A Joint Community Response

to the Totnes Development Plan Document

Totnes: Planning for the Future

co-ordinated by

Totnes Town Council

and the Totnes and District Community Strategy Group

JUNE 2010

This document provides a collective community response to the South Hams District Council (SHDC) Site Allocation Development Plan Document for Totnes, dated April 2010, and has been co-ordinated by Totnes Town Council and the Totnes and District Community Strategy Group. It is supported by the community representatives present at the EbD day (the EbD Consultation Group), and reflects the views of Councillors, individuals and the many local groups who have responded to the DPD this time.

It is becoming clear that the government’s decision to abolish the RSS targets will require a review of all the policies and targets applying to this DPD, and the establishment of new verifiable targets. In principle, we support the need for affordable housing, but wish to see fewer market houses. We are thus likely to oppose any scheme where the amount of affordable housing falls well below the SHDC target of 55%. However this response concentrates on responding to the Totnes DPD as it is currently presented.

The community groups listed in appendix A provisionally agree with six of the nine new proposals, subject to important conditions, whilst rejecting T5, T6, T8 and one part of T3 as unsound. We are pleased that some issues raised previously have been addressed in these latest plans e.g. the Vision for Totnes now reflects many of our collective priorities. In addition to addressing the need for employment development and affordable housing, we know we must address major infrastructure and sustainability problems. We must preserve those distinctive qualities which make Totnes special, and underpin the town’s economic and social wellbeing, as well as making it an attractive place in which to live or visit.

We remain concerned about

• the lack of a long term strategic master plan for the town to provide an appropriate context in which all development options and infrastructure issues can be assessed;
• infrastructure provision, and in particular, the urgent need for an effective transport strategy for the town;
• the need to implement sustainable and resilient development strategies which address the challenges of substantial growth and peak oil/climate change; and
• issues of transparency and openness.

There is considerable cynicism about transparency of purpose in the DPD, with unease that even higher levels of development than the DPD outlines are being considered by SHDC. We have entered in good faith into a process to achieve the optimum levels of development for Totnes, balancing local people’s priorities and concerns with the demands of developers and economic realities. However we are likely to oppose vigorously any major variation from the DPD proposals which increases significantly the numbers of dwellings on proposed sites, or puts forward other sites which do not contribute to the DPD targets, or leads to the overall level of development identified in the plan being exceeded.

There has been a high level of community consensus during the 2.5 years in which the DPD has been discussed. We hope our proposals can be accepted as well considered, realistic and widely supported. Totnes is a nationally important historical town in the vanguard of communities seeking ways to achieve long term sustainability and resilience. We seek to engage meaningfully with South Hams District Council to achieve a Local Development Framework which supports these aspirations.

Tony Whitty, Mayor    for Totnes Town Council and the EbD Consultation Group

Jill Tomalin,              Chair for the Totnes and District Community Strategy Group and the Housing and Built  Environment Forum

Contents

Click on the red headings to read

1.0    Summary of Key Points

2.0    Our Approach

3.0    Context
3.1    The first DPD Consultation, September/October 2007
3.2    The Community Focus Group, Spring 2008
3.3    The Prince’s Foundation
3.4    The EbD Day June 2009
3.5    The Prince’s Foundation Report

4.0    Community Priorities and Areas of Concern

5.0    The Planning Process and Underlying Assumptions

6.0    Individual Site Responses

Sites Considered Sound
T1 Baltic Wharf
T2 KEVICC
T3 Totnes Central Area (Grove School and Market Square)
T4 Dairy Crest
T7 Riverside
T9 Bourton Lane

Sites Considered Unsound as Currently Proposed
T3 Central Area (Southern Area)
T8 Borough Park

Sites Considered Intrinsically Unsound
T5 Land at Dartington Lane
T6 Land at Ashburton Road

Alternative Sites to be Considered
Follaton Farm
Follaton Bungalows
Follaton House and Broomborough
Great Court Farm and Blackpost Lane
Babbage Road Industrial Estate

7.0    Other Issues Which Render the DPD Unsound
7.1    Infrastructure Plans
7.2    Flood Risks and the Impact of Climate Change
7.3    Key Omissions from the Plan
7.4    Community Involvement

8.0    Afterword

Appendices

A) List of Organisations which have contributed to this Response

B) Some Indicative Statistics

1.0 Summary of Key Points

1) This document represents the views of Totnes Town Council, and 21 community groups who between them represent hundreds of people (see Appendix A). It also takes into account:

• the community responses to a previous draft DPD in 2007 (Appendix C);
• the recommendations of the 2008 Community Focus Group (Appendix D);
• the views expressed at the EbD day, and by Totnes representatives thereafter; and
• the concerns expressed at the public meeting on 27th May, attended by more than 100 people, and in written responses to the Town Council exhibition.

There is a remarkable consistency of view across all these groups.

