Another update on the "eco-community"

On behalf of Cllr Matt Luke and myself, I have made further representations to the Inspector dealing with the Examination into the Cornwall Local Plan which recommences on 16 May.

In particular, we have addressed his pre-hearing questions about the so-called “eco-community.”

Our representation is set out below. The Inspector’s text is repeated below in italics and our comments are in bold:

Principle

4.17 Is the identification as a broad location in this Plan of a new community at West Carclaze/Baal justified in the context of the following:

Progress/decisions already made in the context of previous/existing strategies eg China Clay Regeneration Plan and recently committed and planned public investment in the area (eg road improvement, Technology Park/ESRAM building)?

It is our view that the construction of the Technology Park cannot be used as a justification for the construction of 1,500 new properties at West Carclaze and Baal. We would refer the Inspector to the recent meeting (28th April 2016) of the Council’s Economy and Culture PAC (Policy Advisory Committee). At this meeting, it was agreed to recommend to the Cabinet that “the delivery of the Carluddon Technology Park, at a total cost of £9,041,075, be approved” with the unitary authority acting as the “accountable body for £6,238,000 of European Regional Development Funding.” Match funding of £2,803,075 was identified “from the following budgets; a. £1,753,075 from the EU match funding capital budget, approved as part of the Medium Term Financial Strategy; b. £763,000 from the eco-communities budget within Planning; c. £287,000 in-kind match from the value of CC owned land.”

Please note that this was due to be agreed by the Council’s ruling Cabinet on 4th May (following the production of this note).

We would point out that no money from the construction of the 1,500 houses would therefore be going towards the construction of the Technology Park, showing the disjuncture between the housing development and other developments in this area.

The substantial area of currently despoiled land, but taking into account that there are the long term restoration conditions?

It is our understanding that there are significant restoration conditions in this area, which place considerable obligations on the landowner. We note that the Council, in its representation to the Inspector’s preliminary questions, also downplays the loss of green field land as part of the scheme.

It is our view that Cornwall Council should furnish the Inspector with detailed information about the restoration conditions as well as further information about the amount of housing that would be constructed on green fields (or “previously unworked land” as described by the unitary authority).

We would point out that the landowner (and associated partners) do not need to build 1,500 housing units in order to undertake the restoration it is already obliged to carry out.

The particular scale of development proposed (1,500 dwellings with 1,200 in the plan-period) – why is this scale necessary to achieve the stated benefits?

It is our view that the scale of development that has taken place (and is planned to take place) in the China Clay Area is excessive and we would refer the Inspector to our previous representations on this matter. In particular, we would point out that the level of housing growth between 1991 and 2030 would be 87%.

Whether it is deliverable to achieve the expectations of the Plan.

It is our view that the removal of the “eco-community” proposal would not, in any way, make the remainder of the Local Plan unsound.

Irrespective of this particular proposal, does the overall strategy of the Plan/Council/LEP justify/require these 1,200 dwellings (in this plan-period) either within the China Clay CNA or the wider grouping of the 3 CNAs and or/the Regeneration Plan Area (see text in the Plan, version J.2, PP9, p157). If not assigned to West Carclaze/Baal where should they go?

It is our view that the “eco-community” at West Carclaze and Baal became an allocation in the draft Cornwall Local Plan because of the (now cancelled) Planning Policy Statement which said that an “eco-town” should be built near St Austell. Officers at Cornwall Council should be willing to confirm that, during the development of the Local Plan document, the unitary authority consistently viewed the “eco-community” as a “strategic” and not a “local” allocation. On numerous occasions, it was stated that if it was not delivered, the housing allocation would be redistributed across Cornwall as a whole.

We are therefore particularly disturbed that the Council, in its representation to the Inspector’s preliminary questions, stated in the “Sustainability Appraisal of the Cornwall Local Plan: Strategic Policies 2010-2030 SA report Addendum January 2016” it has undertaken “consideration of further reasonable alternatives for specific CNAs and includes assessment of St Austell CNA/China Clay CNA/Eco Community … it assesses two options for providing 1,500 homes, a concentrated approach i.e. the Eco-Communities or dispersed approach through distribution through the CNA.”

It remains our view that if the “eco-community” is removed from the Cornwall Local Plan and the Inspector deems it necessary, any residual target should be reallocated across Cornwall in a pro-rata fashion and not located elsewhere in the parishes of the China Clay Area or on the fringes of the town of St Austell.

4.18 deals with the proposed development at Par Docks, but our comments are restricted to West Carclaze and Baal.

Detailed matters/requirements

4.19 In LI.ID.3, 3.3/3.4 I asked about the justification for the energy efficiency/renewable energy requirements etc of the policy. The Council’s response draws on the national picture, but does not explain why the requirements are specifically justified for this development when not sought in similar terms for any other development. In short, why only here/why here at all?

We are concerned at the nature of this query. This proposal, which we oppose, only came about because of a Government push to construct “eco-towns” which would comprise properties with a very high environmental performance. Indeed, if it were not for that initiative, we would not be debating the merits of a proposal to build 1,500 properties in an area so completely disconnected from existing settlements

It would however be particularly galling if this development was allowed to proceed with lower environmental standards than initially promised.

4.20 I also queried the 30% affordable housing requirement. The Council’s response confirms that this is above the zonal rate for the area of 25%. The Council will be aware that I have seen no evidence to support this approach and that the site developer Eco-Bos seeks 25%. Given the apparent close working between the Council and Eco-Bos, I would hope that this matter could be resolved by the parties before the hearing.
Again, this proposal came through the Government push to construct “eco-towns” when higher levels of affordable housing were expected. The early iterations of an “eco-town” on this site variously promised 40-50% affordable housing (Clay Country Eco-town The Facts; 2008) or 40% affordable housing (see Clay Country Eco-town Summary Booklet; 2009).

We consider 30% to be too low and feel it would also be particularly galling if this development was allowed to proceed with an affordable housing target as low as 25%.

4.21 The table in policy 2a gives a total figure of 1,500 dwellings for the eco-communities and a footnote indicates that this is made up of 1,200 dwellings at West Carclaze/Baal and 300 at Par Docks within the plan-period. The Council confirms that it regards the capacity of the sites as 1,500 and 500 respectively. Should these figures be used in the Plan so as to indicate the full extent of the proposals, whilst recognising that not all will be delivered in the plan-period?

We have no views on this point.