Consultee ID:1020173 April 2017 Rep Summary TTV29 (7) Broom Park Field Legal, Compliant and Sound Hearing: DHT wish to participate in the examination hearings to further develop our comments, to enable us to respond to the views of other participants and to be able to provide specific technical clarification on points raised Attachments: Aug 2016 Submission Intro / Summary This representation is submitted by the Dartington Hall Trust (DHT). It has been informed by recent and in-depth strategic review of the Trust s purpose and draws on assessments prepared by a multi-disciplinary professional team. In the context of a new strategy which identifies the unique status of the estate as a rural campus delivering activity under a range of new priorities including Destination, Placemaking, Learning and Arts, this representation reflects on-going planning for the future of DHT landholdings integral to which will be on-going engagement and consultation with Parish residents and other key stakeholders. This representation should be read in conjunction with our earlier representations submitted in August 2016 which are attached for reference. DHT are the owners of the land at TTV29 (7) Broom Park and wish to support this allocation and confirm its availability and deliverability within the required time frame. This representation should be read in conjunction with our earlier representation submitted in August 2016 which is attached for reference. The following evidence documents, attached with our representation to TTV29(4) should also be referred to: DHT 750_EDR_00 Ecological Deliverability Appraisal DHT Access Appraisal C161570 DHT Heritage Overview Site Context The Broom Park site comprises 8.59 ha agricultural land gently sloping down from North to South with fairly gentle gradients around most of the site. A small portion of at the South of the site lies within the Bidwell Brook flood zone, and this is to be avoided. The site is largely unconstrained, subject to the usual investigations. The site is within the 4km potential foraging buffer of the South Hams SAC and is away from the identified potential strategic flyways for Greater Horseshoe Bats (GHB). However, the Bidwell Brook may form an attractive dark corridor and potential feeding area for the GHBs. The Council s heritage impacts study highlights a large number of listed buildings close to the site though these are largely shielded by topography and mitigation measures have been identified. The site is well located adjacent to the Dartington settlement with a significant range of services. The Primary School and Bidwell Brook Special Educational Needs DHT Rep TTV29(7) Broom Park Field Page 1 of 2
Consultee ID:1020173 April 2017 school are adjacent to the site. Previous assessments have concluded that the site performs very well supporting sustainable residential-led development. The site is very well located for access to services. The Primary School and special educational needs school are adjacent and daily needs shopping is available within walking distance. There are numerous employment opportunities in the immediate vicinity (Webbers Yard, Shops at Dartington, and offices on the Dartington campus). The KEVICC secondary school is approximately 1.3 miles from the site along the NCN2 or the public footpath and Dartington C of E primary school is adjacent to the site. Totnes is the administrative hub of South Hams and the full range of employment, leisure, medical and community services are available in close proximity to the site, accessible by safe sustainable transport routes and public transport Development Context We have reviewed the representations on the previous JLP consultation. It is clear that many local residents object to greenfield development with the loss of Broom Park field a particular cause for concern locally. However, the allocation for 80 homes is low in relation to the sites capacity and reflects DHT s desire to find an appropriate balance of uses including between development, accessible open space, landscaping and green infrastructure. Broom Park field sits is bounded by a major A road to the East, village development to the South and clusters of buildings to the West and North. Given the JLP strategic objective of reinforcing the sustainable villages and not promoting development in more remote areas, development there is potential for future development on this site in preference to sites further away from local services or in more sensitive areas or areas subject to statutory designations. Housing Supply Contribution Broom Park is allocated for 80 dwellings and the Councils housing trajectory identifies home completions on this site to commence in 2026/27 and then deliver 30 dwellings in each of the next two years. This quantum and rate of development is easily achievable. DHT support the delivery later in the plan period as this will provide an opportunity to first focus on heritage-led regeneration projects on Dartington Estate and to continue to work with the local community on placemaking issues. As Council officers monitor progress on plan delivery the potential development in this area can be reviewed in light of changing demand. Finally, DHT wish to note that part of our work is to explore innovative, community-responsive placemaking and home building models in part as an alternative to the volume housebuilder model of delivery. We hope that as work progresses with other estate projects including Dartington Lane (TTV28(1)) and onestate projects we can find ways of helping meet local housing demand which will gain public support. DHT Rep TTV29(7) Broom Park Field Page 2 of 2
Consultation Response by The Dartington Hall Trust Site Reference: SH_14_01_08/13
Contents Introduction 1 Site Description 2 Development Proposal and Context 3 Site Technical Assessment 4 Site Suitability Assessment 5 Planning Policy Review 7 Summary 11
