Caradon District

Statement by Caradon District Council (Respondent Number 144) regarding Plymouth HMA (Matter 4/8) Wed 13th June 2007

Executive Summary
Caradon District Council broadly support the housing growth identified in the Draft RSS because of the acute need for affordable housing in the district and the need to regenerate our towns and villages. However, it may prove difficult to identify sustainable locations for the scale of development being proposed. Outside the Plymouth Urban Area, the Council seek a more dispersed pattern of development that enables market housing to be directed towards the three largest towns (Liskeard, Looe and Callington) and suitable villages.
Within the Plymouth Urban Area (Saltash and Torpoint) the Panel are advised that development options are highly constrained around Torpoint, meaning that all housing growth would need to be accommodated in Saltash. The Council believe that housing growth in Saltash should be aimed at increasing the self-containment of the town as there are significant constraints which limit the relationship with Plymouth.
1. Introduction
1.1 This statement relates to the Plymouth HMA Sub-Regional Strategy discussion which is scheduled to commence on Wednesday 13th June 2007. Caradon District Council notes that this discussion is primarily focused on urban issues. In our original response (submitted in July 2006) we raise a number of rural issues which are relevant to the Plymouth HMA but do not form part of the timetabled discussion. Whilst we have strictly limited this statement to the questions being raised on the day, we ask the Panel to view all of Caradon’s comments in the context of our original response.
2. General Comments on Housing Distribution
2.1 Table 4.1 of the Draft RSS indicates that 290 homes need to be provided in Caradon each year between 2006 and 2026. Inset Diagram 4.7 indicates that 50 of these need to be provided within the part of the Plymouth Urban Area falling within Caradon (Saltash and Torpoint). The figures set out below give an indication of what this might mean in terms of new greenfield housing allocations:
Potential housing development outside Caradon’s existing urban areas up to 2026 based on Table 4.1 of the Draft RSS. Plymouth UA (Saltash/Torpoint) Remainder of Caradon Proposed Housing 2006-2016

