are capable of challenge, bearing in mind that it seems to be a full reflection of current national government thinking. Having said that, the way in which we are seeing the “presumption in favour of sustainable development” interpreted nationally gives cause for concern as the fear is that the NPPF is a developer’s charter. At the same time, both Localism and Neighbourhood Plans are so much smoke: local communities have little or no ability to resist imposed development other than seeking to mitigate its impact and the cost of Neighbourhood Plans is prohibitive to most rural communities particularly bearing in mind the limitations on truly local input.
4.2 It is noted that the Plan suggests the degree of “sustainability” in a “sustainable development” can be a variable thing – and that flexibility is to be welcomed.
4.3 Policy 2 raises some questions, provision of the answers to which could add to confidence in the Plan. In particular:
It would be very reassuring if we could see a direct correlation presented between the number of new jobs targeted with the number of new homes to be built and the number of indigenous unemployed who would be accommodated by the new jobs.
It would also be of key interest to see what the current levels of people unemployed are, the number of people of working age and the number of people of working capacity for each CNA. (CPR contains a high level of deprivation).
When targeting new jobs are we looking at new full time jobs or part time or seasonal jobs? There is ambiguity in the text. A “job” needs to be defined if we are to measure.
4.4 Working from average figures provided from the Homes and Communities Agency, Employment Densities Guide 2010, the suggestion is that the 211,250 square metres of office space planned will provide 7,824 jobs and the planned industrial space of 211,150 of industrial space will provide 3,640 jobs giving a total of 11,464 jobs. Using the lowest figures from this Guide suggests the target floor space will create 17,604 office jobs and 5,865 industrial jobs: a total of 23,469 jobs. That indicates between 26,500 and 38,500 of the planned increase will come from other forms of employment. These need to be identified so that the Plan has credibility and outcomes measured during the Plan period.
4.5 Priority should be given to filling, adapting or redeveloping the existing 60,000 square metres of empty commercial space. Building commercial space in itself is no guarantee of jobs being created. What indicators exist to suggest that planned employment targets will be met? If they are not met, how will adjustments be effected within the plan of these targets: not only for employment space but related housing?
4.6 Given the big question mark over the Plan’s ability to deliver the required number of new jobs, the planned new housing target appears sufficiently high as to deliver significant growth to the level of unemployment and the retired. Is this a wise approach for one of the poorest areas in Europe and how is a high pool of unemployed compatible with the objective of better paid work? We do not believe there is sufficient evidence to validate a new housing target of over 30,000 unless and until sufficient progress in employment growth is seen to be secured as to warrant it. It is easier to revisit and revise a paper Plan than to deal with the effects of excess development.
4.7 The homes referred to in the Policy and in Table 1 are based on the balance of probabilities at a moment in time taking account of expectation of migration, jobs and availability. That balance of probabilities will change over the Plan period. Thus the “minimum” figure should be a “target” figure and variable according to the circumstances prevailing. The concern is that if the “balance of probabilities” prevailing today is erroneous the Council would be obliged to approve developments up to the level of the “minimum” and Cornwall could end up like parts of the Irish Republic with masses of speculative new dwellings and nobody to live in them. Cornwall Council should be under an obligation to keep what would then be a target figure under regular, say annual, review.
4.8 There has to be concern that it is only the coastline that is singled out here for protection: presumably other areas of the countryside will have to demonstrate their superior worth against any development proposal put forward. There should be protective measures identified as a primary objective for all AONBs and SSSIs: in particular the protection to be afforded coastal AONBs should be afforded to the one inland AONB – Bodmin Moor.
4.9 There is no comment about water. Water shortage is generally acknowledged to be a more pressing concern worldwide than of food or energy.
4.10 In providing a Spatial Strategy it is of the highest importance to discuss the importance of open spaces in relation to our key industries of tourism and food production. Open spaces are not empty spaces but have economic significance and value which needs to be addressed here.