Introduction This document provides information related to the potential use of land at Broom Park, Dartington for residential development. It has been assembled by The Dartington Hall Trust (DHT) drawing on assessments prepared by a multi-disciplinary professional team in response to the consultation on the emerging Plymouth and South West Devon Joint Local Plan. It specifically addresses the question of suitability and deliverability of the site in terms of its ability to meet identified housing needs in the plan area and the proposed allocation of land in Totnes, including sites in Dartington and Berry Pomeroy. It provides a systematic and thorough analysis to ensure that the Joint Local Plan is founded on a sound evidence base. The work undertaken and reflected in this document supports the local planning authorities inclusion of the Broom Park field as a potential housing site for allocation in the Joint Local Plan. Its key findings are: The Broom Park site comprises 8.59 ha of land in a highly sustainable location. The site is available and is being promoted by DHT for the development of around 60 homes. This reflects the results of studies undertaken and the potential of other sites owned by DHT. The site is not constrained by technical issues including access, landscape, ecology, or servicing and is considered viable. The site is compliant with National Planning Policy Guidance. The site is deliverable within a phased programme to meet market demand. 1
Site Description Figure 1: Site Photograph Broom Park field comprises 8.73 ha of agricultural land bounded to the east by the A384, Bidwell Brook to the south and west and adjacent to Broom Park, a 1930s residential cluster development constructed by DHT on the northern boundary and the access lane leading from St Mary s Church to the hamlet of Week. The land adjoins a 2 ha site to the south west on which the new 360 pupil Dartington Primary School was constructed in 2009, which is now being rebuilt. The land comprises a gently sloping large field under tenancy, contained mainly by traditional planted hedgerows and stock-proof fences to various boundaries. The original hedgerows have been removed over the years as the land has been used for arable production as part of DHT tenant farming activities. 2
Development Proposal and Context The Broom Park site is available for development and is being promoted by DHT as a site for around 60 homes. Part of site was submitted in the 2009 SHLAA as site SH_14_01_08 (referred to as Bidwell ). The site was assessed for suitability through the Site Allocations Sustainability Threshold Assessment in April 2010 as site DN3. This assessment concluded that the site performed very well in supporting sustainable development with the only caution being a small area on the southern edge, which occupies the Bidwell Brook flood zone. The site was not allocated in the Rural Areas DPD in 2011 as there was sufficient land to meet the then identified needs of Dartington through development of Webbers Yard and Sawmills East and Ashburton Road sites; the majority of which are now close to completion. There are no planning applications for the site identified on South Hams District Council s web site. 3
Site Technical Assessment Access The site is very well located for access to Dartington, Totnes and the wider road network. A number of footways serve the parish and provide connection to Totnes. There is a safe and direct link to the cycle route NCN2 which provides access to Totnes town and station via a designated cycle path. An access appraisal tested the trip generation from this site in combination with other potential and proposed developments in the area and it was demonstrated that the road network will be able to accommodate the vehicle movements arising. The access appraisal has demonstrated that there are no material highway or transportation matters that would preclude the Local Planning Authority from approving any planning application with regard to highways issues. Utilities An infrastructure report prepared by Jubb Consulting Engineers confirms that site water, drainage and energy services can be achieved without abnormal cost. Delivery The results of the technical assessment work confirms that there are no issues that would impede delivery and viability of the site and its ability to contribute to the district s identified housing requirements. 4
Site Suitability Assessment Location The site is very well located for access to services. The Primary School is adjacent and daily needs shopping is available nearby. There are numerous employment opportunities in the immediate vicinity (Webbers Yard, Shops at Dartington, and offices on the Dartington campus). The KEVICC secondary school is approximately 1.3 miles from the site along the NCN2 or the public footpath and Dartington C of E primary school is adjacent to the site. Totnes is the administrative hub of South Hams and the full range of employment, leisure, medical and community services are available in close proximity to the site, accessible by safe sustainable transport routes and public transport. Flood Risk The site is predominately outside Flood Zones 2 and 3 with the exception of the southern boundary along Bidwell Brook. There is no development proposed in this area, and on site drainage and attenuation can be easily achieved at the density proposed. Ecology The site falls wholly within the potential foraging area for Greater Horseshoe Bats from the South Hams Special Areas of Conservation (SAC). The design of any development in the area should reinforce potential flyways through landscaping and will be subject to appropriate mitigation for example conditions on external lighting. An Ecology overview report has been produced by EAD which outlines a scheme of detailed assessments to support mitigation considerations in detailed scheme design including: Extended Phase 1 Habitat Survey. Ecological Impact Assessment (EcIA). Bat Activity Survey (cf South Hams SAC Planning Guidelines). Possible other surveys if indicated (reptiles, amphibians, breeding birds, dormice, invertebrates). Based on the desk-based environmental assessment, no overriding ecological constraints to development are identified. Appropriate on site mitigation and enhancement will be required for any notable species. 5
