Representation to council consultation on Local Plan

ORIGINALLY PUBLISHED APR 14, 2014

Here’s what I’m sending to the Council – you’re welcome to plagiarise any or all of it. And here’s a Word version – representation on LP

Policy 1: Presumption in favour of sustainable development

I note the addition of ‘the three pillars of economic development, social development and environmental protection and improvement’ to this policy. This is a slight improvement. However, the Sustainability Appraisal Addendum 2014 (p.5) states that ‘it is unclear how the process will be undertaken’ and urges that these three pillars ‘must be considered together and not in isolation to avoid overriding weight being given to any one pillar.’

In contrast, the Local Plan (LP) is unbalanced as it

  • gives overriding weight to the economic pillar – ‘our overall aim is to support economic growth’ (LP, para 1.19).
  • fails to suggest ways of measuring the social and environmental pillars.
  • does not take the social and environmental pillars into account in its Policy 2,.4 ‘provide for 47,500 homes’ (see below).
  • does not accord with the National Planning Policy Framework (NPPF), which explicitly aims at a balance between sustainability and growth (p.i).

Policy 2: Key targets and spatial strategy

I object to Policy 2.4 ‘provide for 47,500 homes [sic] over the plan period at an average rate of about 2,300 per year …’

First, this should be corrected to read ‘provide for 47,500 houses over the plan period at an average rate of about 2,375 per year …’. A significant proportion of the additional housing stock in Cornwall ends up with no permanent resident, being used as second homes or holiday lets and not first homes. It is therefore inaccurate to call all these ‘homes’. Second, 20 x 2,300 = 46,000 not 47,500.

The 47,500 target should be reduced on the following grounds.

1. Inadequate and faulty datasets

  • The NPPF states that Plans should be based on ‘proportionate evidence’ (para 182) while evidence should be ‘up to date, robust local evidence’ (para 218)
  • The Cambridge Centre for Housing and Planning Research states that official household projections should be used ‘unless there is strong, local evidence to the contrary’ (Choice of Assumptions in Forecasting Housing Requirements, p.24)

The evidence used to derive the housing target is neither proportionate nor robust. Indeed, there is strong local evidence that official datasets consistently exaggerate population and household growth in Cornwall.

All eight Office for National Statistics (ONS)/Department for Communities and Local Government (DCLG) projections in the 2000s overestimated growth. The five ONS projections overestimated population growth in that decade by between 25% and 69%. The three DCLG projections overestimated household growth by 63% to 106%. This consistent inflation was also indicated in the ONS mid-year estimates throughout the 2000s. Such consistent failure suggests a structural flaw, almost certainly principally the result of overstating net in-migration. The demographic projection which is the basis of Policy 2.4 therefore needs to be revised downwards to between 29,800 and 35,500 to take account of the past performance of these flawed projections.

2. Adverse impacts

Paragraph 14 of the NPPF states that local planning authorities should meet objectively assessed need (although this is not objective in the Cornish case – see 1 above) unless ‘any adverse impacts of doing so would significantly and demonstrably outweigh the benefits’. The adverse impacts of a housing target that potentially doubles Cornwall’s population and built-up area every 77 years are considerable but have been ignored in this policy. These adverse impacts can for example be traced in the following dimensions.

a) Cornishness and Cornwall’s distinctiveness

Policy 2.4

  • is in breach of the Framework Charter for the Protection of National Minorities. Article 16 states ‘All parties shall refrain from measures which alter the proportions of the population in areas inhabited by persons belonging to national minorities’.
  • fails to provide an Equality Impact Assessment of the effects of its population growth policies on the Cornish as a distinct group.
  • does not meet guiding principles b) ‘ensuring a strong, healthy and just society’ and d) ‘promoting good governance’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.
  • does not meet the social dimension of sustainable development, ‘supporting strong, healthy and vibrant communities’ (NPPF, para 7).
  • does not meet core planning principles of the NPPF (para 17), namely ‘empowering local people’, ‘conserve heritage assets’ and ‘improve health, social and cultural wellbeing for all’.
  • contradicts para 50 of the NPPF, to meet ‘needs of different groups in the community’.
  • contradicts the preamble of Policy 2, ‘respecting the natural and historic character of Cornwall.
  • contradicts Policy 2.6, ’maintain the special character of Cornwall’.

b) Landscape and countryside

Policy 2.4

  • does not meet guiding principle a) ‘living within the planet’s environmental limits’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.
  • does not meet the environmental dimension of sustainable development, ‘contributing to protecting and enhancing our natural, built and historic environment’ (NPPF, para 7).
  • does not meet core planning principles of the NPPF (para 17), namely ‘enhance and improve the places in which people live their lives’, ‘encourage the effective use of land’ (note also the contrast between the detailed local policies for housing (LP, section 4ff) and the SA, p.48), and ‘open land can perform many functions’.
  • contradicts the preamble to Policy 1, ‘respecting the distinctive character of Cornwall’s diverse landscapes’
  • contradicts Policy 2.5b ’protection and enhancement of environmental assets’.
  • contradicts Policy 2.6, ’maintain the special character of Cornwall’.

c) Climate change

Policy 2.4

  • contradicts its Green Cornwall Strategy aim of reducing greenhouse gas emissions in Cornwall by 34% by 2020 (Green Cornwall Strategy, p.15)
  • does not meet guiding principles a) ‘living within the planet’s environmental limits’, c) ‘achieving a sustainable economy’ or e) ‘using sound science responsibly’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.
  • does not meet the environmental dimension of sustainable development, ‘contributing to protecting and enhancing our natural, built and historic environment’ (NPPF, para 7). The NPPF specifically encourages local planning authorities to ‘move to a low carbon economy’ (para 7)
  • does not meet core planning principles of the NPPF (para 17), namely ‘support the transition to a low carbon future’.
  • contradicts Policy 2.3 ’minimise resource consumption’


d) Biodiversity

Policy 2.4

  • does not meet guiding principle a) ‘living within the planet’s environmental limits’ of the UK’s Sustainable Development Strategy, as set out in the NPPF. p.2.
  • does not meet the environmental dimension of sustainable development, ‘contributing to protecting and enhancing our natural, built and historic environment’ (NPPF, para 7). The NPPF specifically encourages local planning authorities to ‘improve biodiversity’ (para 7).
  • does not meet core planning principles of the NPPF (para 17), namely ‘conserving and enhancing the natural environment and reducing pollution’.
  • does not meet para 118 of the NPPF, refusing development that will lead to a ‘loss or deterioration of irreplaceable habitats’.

Other
Throughout the Local Plan there is considerable ambiguity about whose needs are being met. For example, the LP states ‘meet our current and future needs’ on page 7. This should be revised to more precisely read ‘to meet the current needs of Cornish communities and meet market demand from future generations of in-migrants’, as in-migration accounts for virtually all projected population growth (SHMNA, 57 and 140).

Advertisements
This entry was posted in Local Plan. Bookmark the permalink.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s