5.1 Policy 3 seems incontestable except that we need to see a definition of “local”. To most, it would be taken as meaning of the village or hamlet. However, it is apparent from the perspective of Cornwall Council that it could have much a wider definition.
6.1 We are pleased to see paragraph 1 of this Policy but would go further. Cornwall has one of the highest levels of supermarket floor space per head of population in the country. In the case of out-of-town retail development, a claim for “consumer choice” should not be sufficient in itself to justify “need”.
7.1 It seems surprising in Policy 5 that a whole section is given to identifying the need to support the marine sector which currently contributes about £130m (and that we also wish to see flourish) when no mention is made here of the need to support the food and drink industry which brings about £1.5 billion to the economy. Growth is in the manufacturing and processing of food products and it is the whole of the food industry, not just farming, that the Plan needs to support. A very positive contribution could come from supporting shorter food chains within and distribution lines out of the county. Further, it is essential that support be provided to ensure the continuance of at least one, central livestock market for Cornish farmers and that the county’s abattoirs be protected.
7.2 Health and Social Services are major employers in Cornwall. The way in which these services are deployed, how they are physically accessed by those needing them, and how they are to develop and grow must be addressed. This industry has significant growth prospects and the maintenance of health, including we assume the development of skills and knowledge in it, is one of the main Themes of the Plan. It merits identity and consideration here.
8.1 The provision of new homes needs to be employment driven. Where new homes are built to accommodate local needs, support should be provided to raise the standard of homes thereby vacated which fall below desired standards if a self-perpetuating cycle is to be broken. Ways of making good deficiencies within the existing housing stock as a way of mitigating the need to build new homes and quantifying those opportunities needs to be addressed. In addition, there are many opportunities for providing homes from existing empty commercial homes which should be explored and quantified.
8.2 As argued above, the number of new houses proposed appears to be excessive in relation to the provision of new employment and the necessity for affordable homes for local needs to satisfy Bands A-D. It would seem that the majority of new homes proposed are for inward migration and for which there are insufficient new jobs available. Thus competition for jobs will be exacerbated, and wage levels depressed, by building an excess of new homes.
8.3 In considering housing mix, urban development which affords relatively high densities in buildings of more than two stories and in multiple occupation should be favourably considered. There is historic landscape precedent in our towns to recommend this approach. Flats are perfectly acceptable in the urban environment and where building land may be relatively expensive.
8.4 The role of the private landlord in the housing market should be addressed and encouraged.
8.5 The issues of housing, social care and health and welfare when combined do not receive the detailed attention that they deserve. This neglect illustrates the weakness in preparing a Plan which apparently begins with certain goals or conclusions and works backwards ignoring the SWOT factors of the present. The fact is that, notwithstanding a slight immediate blip to the contrary, the age profile is of a rising number of old people coupled with a falling number of young people. So, whilst there is a short term need for more housing, by the latter stages of the Plan period there will be a general decline in demand and values will fall. It is also possible that more houses will become and remain unoccupied. The Plan needs to address this scenario, not leave it for the next generation.
9.1 The relationship between affordable homes and local need homes is not clearly defined and nor their difference distinguished. It should be. Many people confuse affordable homes with homes for first time buyers and few seem to embrace the concept of shared or part ownership.
9.2 Specific reference should be made to the approach to be adopted to the provision of affordable homes in rural areas in accordance with the NPPF paragraphs 54 and 55. In particular, the Plan does not refer to rural exception sites or seek to define them. The NPPF defines these as “small sites” for local needs. Given Cornwall Council’s ambivalent use of the word “small” and the phrase “local need” we require an agreed tighter definition. Common parlance, professional practice and the use of 10 dwellings as the trigger for “the provision of a range of housing type and tenure” in Policy 6 all suggest 10 as being the upper limit of “small”. (Para 2.32 in the Plan document alludes to the exception site approach , though not by name, but is far too imprecise).