Heritage Impacts A detailed assessment of heritage impacts will only be possible when the sites for development have been defined firmly and their nature and layout have been planned. It is likely that impacts on significance, if any, will result from changes to the settings of heritage assets in the vicinity. Two designated heritage assets are situated close to Broom Park: at its nearest point, the site is about 100 m from the Grade II* listed St Mary s Church and parts of the site are visible from the church yard; Church Cottage located immediately to the North of St Mary s is also Grade II listed. Historic England s Historic Environment Good Practice Advice in Planning: 2 observes: Development proposals that affect the historic environment are much more likely to gain the necessary permissions and create successful places if they are designed with the knowledge and understanding of the significance of the heritage assets they may affect. The first step for all applicants is to understand the significance of any affected heritage asset and, if relevant, the contribution of its setting to its significance. A detailed assessment of the settings of the two designated heritage assets close to Broom Park is currently being prepared to accord with Step 2 of guidance in paragraph 12 of Historic England s Historic Environment Good Practice Advice in Planning: 3. Early indications are that there is good scope at Broom Park to provide new development with acceptable levels of impact upon the significance of both heritage assets. Promotion of a modest number of dwellings on this site will provide opportunities to introduce landscaping and green infrastructure, which will ensure development does not impact the setting of the two heritage assets in the vicinity. Finally, development is likely to require archaeological investigation. 6
Planning Policy Review The consultation document issued on the South West Devon Joint Local Plan indicates that outside of Plymouth planning policy sets out to focus development on the market towns where employment, transport and community services are available. The Broom Park site represents an opportunity to deliver sustainable development which supports the sustainability objectives promoted by the council(s). DHT shares with the council the overarching aim to produce a sound local plan in order to guide development in a sustainable way over the coming years. This planning assessment includes reference to both policy compliance for proposed development and plan-making compliance for the forthcoming presubmission Draft Local Plan. Under Section 38(6) of the Planning and Compulsory Purchase Act 2004 the local development plan provides the primary guidance in consideration of planning proposals. However, this consultation is intended to inform the content of the new Joint Local Plan for the area so initial consideration of appropriateness of allocations and policies is based on the National Planning Policy Framework (NPPF) and National Planning Practice Guidance (NPPG). 7
National Policy Planning Balance The allocation of land for development on this site presents an opportunity to satisfy the NPPF objective to significantly boost the supply of housing, and the requirement for Local Planning Authorities to make plans and to determine planning applications based on the presumption in favour of sustainable development. Specifically, development is supported by the following: NPPF 7 notes that there are three dimensions to planning; economic, social and environmental. This proposal provides an opportunity to deliver housing in a well-located area, which avoids more sensitive environments and landscapes. This also provides an opportunity to support the charitable aims of DHT and to make provision for housing for significant numbers of people employed locally. NPPF 17 identifies core principles including to proactively drive and support sustainable economic development to deliver the homes, infrastructure and thriving local places that the country needs. NPPF 63 states that in determining applications, great weight should be given to outstanding or innovative designs, which help raise the standard of design more generally in the area. DHT has fully committed to enabling development that introduces more locally-responsive approaches to design and construction and this development presents a unique opportunity to fulfil this objective. NPPF 118 notes that local planning authorities should aim to conserve and enhance biodiversity through avoidance, mitigation and enhancement. Supporting development in this site, bounded on two sides by the existing built up area, helps achieve the required housing needs for the district without incursion into areas of undisturbed or sensitive ecology. NPPF 128 and 129 highlight the need to assess historic assets and potential impacts of any proposals. Discussions with architects and heritage experts confirms that plans within this area can be designed to be compatible with the listed buildings nearby and to add to the legibility and sense of arrival for the historic Estate. NPPF 14 (and 197) highlights the presumption in favour of sustainable development. For decisiontaking this means: In the absence of a robust plan the council should grant permission unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits... or specific policies in this Framework indicate development should be restricted. Based on this appraisal it is clear that this site accords with the requirements of the NPPF and the principle of development on this site would be supported by national policy. 8
National Policy Plan Soundness The NPPF sets out a number of requirements for plan making. NPPF 182 summarises the tests of soundness as being: positively prepared, justified, effective and consistent with national policy. The inclusion of Broom Park field helps meet these tests with particular support for the following: NPPF 15 highlights that policies in Local Plans should also follow the approach of the presumption in favour of sustainable development. NPPF 35 requires that plans should ensure development is located where it can exploit opportunities for the use of sustainable transport modes for the movement of goods or people etc. Broom Park provides ready access to public footpaths, NCN2 cycleway, public transport, and the strategic rail network. NPPF 37 seeks to ensure planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. Many of these facilities are available in close proximity to the site. NPPF 47 To boost significantly the supply of housing