* NOTE: Urban Capacity to 2016 was estimated in a study carried out in 2004. There are no urban capacity estimates for the period beyond 2016, so for the purposes of this table, the same annual rates are assumed to continue up to 2026.
2.2 The Council supports the level of additional housing in principle due to the acute need for affordable homes and the need to regenerate towns and villages through new investment and activity. However, the Council also wishes to ensure that a sustainable pattern of development is promoted and that new housing growth does not cause any local environmental impacts which might adversely effect the existing population.
2.3 The Council draws the Panel’s attention to the limited quantity of previously developed land within Caradon’s urban areas and the fact that most of the proposed new housing will need to be accommodated on greenfield sites. We have some concerns about the potential impact of this development on a predominantly rural landscape and our ability to identify appropriate locations in the context of national planning guidance.
2.4 The Council have some concerns about the revised RSS Housing Scenarios (February 2007). All of these revised scenarios show a significant increase in the level of proposed development. Scenario 3 (which proposes 429 dwellings in Caradon each year) would result in approximately 7,700 greenfield allocations in the district up to 2026. It would be very difficult to accommodate this scale of development in a sustainable and politically acceptable manner.
Housing outside the Plymouth Urban Area
2.5 We note that very significant housing growth is proposed outside the Plymouth Urban Area. This part of Caradon contains three main towns; Liskeard (population 8,652) Looe (population 5,280) and Callington (population 4137) based on the 2001 Census. There are over 70 villages in this part of the district, with the population of the 10 largest villages in the range 1,000 - 2,000. The housing being proposed in the Draft RSS could lead to over 4,000 new housing allocations in this part of Caradon which is a scale of growth not experienced previously.
2.6 For this reason, the Council are particularly concerned that the new housing is distributed in a sustainable manner. We do not agree that this level of development should only be focused on the largest market town in Caradon (Liskeard) and therefore seek a distribution of housing across the other main towns and significant villages. Focusing all development in Liskeard would nearly double the size of the town and severely affect the local landscape. A more dispersed distribution model would result in smaller extensions to additional settlements, helping to reduce the impact on social character and local landscapes.
2.7 The Council’s view is that Development Policy B of the Draft RSS should contain a clear statement that it will be for the local planning authority to decide which towns fall under this policy. We also feel that there should be 3
A clearer definition of what is meant by ‘self containment’ in the context of Cornish towns. The focus should not solely be on focusing new development around public transport nodes, but should also incorporate other facets of sustainability. Caradon’s towns provide services for networks of villages and hamlets and therefore play an important role in sustaining a wider rural hinterland.
2.8 With regard to Development Policy C, the recognition of the role of smaller towns and larger villages as a focus for sustainable development in rural areas (which is given in paragraph 3.5.1 of the supporting text) should be raised to policy status. This policy would then allow Caradon to accommodate new housing in a more dispersed and less disruptive way. The Commission for Rural Communities identify access, network and financial deprivation as particular issues in rural areas. Enhancing the viability of smaller settlements through housing growth may help to address these aspects of rural deprivation.
Housing within the Plymouth Urban Area (Saltash & Torpoint)
2.9 The Panel should note that both Saltash and Torpoint are particularly constrained by land ownership, planning designations and natural features and that it will be difficult to meet the housing figures suggested for these areas in a sustainable way. It is very unlikely that suitable sites will become available in Torpoint, so 100% of the PUA growth will be directed towards Saltash. Given the physical constraints, including the Tamar Bridge, the Council believe that new housing in Saltash should be aimed at helping the self-containment of the town rather than serving as an extension to the Plymouth Urban Area.
2.10 The Council feel that Saltash should be given Development Policy B status and this should be reflected in supporting text. The Saltash Gateway Community Strategic Action Plan (prepared by the Saltash Gateway Market and Coastal Towns Initiative) sets out a community vision for the town. Housing growth of an appropriate scale, which supports the fruition of this plan (including a mixed-use community campus on the edge of the town) is supported by the Council. The Caradon Local Plan Public Inquiry is not due to close until 26th June 2007, but in response to objections the Inspector suggested the following text for inclusion in the Local Plan which is broadly supported-
“Whilst the allocation of this land at present [for a community campus] would not generally conform with the Structure Plan, the Council accepts that, owing to its scale and location, Broadmoor Farm is an obvious site for consideration as an urban extension to Saltash, although not necessarily to the exclusion of the development of other land in this part of the District.
Should Broadmoor Farm be developed at some time in the future, the Council would expect a scheme to be based upon the three following principles. It should be community-led, it should reflect the needs of the community and it should be based upon a comprehensive, holistic approach with a strong emphasis on all relevant aspects of sustainability, including the generation of renewable energy, minimum emissions and the achievement of the highest environmental standards.”
3. Questions raised by the Panel
3.1 Is the draft RSS sufficiently clear about the spatial outcomes it is seeking in Plymouth towards its present and future sub-regional roles ? Reply: The Sub-Regional Statements section gives prescriptions for the joint study areas, including the Cornish Towns and the Plymouth, South East Cornwall and South West Devon area. The ‘Cornish Towns’ statement fails to include large areas of the western part of Caradon, whilst the ‘Plymouth, South East Cornwall and South West Devon’ statement and map gives the impression that eastern Caradon is part of Plymouth. This causes confusion and concern for non-technical readers of the RSS. The Council request that the mapping and wording is changed to make it clear that Caradon is part of Cornwall. We also request more clarity on what the policy prescriptions are for areas not included within the Sub-Regional Statements.
3.2 Has the scale of additional greenfield development been adequately justified against the likely level of housing requirements and in particular the urban renewal opportunities in Plymouth ? Reply:  As already explained under Section 2 of this statement, there is likely to be a significant amount of greenfield development taking place within Caradon. There is a limited amount of opportunity to build homes on previously developed land due to the rural nature of the district. The Council wish to ensure that opportunities to develop on brownfield sites elsewhere in the Plymouth HMA have been exploited before committing to further greenfield development in Caradon.
3.3 Has sufficient consideration been given to the impact of the lead-in times for the large development area of Sherford on the required annual output for the HMA ? Reply: We have no specific comments to make on this matter.
3.4 Have environmental limits arising from matters such as protection from flood risk and the protection of environmental assets been adequately taken into account ? Reply: A single greenfield development of over 800 homes on the edge of Saltash would clearly have environmental impacts for the town, which serves as the gateway into Cornwall. Saltash is bound north and south by AONB designations which also affect Torpoint. The Council supports some development in Saltash, but it must be appropriately scaled. Outside the PUA, Caradon is a predominantly rural district and any significant development is likely to have an impact on the landscape. We re-iterate our point that focusing the entire housing allocation in Liskeard would have a disproportionate effect on the town and it would be advisable to distribute a proportion of the development elsewhere.
3.5 Have infrastructure considerations been adequately taken into account ? Reply: We question the ability of the Tamar Bridge and Tunnel to easily accommodate the commuting traffic that will be generated by an additional 1,000 homes in Saltash. Any housing growth in Saltash should be scaled to improve the self-containment of the town.
3.6 Do the proposals adequately reflect the need to reduce the need to travel, support the use of public transport and minimise congestion ? Reply: With regard to development in Saltash, the Council refer to the points raised in 3.5 (above). With regard to development elsewhere in Caradon, we re-iterate the points raised in paragraph 3.5.1 of the Draft RSS which recognises that many small communities and groups of communities are sustainable “especially where economic development is taking place and employment is available locally and local services, including shops, post offices schools, health centres and meeting places, are provided together with an adequate supply of affordable housing”.
3.7 Does the draft RSS set out adequate guidance on the provision of green infrastructure ?  Reply: We have no specific comments to make on this matter.


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