9.3 The way in which housing need is assessed, and thus the level of affordable housing required, continues to be confused and confusing. It is appreciated that exact precision cannot be obtained. The Plan highlights the Homechoice register headline figure as a key indicator. It then refers to households banded A-C as showing a significant housing need. It then shows figures for Bands A-D and separately for Band E. Using the definitions which Homechoice ascribe to the Bands, it seems most logical to look to accommodate A-C but plan for A-D to allow for flexibility. Band E should not be provided for in the figures, as by definition persons in Band E are not in need. Thus the “need” in CPR should read 1307 not 2704.
9.4 There needs to be a precise definition of what “local” means in the phrase “local need”. We suggest that it is the need directly coming out of a particular geographic community which should not exceed the size of a rural parish or the town council boundary, but it may include someone who is evidenced to be required to supply care to or receive care from a close relative in that community. It should not mean a cluster of parishes or indeed the wider Cornish community. A definition of “local need” is essential in the consideration of rural exception sites: it is not synonymous with “local connection”.
10.1 Policy 9 refers to tenure split being established by reference to either the Cornwall housing register or to specific local surveys. This should be “and” to avoid the possibility of one being used in preference to the other merely to achieve a housing target and to secure the widest base for assessment. Moreover, and perhaps more importantly, the level of local need itself for affordable housing should be so established.
10.2 If a scheme is “affordable housing led” then any open market housing should be less than 50% of the whole development and not defined as “not more than 50%”. To be affordable housing led, any such scheme should not include more than 40% open market housing. The current proposal inverts the proposition of development being affordable housing led.
10.3 In employing the Cornwall housing register (Homechoice) to determine the level of need for affordable housing it needs to be remembered that Homechoice is first and foremost a choice based system for allocating social housing. In using it to determine local needs, as opposed to general levels of needs, not only are the applicants’ Bands and local connection material (and on which we have commented above) but also whether or not applicants actually want to live in the parish to which they have a local connection. Our experience is that not only will the removal of Band E reduce “need” by over a half, but removing applicants who express no desire to live in the parish can reduce this “local need” by about a half again.
10.4 If there is to be community involvement in the decision making process then the register, in redacted form to exclude the possibility of individuals being identified, should be available to the relevant town or parish council.
11.1 It is highly desirable that technologies for renewable and low carbon energy should be developed. However, it is foolish to produce energy by such methods unless and until it is economic to do so. At this point in time it would appear that renewables, particularly wind turbines and solar panels, free of subsidy, are not a sustainable option.
11.2 Bearing in mind that Cornwall is a poverty area within the EU, to focus on renewables now – and in particular to unilaterally and substantially exceed the targets agreed in the Covenant of Mayors – would seem to put the county at even more of a comparative economic disadvantage. It is considered inappropriate for the Local Plan to be a vehicle for purely political expression.
11.3 At least until the price of energy produced by wind turbines to the National Grid is equal to or competitive with the general cost of energy exported to the Grid, no further wind turbines should be permitted. The prospect of cheap shale gas coming on line needs to be factored in to avoid irreversible decisions being made now which may be regretted later.
11.4 In considering proposed developments for wind turbines or other large scale energy developments such as solar panel “farms” their effect on the general landscape and on other land uses such as tourism should be a material consideration regardless of whether they are in an AONB or coastal area.
11.5 Cornwall has a history of using its rivers and streams to generate power: reintroducing such systems, particularly for individual businesses and residential clusters should be positively encouraged.
12.1 With regard to Policy 17.2, it would seem appropriate for Cornwall Council to reaffirm its commitment to the continuance and development of the existing network of public rights of way and to its duty to maintain those footpaths, bridleways and highways to a useable standard.
12.2 Allotments and the use of private gardens for fruit and vegetable growing are outside of the planning remit. Does Policy 17.4 indicate a change in attitude towards garden sheds, greenhouses and the like? If so, some clarity is needed.