local plans must identify developable and deliverable sites to meet their objectively assessed needs; this test of soundness is one of the most carefully examined. This site can contribute to meeting the council s identified need including delivery within years one to five. NPPF 55 requires that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. The council recognised that the market towns provide the most sustainable approach to meeting housing needs in the district. Broom Park will help meet the housing needs of Totnes and immediately surrounding parishes. NPPF 173 notes the need for plans to be deliverable including considerations of viability. Allocating this site provides a more diverse basis for delivery. In practice, much of the discussion during the examination of the Joint Local Plan will hinge on deliverable housing land supply, namely NPPF 47 requirement that the council: meets the full, objectively assessed needs for market and affordable housing in the housing market area and identify a supply of specific deliverable sites sufficient to provide five years worth of housing and developable sites for years 6-10 and, where possible, for years 11-15. This site forms one of DHT s potential development sites, which is clearly deliverable, is located in a sustainable location and can contribute to meeting the District s housing need whilst avoiding more sensitive and less sustainable sites. At present DHT wishes to focus its efforts on the Estate Framework developments on the Dartington campus. To that end it is recommended that the site be considered part of the overall land supply rather than the specific Five Year Housing Land Supply calculation. 9
Local Policy Analysis South Hams District Council is in the process of updating its Local Development Framework which was put in place in 2006. Site allocations which flowed from the Core Strategy in Totnes and Dartington have largely been taken up or are in the process of progressing. The Joint Local Plan is required to provide for new homes and employment to 2034 which necessarily requires additional sites to be brought forward. Much of this is being focused on Plymouth and the urban fringe. The market towns and area centres of South Hams and West Devon remain the focus of development needs. With limited land now available within the parish boundaries of Totnes, local policy is necessarily looking to the adjoining parishes of Dartington and Berry Pomeroy to meet the objectively assessed needs in this part of the South Hams. South Hams District Council assessed this site in April 2010 when considering requirements for the Rural Site Allocations DPD. That assessment found the site to be highly sustainable and deliverable. However, at that time, the village housing requirement could be met by allocations at Ashburton Road and Sawmills East/Webbers Yard and both of these allocations are scheduled for completion in the coming year. Neighbourhood Planning Dartington Parish is a designated Neighbourhood Plan area. DHT has been engaging in the Neighbourhood Plan process and hopes to align the Trust s development opportunities with the objectives of the local community. This includes development management policies as well as meeting overall requirements. DHT is committed to being responsive to the needs of the local and wider community and an allocation of the Broom Park field site makes provision for an amount of housing which is significantly below the capacity of the site. This will allow development to be brought forward in a way that responds to the community s desire for housing to be developed in a way which maintains the predominantly rural character of Dartington and the aspiration for design quality likely to be reflected in the policies of the Neighbourhood Plan. In looking forward for the next twenty years, the council has recognised that Totnes and its adjoining settlements form an integrated community and that Totnes is tightly constrained and built out to its boundary. As such the council will have to consider the relative performance of various sites in the area. It is assumed that when judged against most measures of sustainability this site will be identified as a good location for development. 10
Summary Analysis of policy makes it clear that allocation for development is appropriate and the principle of development on this site should be acceptable. Review of technical and design issues make it clear that the scheme is deliverable. On the basis of current policy, and in light of the lack of site constraints, this site could begin to deliver in the five year time frame. It will be for the council to determine the specific allocations and wording. However, in light of the unconstrained nature of the site, we would recommend that this allocation be made in the form of around 60 dwellings to provide certainty and a potential buffer in land supply. Proposed Delivery Programme Years one to twenty available for release in a phased programme as required. Consultants The appraisals have been prepared by the Dartington Hall Trust with support and advice from specialist consultants including: Planning advice Prof Chris Balch, Professor of Planning, Plymouth University Planning advice Mary Elkington, Figura Planning Masterplanning and Estate Framework Studio Partington Heritage Stephen Bond, Heritage Places Transport Assessment Hydrock Surface and foul drainage infrastructure Jubb Consulting Engineers Ecology EAD Ecology 11
Figure 2: Site Location Plan Scale 1:5000 @ A3 St Mary s Church Schumacher College/ Old Postern Old Parsonage Farm Upper Drive A384 Development Area Primary School Bidwell Brook 8.73 ha Foxhole Car Park Bidwell Brook Middle Drive Shops at Dartington Cott Road A385 A385 0 50 100 150 200 M 12
Figure 3: Site Constraints Plan Scale 1:2500 @ A3 Key to Site Constraints Plan Grade II* listed St Mary s Church Listed buildings Recreational area Hazel Park Upper Drive/ main visitor entrance to Dartington Hall Flood Map for Planning zone 3 1932 houses for estate workers 1:29 gradient 1:18 Flood Map for Planning zone 2 Steep gradient, arrow points in direction of fall 1:11 gradient 1:11 gradient Primary School Steep slope 1:4 gradient Area within flood zone Bidwell Brook 0 25 50 75 100 M 1:2 gradient 13