SHS Representation of 15 June 2010 on SHDC Rural Areas Site Allocations DPD
From: "Lee Bray"
Date: 22 February 2010 12:09:21 GMT
To: "John Chalmers" Cc: "Robin Hogg", "Paul Coulson", "Cllr Carter", "Cllr R. Tucker", "Cllr Gilbert", "Cllr Howarth", "Julian Brazil
DCC" Subject: RE: Housing Site Allocations
Dear Mr Chalmers,
Thank you for your further comments.
I will ensure that they are, together with your earlier ones, treated as comments of the South Hams Society on the plans.
Yours sincerely,
Lee Bray
Head of Community Regeneration
South Hams District Council
From: John Chalmers [mailto:john@croftroad.eclipse.co.uk]
To: Lee Bray
Cc: Robin Hogg; Paul Coulson; Cllr Carter; Cllr R. Tucker; Cllr Gilbert; Cllr Howarth; Julian Brazil DCC
Subject: Housing Site Allocations
Dear Mr Bray
Thank you for your reply to my letter to Mr Incoll. I hope you are now recovered. I must accept that you aim to find the right solution in each place but to convince the residents of the South Hams you must be seen to be responding to their rightful concerns about their environment. If the forward planning proposals are taken unchanged to publication stage and beyond the communities will consider that local democracy has not worked and further action must be taken.
I will reply briefly to the other points you raise.
As far as the SHLAA is concerned Robin Hogg's letters to Mr Incoll and Mr Swiss (both of which I believe remain unacknowledged as well as unanswered) suggests some deficiencies notably in the lack of attention to small brown-field sites within development boundaries which can make a significant contribution to targets. Whether consultation went far enough is best judged by results and we know that for most of the population of South Hams your site allocations came as a surprise - usually unpleasant. Graham Swiss and James Doxford should be able to vouch for this from their experiences at Salcombe, Modbury and West Alvington.
As for the STAs they are still marked "draft" and contain conspicuous errors, for example, how is it that site 3 in Salcombe is marked with the same biodiversity grade as all the other sites in Salcombe (even including the car park) despite being a County Wildlife Site and a habitat for two protected species which none of the other sites are? We understand this arose because the GIS used by the planners mistakenly did not contain the overlay with this information. There are many other such defects in all the STAs we have seen. So although we agree that STA might be a useful tool, it is only so if completed correctly.
As for the Prince's Foundation it was clear to the attendees of the EbD workshops that the recommendations that came in the report paid very little attention to the views expressed by the residents. For example the site chosen in Malborough was against the clearly expressed wishes not only of the representatives of the village but everyone else in the workshop. The planners overrode local knowledge with their ideas of Place-Making, etc.
Again there is no information on the Strategic Infrastructure Delivery yet it is often crucial to the choice of a site. For example the site chosen in Salcombe, Modbury and W Alvington all generate access and traffic problems which can only be solved by highway upgrades on a large scale - not to speak of the demolition of buildings. It has also become apparent that the AONB has not been consulted for their views before the sites were chosen.
In West Alvington what ever the opinion of a individual Councillor, the Parish Council and residents did agree on a site which was available at no cost and informed you of it. Similarly the secretary of the Modbury Town Council confirmed that the Council wrote to SHDC last year asking for the use of infill sites but did not even get an acknowledgement.
It is my belief that the forward planning process has been conducted too hastily to provide proper consultation and the attention to detail that small sites require. So to meet the timescale self imposed by the Council large green field sites were chosen as the easiest option in the hope that large contractors can be attracted to develop them and in the process provide a percentage of affordable housing.
But this approach is very damaging both to the country side and to the towns and villages in the South Hams. All agree that we need more affordable housing as well as employment sites but we do not need more open market housing which is likely to end up as second homes. The affordable housing obtained by the development of a large green-field site by a large contractor is now down to 25% of the total houses built - Lee Mill and Sherford demonstrate this and no better prediction can be made for the future.
So are we to build four times the number of houses required to get the affordable houses specified in the Core Strategy? That means 800 in Kingsbridge and Dartmouth and 200 in Local Centres such as Salcombe and Modbury. Are our towns and villages to become victims of the desire of developers to make a profit? Where will it stop?
