Strategic planning consultation response
The local and wider South Hams community have reacted to the loss of woodland by strenuously opposing the development plans for the cleared hillside at Seymour Drive, Dartmouth. So it is encouraging to see this consultation response to the Planning Case Officer from Phil Baker MA(Hons) MRTPI, Planning Officer, Joint Local Plan Team For South Hams District Council, West Devon Borough Council & Plymouth City Council, Follaton House.
To: Gemma Bristow
Subject: 0852/19/FUL land north of Seymour Drive
In response to the above application I would like to offer the following comments: The adopted Plymouth & South West Devon Joint Local Plan (JLP) identifies and allocates sufficient housing sites to meet the housing needs across the plan area until 2034. A 5 year supply of housing sites can currently be demonstrated across the plan area, and as such there is no obligation for the LPA to give planning permissions to proposals on un-allocated sites and that will not deliver a sustainable form of development.
This piece of land provides an ongoing function associated with the previous development of the adjoining residential area, and the use of this land in providing visual screening through woodland planting forms a part of planning permission 15/1790/98/F, and is required to be maintained as such in perpetuity.
Clearly the loss of this function would result in environmental harm, and as such the three tenets of sustainable development cannot be mutually secured. The limited social and economic benefits of this proposal are not considered to outweigh the environmental harm, and as such the requirements of NPPF paragraph 8 cannot be met. Although adjacent to the edge of settlement, it is required by planning condition that this field contributes to softening the edge of the built form of Seymour Drive and Raleigh Close.
The level of landscape mitigation offered by this field when viewed from the north and west is such that it should already be considered as an integral component of the edge of settlement, and any change that reduces the visual mitigation provided by this field would be considered detrimental to local character.
The application form describes the land as ‘derelict’. The definition of derelict indicates ‘poor condition as a result of disuse and neglect’. The planning statement describes the land as ‘disused’, the definition of which is ‘no longer being used’. However, neither of these descriptions accurately reflects the ongoing use of the site to provide visual screening of the adjacent built form.
The Design and Access Statement describes the site as ‘brownfield’. The National Planning Policy Framework definition requires that for land to be considered as brownfield or Previously Developed Land it should be, either existing or previously, occupied by a permanent structure and any associated fixed surface infrastructure. Considering the extent of vegetation on the site, and the value of the land for its planted woodland (the removal of which is subject to comment from the LPA Tree Officer), it is not considered to be either brownfield or PDL.
Notwithstanding that the principle of development is not accepted, it is also considered that the proposal does not accord with policy DEV8 of the JLP. DEV8 seeks to diversify the housing mix across the plan area in terms of the size, type and tenure of the housing stock. This proposal contains no diversity whatsoever, comprising as it does nine identical buildings. The planning statement claims that the proposed dwellings would meet the ‘local housing needs of Dartmouth’ but with no details of how this proposal would do so, as in planning terms they would be unrestricted open market dwellings.
The Planning Statement seems to suggest that these nine identical units ‘could provide opportunities for local self-build’. Nowhere in the application form is there any indication that these plots will be available for self-build, local or otherwise. It is also considered highly unlikely that a series of plots will be built by different self-builders to exactly the same design and specification – part of the benefit of self-build is the diversity of design and innovation that individual builders wish to invest in their own building, and there is no room for individual expression in this proposal.
Kind regards Phil Phil Baker MA(Hons) MRTPI | Planning Officer | Joint Local Plan Team For South Hams District Council, West Devon Borough Council & Plymouth City Council Follaton House | Plymouth Road | Totnes | TQ9 5NE
Seymour drive ‘before’ the trees were felled. They provided “visual screening through woodland planting forms a part of planning permission 15/1790/98/F, and is required to be maintained as such in perpetuity.”