Wednesday, 13 April 2016

Update: Cornwall Local Plan and the so-called “eco-community” proposal

As I have already reported on this blog, the Examination in Public into the draft Cornwall Local Plan will be reconvening on 16th May.

I can further report that the Inspector has sent three notes through to Cornwall Council seeking further information on key areas which he would like to address in the upcoming hearings.

One of these notes related to the so-called “eco-community” which Mebyon Kernow and others have made representations on. Once Cornwall Council has responded “interested parties” will also be given an opportunity to respond further.

The statement from the Inspector (dated 8th April) was as follows:

Inspector’s Preliminary Questions for the Council on the Changes 
Part 3: Eco-Communities West Carclaze/Baal and Par Docks 

1. Introduction

1.1 This is the 3rd in a series of notes I am sending to the Council to try and clarify and focus matters in dispute in advance of the hearings. For more background, please see my first note of this series (LI.ID.1). When I have received the Council’s response I will provide the opportunity for a written response from interested parties.

1.2 Timescales are tight. It would be helpful if I could receive a response by the end of Friday 15th April. Although this is an important tissue, I am not expecting substantial new documentation. A response of 3-4 pages should be all that is necessary, together with a simple plan of the location of any features referred to in the response or below.

1.3 It is important that my assessment of the soundness of the strategic principles of these proposals as set out in the Plan is kept separate from the detailed, site-specific proposal in the current planning application which is not a matter for my decision or comment. Accordingly, I do not expect the Council to provide me with the detailed evidence submitted in support of that planning application nor will I accept copies of the representations which have been made on that application (as requested by Cllr Cole, Rep 892 and others).

1.4 The Eco-communities are referred to in principle in new policy 2, part 2l (change 13) and in detail in amended policy 3 (change 25).

2. Principle of the Proposals

2.1 The main evidence in support of the Eco-communities proposal in this Plan that has been formally submitted by the Council is: West Carclaze/Baal and Par Docks Eco-Communities Site Allocations Overview Report (January 2015) (Examination Document A15) and the Strategic Flood Risk Assessment (January 2015)(A16). I have not seen any subsequent update. The Council should therefore bring the position up-to-date with reference to (so far as is relevant): the completion of the A391 Carloddon road scheme; progress on the technology park and ESAM building and how this relates (if at all to) to the proposal; the significance or otherwise of the emerging proposal for a link road to the A30 and whether the proposals in the Plan depend on that link and any other significant changes of circumstances since the analysis in A15.

2.2 As highlighted in representations, the Planning Policy Statement Supplement on Eco-towns was cancelled in March 2015. Given that this had provided an important context for the original development of the scheme, the Council should provide a brief summary of why it considers that the eco-communities concept in these locations is still justified.

2.3 Any changes in relation to flood risk, particularly at Par Docks should also be highlighted, including the current position of the Environment Agency.

2.4 Bearing in mind that a planning application (prepared I understand by the Council) was submitted in January 2015, but remains undetermined some 15 months later, are there any fundamental obstacles to the start/delivery of the proposal if it were to remain in the Plan at adoption?

3. Detailed matters

3.1 The proposed changes have reduced the scale of new housing proposed in both locations. K1.CC.1 (PP9) notes that the figures have been reduced to those that are considered deliverable. Does this mean deliverable in plan-period? Do the figures also reflect what is the overall, long term scale of development? If not should those also be (remain) in the Plan, so that appropriate decisions on infrastructure and master-planning are made at the outset?

3.2 30% affordable housing is proposed. For both locations is this consistent with the zonal rates in policy 8 (change 60). If not why is it justified? (It is queried by Eco-Bos, rep 128).

3.3 What is the justification to demonstrate high levels of energy efficiency in the fabric of the buildings on the site given the Written Ministerial Statement of March 2015 on requirements relating to construction and energy performance? Has this and the other requirements specific to this proposal been viability tested? If justified, should there be greater clarity of what is required?

3.4 Are the requirements in relation to all energy being from renewable and low carbon sources on or near the site and provision of a low carbon heat network feasible and viable/deliverable?

3.5 If part of the justification for these proposals remains the opportunity to address an area of “derelict or despoiled” land should land “restoration” (in some form) be a requirement and over what area?

3.6 Two particular site-specific concerns are raised in representations: the loss of the few remaining green fields in the area and the threat to a County Wildlife Site. Irrespective of the particular proposal in the planning application, are these 2 impacts inevitable or likely and, if so, what is the harm and is any such loss justified?

3.7 In my first note to the Council in this series (LI.ID.1) on Employment Floorspace I made the following comment (3.3d):  For St Austell CNA a note on the 2nd table in J.8.2 states that the residual target (presumably for the industrial floorspace) will be delivered in the adjacent West Carclaze. If this intention is justified (which will need testing as part of the examination of the Eco-community) it should be made clear in the Plan.

3.8 Should the provision of the residual requirement for industrial floorspace that cannot be delivered in St Austell CNA be directed to West Carclaze? If so, how should that be expressed in the Plan? Would the Carloddon Technology Park be part of that prevision or has that already been counted in the figures in J.8.2 for China Clay CNA?

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