12.3 There is much evidence that some controls and standards would be beneficial in respect of private allotments. We are witnessing, in some instances, inappropriate and inadequate access; a proliferation of huts and sheds in open countryside with no site screening provision; allotments being used for children’s play equipment and late or all-night parties; and an unwillingness to action by planning enforcement.
12.4 Is there any intention for Policy 17.4 to be used to impact on people’s rights to extend and/or to seek permission to build in their gardens?
13.1 Does the support referred to in Policy 18 indicate that public bodies will, in future, use Cornish granite and slate versus imports?
14.1 We believe that the particular advantages in managing human waste and extracting energy and other resources such as fertiliser, heavy metals, aggregates and recycled water from it by the use of anaerobic digesters should be highlighted. There are significant opportunities for supporting the siting of such operations at and in conjunction with sewage plants and water treatment centres.
14.2 We are confused by the categorical statement in para 2.82 that “no additional landfill capacity will be needed up to 2020” which is then apparently qualified in Policies 20 and 21 which indicate circumstances which will allow additional landfill facilities. Clarification here is needed.
15.1 Grade 3b agricultural land is, essentially, the specialist grassland that supports Cornwall’s renowned dairy and livestock industries. In addition, outside of the AONBs, this land provides the classic rural landscape with patchwork fields edged by Cornish stone hedges and a far higher level of biodiversity than Grade 1 or 2 lands which tend to be more intensively farmed and increasingly covered in plastic to get fruit and vegetables to the early markets. Its safeguarding is essential to the Cornish food industry, the tourist industry and the future of the family farm.
16.1 We would draw out the warning in Policy 23.1 that regard should be had for “the potential cumulative impact” of development. In terms of damage to biodiversity, the risk is not necessarily site specific but on the way in which an accumulation of developments (not necessarily all of the same type) can cause irreparable damage to indigenous and migratory wildlife.
17.1 With regard to Policy 26.2b, in no case should development increase the flood risk to other properties or sites in the neighbourhood whether or not in a recognised flood plain. This has particular importance as Cornwall Council has moved from a planned maintenance strategy for drains, ditches and culverts to a response based strategy. In addition, the cumulative impact of planning consents must be taken into account in each flood plain before further consents are granted.
18.1 Accessibility, particularly for rural areas, is of great importance. The provision of bus services to many rural areas is weak: routes are being cut or the frequency of buses reduced; fares are becoming more expensive; mechanical and operational reliability of buses poor; profits and competition limited. For most within rural areas the private car will continue to be the primary mode of transport throughout the Plan period and this should be acknowledged and catered for unless substantial subsidies for public transport can be guaranteed.
18.2 Capital expenditure appears relatively easy: it is maintenance costs which are the most difficult to find. Use of any transport mode – particularly walking and cycling – will be frustrated if both proper planned and responsive maintenance of routes is not undertaken.
18.3 We again recommend reducing the speed limit on rural roads (that is roads outside of towns and villages or which are not A or B roads) to 40mph from 60mph. This would improve road safety, reduce carbon emissions, and reduce wear and tear of the road surface.
18.4 Support for rail services should be a priority and proposals which encourage the movement of goods by rail or through the ports should be looked at positively.
PP4 Camborne, Pool, Redruth CNA
19.1 Although the Mining Villages are all located within the Camborne Pool Redruth CNA, Truro, and Falmouth also exert strong pulls on our communities’ economic and social activity.
19.2 Each of the CNA ”plans” is prefaced with Key Facts. We can (perhaps naively?) assume that these Key Facts are presented to illustrate the rationale behind the policies. So with that in mind let’s compare three selected CNAs – CPR, Camelford and also St Austell.
19.3 Looking at persons per dwelling CPR has 2.22, St Austell 2.05 and Camelford 1.97. The suggestion must be that the higher the figure the younger the population profile.
