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CPRE Cornwall's Objection to the Proposal for 1300 homes at St Austell
Planning Application 09/01525/OUT – Land off Treverbyn Road, St Austell – Wainhomes – Erection of 1300 dwellings etc.
1. CPRE Cornwall has examined this planning proposal and all the supporting material most carefully. Having examined the proposal in detail it makes the following planning representations to the LPA. CPRE Cornwall formally objects to the proposal and sets out below its planning reason for this and specifies why the proposal should be refused planning permission which it asks Members to take into account when making a decision on the application.
The Development Plan
2. The proposal represents a major expansion of St Austell and it is noted the developer accepts this. The proposed site is not allocated for housing and any of the uses proposed in the current Development Plan and this is not disputed. Therefore the applicant has to clearly justify their proposal and why the provisions of the Development Plan should be set aside to enable it to be approved. In this case the applicant relied on the need to meet the provision of the RSS and housing targets within it and claims that there is not a five year supply of deliverable housing land in St Austell.
3. The justification for the proposal based on the RSS is now outdated as the Planning Minister has suspended the RSS prior to its abolition. Therefore the proposal remains totally contrary to the Development Plan. The contents of the Development Plan are to prevail when determining planning applications of this nature. Given this there is no longer any justification for approving the proposal.
Plan Lead System
4. The applicant then claims that the application site is the only one for the future expansion of St Austell. Whether St Austell should continue to grow and develop, at what rate, and where are decisions for the Council’s Local Development Framework (LDF) Core Strategy. The Government has made it clear on several occasions that major decisions of this nature are to be made via a Plan Lead System i.e. the LDF and not by, as in this case, a speculative, ad-hoc planning application. This is because the processes and procedures of the LDF allow the community to be properly and fully engaged in major decision making about the future planning of their area and for all options to be properly and comprehensively assessed.
5. This proposal removes from the Plan Lead System the ability to make a fully informed decision about the future expansion of St Austell. For example, given the acute infrastructure problems (which the applicant admits to) is it right the town should continue to grow at current rates? Is the application site the only one available to accommodate future development? What does the local community need in terms of future housing? What are the implications of the Eco-Villages proposal on the needed for future housing requirements for St Austell? Why should this proposal be developed to significantly lower sustainability standards that the Eco-Villages given their close proximity? What do the local community of the Town want? All of these and many others are questions for the LDF Core Strategy and that is when any future housing sites in and around St Austell should be identified.
6. If the LDF is not therefore to become a meaningless exercise and document in terms of St Austell (because of the announcement of the Eco-Villages and this planning application) then the proposal has to be deemed to be premature pending the outcome of the LDF and should be refused because of this. Note - Members should be aware that prematurity can with other reasons be used to refuse a planning application as in this case.
Housing Land Supply
7. Planning Policy Statement 3 (PPS3) requires LPA’s to maintain at least a five year supply of deliverable housing land in their area. The applicant claims that the supply of deliverable housing land in St Austell is now below five years. CPRE Cornwall and others dispute this. The difference of opinion appear to largely hang on the actual housing need figure for the town which the Council and LPA have refused to release until the case officer’s report into the planning application is in the public domain. This is of course too late to allow others such as CPRE, SOUL and the Town Council to take the figure into account in there representations. This CPRE Cornwall deems to be unreasonable behaviour by the LPA and the Council who have been informed formally that an award of costs will be sought against it at any appeal or Inquiry.
8. The fact is that the applicant’s whole rationale for this proposal is now only based on a mathematical argument on need and supply of housing and housing land. CPRE Cornwall considers this a desperate attempt by the applicant to gain approval for their site in advance of other sites which might be more suitable for housing and welcomed by the local community.
9. There is agreement that the deliverable supply of housing land is not to be exhausted in the next two to three years. Given this if we consider the current housing needs for the town and the deliverable supply of housing sites, them CPRE Cornwall would strongly suggest that there is sufficient supply to enable the LPA to refuse this application and allow the LDF process and Core Strategy to identify any future housing development sites in the town knowing that the supply of housing land will not be exhausted before this process is completed. This would represent the best outcome for the local community and allow the applicant to have their site properly assessed for allocation for future housing with others. Therefore CPRE Cornwall finds that having regard to the immediate need of the town for housing and the supply of deliverable housing land there is no overriding justification to set aside the Development Plan or the need to deliver a Plan Lead System and the application can safely be refused.
Agricultural Issues
10. The applicants at the recent Town Council meeting made great play about the limited agricultural output from the site. They site this as justification to develop it even though it is in the open countryside and is good quality agricultural land and therefore the proposal is contrary to national planning policies and the provisions of the Development Plan. It must be remembered that present output from the land is more to do with the current management of the land and not the value and quality of the land.