We must find another strategy and it must be the careful selection of smaller sites, the use of all available brown-field sites and those within the town boundary. Coming to the community with open minds will help you find them just as W Alvington and Modbury did. Robin Hogg's idea of village exception sites will help. Small sites developed by local builders within the existing infrastructure will contribute. Housing trusts such the Guinness Trust can be approached. The Hastoe Housing Association who are applying for permission for 17 affordable houses at Malborough will save that village from large numbers of unwanted open market houses.
These are not grand visions but they are a robust and flexible method of achieving results so that the character of villages and towns that have grown up through the centuries is respected.
Lastly you asked if I wished my letter to be treated as a comment on the consultation and the answer is yes, I do and I would also like this letter to be treated similarly. You also asked whether it represents the views of the South Hams Society and again the answer is yes - the committee asked me to write it and I would not have signed it as chairman if it had been otherwise.
Yours sincerely
John Chalmers
Chairman
South Hams Society
On 17 Feb 2010, at 14:04, Lee Bray wrote:
Dear Mr Chalmers,
Further to our Chief Executive's reply to you last week (and with my apologies for the delay in my replying further, swine flu having intervened!), may I add my thanks to his for your input. I understand the strength of your feelings in this matter. I hope that you would, however, agree that the Council was right to go beyond the basic steps required by government in LDF guidance.
The 2 month consultation last May/June went beyond those requirements, as did the STA process (a significant step beyond the government's SHLAA requirements - please forgive the acronyms - I think you are familiar with them). Bringing in the Prince's Foundation added yet a further design dimension and enabled additional community engagement. Most recently, we have reconsulted in several communities where we felt issues remained - Salcombe being one of these. Our aim truly is to find the right solution in each place.
Delivering affordable homes is always difficult, and that is particularly so in the present economic climate. However, the plans we are preparing are intended to carry us forward for many years and we are aiming for a sound and robust foundation which will endure and serve us all well in spite of social, economic and political change.
For the record, since you refer to other places - In West Alvington the site for 50 houses was first raised by a WA parish councillor at the Kingsbridge EbD workshop. It was not a site initially promoted by the District Council. In Modbury, the alternatives put forward were variously acknowledged and have been investigated. We have carried out further engagement in both these places (and others) as we seek to discern the best way forward in each case.
You also refer to timescales, infrastructure provision and biodiversity requirements. In each case we have again gone beyond the basic government requirement.
I am not seeking to change your mind as to whether or not such things are important. On the contrary, the Council also believes that they are, and we hope that the approach we have taken will enable much more evidence to be gathered than would otherwise have been possible. In due course all of this will, of course, be put before an inspector. We hope that the range of evidence available will help him (or her) to come to sound conclusions.
Finally, and solely for the purpose of clarification, may I ask whether you wish your letter of 9th February to be treated as a comment on the recent consultation and, if so, whether it represents the view of the South Hams Society or your own views as Society Chairman. We shall be pleased to treat it as a comment either way, but wish to be clear of your intent since the letter is addressed to the Chief Executive.
Thank you again.
Yours sincerely,
Lee Bray
Head of Community Regeneration
South Hams District Council
01803 861292
lee.bray@southhams.gov.uk
P.S. I am copying this reply to the same District Councillors as those you had copied your original letter to. I do not have email addresses to hand for Gary Streeter, Anthony Steen or Robin Hogg.
From: David Incoll
To: 'John Chalmers'
Cc: Lee Bray
Subject: RE: Housing Site Allocations
Dear Mr Chalmers
thank you for your letter.
Clearly our actions have to address a whole range of issues and timescales, including the statutory duties imposed on us, the very real need to address the issue of affordable housing in a way that is going to deliver results ,public consultation( in respect of which we went far beyond the normal rules and engagedd the Prince's Foundation Trust ) and a further range of material considerations.
I am copying this to Lee Bray,our Head of Service, to provide a full response. There will ,I regret be some delay, as he is currently off sick with Swine Flu
Yours sincerely
David Incoll
Letter of 9/2/10 to SHDC on forward plans
Campaign to oppose development of harbour-side fields in Salcombe:
Headline critique of the site options