19.4 Considering the figures for Housing Need, those quoted are for “preferred area”. Does this relate to just first preference, or to all three preferences presented on the Homechoice application form? If preference relates to the latter then there can and will be overlap or duplication with other CNAs. To what extent, if any, has any duplication been accounted for?
19.5 We can also compare housing need between areas: thus, assuming all who need affordable housing already live in the area: CPR has 2.21% of its population in A-D seeking affordable housing; St Austell 2.93% and Camelford 1.48%. So in an area like Camelford it appears clear that with such a low number of indigenous people looking for affordable homes the 900 planned are mainly open market for incomers. This is pretty much in line with the 2008 estimation of 70 – 80% of new CPR housing being for incomers.
19.6 What do the highlighted facts tell us about job provision? The first thing to say is that it is unclear whether the “employees estimate” is indeed for employees or includes the self-employed. Given the relatively high level of self employed in Cornwall it is surprising that these are not worthy of special mention. For CPR the number in full employment is given as 20.42% of the overall population and for all employment 32.66%. But what relationship does this bear to those who are actively employable? In St Austell the numbers are 24.97% and 42.68% (signifying much more part time employment) and in Camelford it is only 3.51% and 6.63%! So for Camelford 900 new homes are being built and 200 jobs provided, suggesting a total retirement zone!
19.7 This mis-match between jobs and homes is without doubt a major catastrophe for the Plan.
19.8 Outside of CPR the housing target of 500 in total for all the rural areas is hardly stretching: which is to the good as it can probably be met by infill. It is unclear – indeed ambiguous – as to whether affordable homes for local needs are within that figure or to be added to it. There is no good reason why local needs housing should not be calculated within the overall figure.
19.9 Within CPR the Policy disappoints and is self-contradictory. Camborne and Redruth cannot be protected as viable town centres when there is an active plan by Cornwall Council to force Pool into becoming a dominant sub regional retail destination. “To replace unsustainable past competition between the towns with a strategy that promotes a coordinated response” is disingenuous. It is Truro and out of town “retail offers” that have weakened Camborne and Redruth and the planned Out-of-town retail complex at Pool will kill both off as destination shopping locations. Moreover, there should be active encouragement of retail in Chapel Street, Redruth which is level whereas Fore Street is a steep hill. No new out of town supermarkets should be permitted within CPR. Cornwall Council will be aware of the possibility of at least one of the existing Tesco stores closing. It is arguable that there is too much retail space in CPR – the issue is more of quality and variety.
19.10 Using the figures from 4.4 above, our calculation is that the given amount of planned office/industrial floor space will only provide 2002 jobs. But let’s take the given figure of 2850 jobs. At present there are 0.58 jobs per dwelling in the area. Even allowing for the current level of chronic illness and the elderly in the area there is still a lot of potential for take up of those new jobs within the existing community. It is therefore highly likely that the net additional 4500 houses within the area will result in a shortfall of at least 60% of their occupants coming from the local community. Or, to put it another way, the Plan is planning for 2700 households within the community for whom there will be no employment.
19.11 Health and social work is a major employer in the area, providing a ready pool of skills which could provide the base for growth in the expanding industry of maintaining and extending the quality of life in old age. No mention is made of this in the Plan other than services should be “improved”.
19.12 If Pool is to have a major commercial future a serviceable railway station should be fostered in addition to, and not at the loss of, Redruth and Camborne railway stations.
19.13 Substantial investment is required in primary and secondary education – the building blocks of further and adult education. From the “Key Facts” it can be assumed that there is a minimum of 0.22 children per household. Therefore, 4500 new homes will provide 990 additional schoolchildren. This far exceeds the extra capacity anticipated in the Core strategy discussion paper. Further, particularly at primary level, distances to schools beyond those that are walkable are inappropriate: the word “consolidate” sets of alarm bells in this respect.
19.14 How confident can we be that there will not be further drainage embargos on development which had a profound effect within the mining villages’ area?