11. The LPA has to have regard to the fact that the agricultural land forming the application site is good quality agricultural land and would appear to fall within the defined Best and Most Versatile Agricultural Land. The Government is committed to protecting such land to help sustainable food production, and most importantly the land is free from any limitations in terms of its potential production. Given this the application could and should be refused on this ground. Infrastructure Issues
12. The applicants stated at the Town Council Public meeting on the 29th June that “The infrastructure here at present is struggling to cope,” and “It (the infrastructure) cannot cope anymore.” The applicant then use the infrastructure problems in St Austell as justification to be allowed to build more houses to further overload the infrastructure of the town and offers to offset any further impacts on the already broken infrastructure system by contribution up to £7million to help fund new infrastructure works.
13. There is agreement by all parties that the infrastructure of St Austell is at capacity and cannot cope with any further development. This is a critically important fact.
14. While £7 million appear a significant amount of money, in relation to infrastructure projects it is in fact quite a small amount of money and it will not fix or begin to fix the many infrastructure problems of the town. It is a contribution but that is all. It will not fund what is needed for the town to function as it should. Hence the net impact of this proposal will be to make the infrastructure of St Austell problems even worse not better.
15. An example of this is in relation to the identified need for a new school. Part of the £7M would be used to fund the new school but the balance, perhaps a half, would need to be found from the public purse. It is understood in the current economic climate money for a new school would not be available. Hence temporary classrooms are likely to have to be erected at existing school sites in the town. Is this what Cornwall Council sees as the future of St Austell? If the application generates the need for a new school should not the applicant fund all of the cost of that new school? But the school is only one example and there are others. The conclusion is that the £7M will not deliver and address the infrastructure impacts associated with the proposal. By implication if the developer is allowed to build the 1,300 houses the infrastructure problems in St Austell will get significantly worse. There is from SOUL material detailing this.
Sustainability
16. The applicant again made much play at the Town Council public meeting of the standards of construction to be used in building the proposal. These are in fact no more than the national requirements for new homes and are less than the standards to be used in the eco-villages proposal.
17. But delivering Sustainable Development as required by Planning Policy Statement 1 is more than the construction methods and standards used when building houses. It raised more fundamental issues and questions. CPRE Cornwall notes this proposal is called the northern expansion and due to its location and scale it is certainly that. What has not been addressed is whether this site is the most sustainable one in terms of expanding St Austell? This is a question that would be addressed in great detail as part of the LDF process. Often the location and position of development sites is key to their sustainability rating. So how does this site rank and rate in relation to others in and around the town? Is it the best? CPRE Cornwall does not consider at present the site is the most sustainable one for development regardless of the attempt by the developer to introduce other uses into the development mix. This in fact suggests the location is not the right one as it needs to have other uses introduced to cut down on private car journeys etc.
Eco-Villages
18. The Eco–Villages proposal cannot be ignored but this proposal appears to want to do just that. The Eco villages proposal is of a scale which will, .if it is developed, dwarf this proposal. But due to the fact that the two proposals have been brought forward by different routes (and not via the LDF as they should have been) there is no indication of any linkages (how transport system and infrastructure will in total be affected and any improvements that are needed) between the very different development proposals.
19. It is in fact quite unbelievable that in total over 6,800 houses are to be delivered in two major proposals without an overall Master Plan for the general area which covers both proposals and shows how they will dovetail together. This represents very poor planning for St Austell and the general area.
20. In CPRE Cornwall’s view the lack of joined up planning and linkages between the developments is a serious omission. There is no evidence in the application submission of any working together and if anything it is clear that both developers see each other’s proposal as a potential threat to their development.
Consultation and Public Engagement
21. Developers are encouraged to engage with the local communities on proposals of this scale and size. The developer appears to think this has been done and done well.
22. The engagement process has relied on a consultation process just before the planning application was submitted on plans that appear to have been clearly finalised. There is no evidence that the public consultation process in any way or to any degree influenced or shaped such an important proposal as this one to the local community. The local community refer to the consultation process as a sham and CPRE Cornwall would not disagree with this assessment.
23. The LPA should totally disregard any claim that the proposal has any degree of community support in St Austell. The views of St Austell Town Council are highly pertinent to this point and show the degree of dissatisfaction and opposition to the proposal. That is the true community view of the proposal. It is noted the community have asked the LPA to refuse the planning application on valid planning grounds.
24. The decision to appeal against non-determination is the applicants right although the claimed justification is flawed. It is a clear attempt to take decision making away from the local community.
25. Even at this late stage without any public or community engagement the applicant has submitted two further applications to ensure that some type of planning permission is obtained. This cannot in any way be described as engaging with or working with the local community. It is unfortunately an example of how volume house builders treat local communities and the LPA. It is hoped that Wainhomes would have set a better example and shown greater commitment to really working with the local community.
Conclusions
26. The application is major in scale and significance to St Austell. The local community do not want it. There are numerous valid planning objections to it any of which warrant refusal but in combination they make an unquestionable case for refusal.
27. CPRE Cornwall joins with the local MP, St Austell Town Council, the four neighbouring Parish Councils all of whom voted unanimously to reject the proposal, SOUL and most importantly the local community in urging the LPA to indicate that if the applicant had not appealed against non-determination the LPA would have refused the application.
Written by Richard Ward, Planning and Development Manager for CPRE Cornwall, on 29th July 2010
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