2) Sections 2 and 3 detail our approach and the background to this report, while Section 4 indicates our priorities and concerns. In particular, we call for

• the development of a long term, strategic master plan to provide a robust context in which all future planning decisions can be made (page 11). This is particularly key for the strategically important area running from KEVICC, via the Dairy Crest site and the railway, to Borough Park and Babbage Road, and for the whole of the central area; to “future proof” any future necessary infrastructure developments; and in order to manage developing flood risks across the town (see also p14);
• the creation of an integrated traffic management strategy for Totnes (p12);
• the highest possible levels of genuinely affordable housing with the option to abandon development if the level drops too low; priority to be given to local people; and for innovative approaches to be developed to deliver this pressing need (p13); .

3) Section 5 assesses the planning process. Key points are:

• Uncertainty over the RSS and setting of housing targets (p17) – we recognise the need for affordable homes, but dislike the current dependence on market housing to achieve this. Growth must be at a level our infrastructure can reasonably support. Ideally, we seek lower overall housing targets while sustaining the numbers of affordable homes. We are thus likely to oppose any scheme where the amount of affordable housing falls significantly below the SHDC target of 55%.
• Transparency of Housing Targets (p17) - we have long supported development which leads to higher levels of affordable housing and new employment opportunities, but will oppose any significant level of additional development which leads to the DPD total being exceeded. We propose that all targets currently quoted as “about…” should be clearly understood to mean in a range plus or minus 20% at most. In the event of a larger number of homes being approved on any one site, we call for a corresponding reduction in the number of homes built elsewhere. Similarly, any large scale exception or departure site approved by SHDC during the plan period should count towards the DPD targets

4) Section 6 looks at the sites proposed in the DPD. These sites are considered sound for development, albeit often with important conditions attached:
T1, Baltic Wharf
T2, KEVICC
T3, Central Area (Market Square and Grove School)
T4, Dairy Crest
T7, Riverside, and
T9, Bourton Lane

We note that Devon County Council has recently announced alternative sites for the library and the youth centre. If these are confirmed, any new proposals for the Grove School site and the Market Square will need to be consulted upon once more. We consider that approval for any proposals for the Market Square and for Borough Park must be design dependent and will require extensive community involvement in their development. We will oppose any development which compromises the space available for the market in the Market Square or the open space in Borough Park. We call for the housing targets on these sites to be removed to avoid any pressure to achieve the stipulated number in future.

5) Two sites are considered unsound in their current form:
T3, Central Area (Southern Area)
T8, Borough Park

Proposals for the Southern Area are not justified, being inadequately considered and lacking consultation.

6) Two sites are considered intrinsically unsound:
T5, Land at Dartington Lane and
T6, Land at Ashburton Road

These are unjustified as there are better alternative sites available at Follaton Farm, Follaton Bungalows, Follaton House and Broomborough. Sites in Bridgetown at Great Court Farm and Blackpost Lane are also mooted as alternatives (pp36 – 37). An outline planning application for Follaton Farm is imminent, having been under discussion for four years, and it is not acceptable that this development should fall outside the DPD.

7) Aspects of infrastructure planning have not been adequately justified. The current lack of effective transport planning should be considered unsound until a rigorous evidence base is established, consultation undertaken, and greater clarity about transport strategies achieved (p38). Similarly, omissions in the evidence base and an assessment of the impact of future flood risks across the town need to be addressed (p40).

8) We seek clarification on where development policies not contained in this site allocation only DPD will be addressed as part of the LDF, and to an agreed timetable. These include the designation of a town centre zone, a primary shopping area and Core Zone with identified frontage policies, and the updating of policy areas (p41). The current lack of clarity will lead to inconsistent and unclear planning decisions. Additionally, it is necessary to reconfirm the town’s development boundary which has not been updated since 1996. Without these elements, the whole LDF must be considered incomplete and unsound.

9) Measures must be put in place so that the Vision for Totnes can be attained (p41). To date, SHDC has failed to adopt sufficiently stringent policies to support the Vision. We now need a separate mechanism/development of policies for Totnes if our Vision is to have meaning – without such a mechanism, the Vision contained in the DPD is rendered unsound by being ineffective, as there are no means by which the desired outcomes can be achieved. The plan can only be made sound if such a mechanism is devised.

10) While SHDC’s Statement of Community Involvement (SCI) was approved by a Government Inspector, we note that the examination process is carried out on the following basis: "The presumption will be that the Statement of Community Involvement is sound unless it is shown to be otherwise as a result of evidence considered at the examination".

We remain concerned that very little is done to promote, encourage, or provide genuine and meaningful engagement in the planning process by local people and community groups, and investigation would suggest that SHDC is not achieving the practices now operated by more progressive local authorities. Paragraph 7.4.4 (p42) cites examples of poor community engagement in the development of this DPD, particularly the SHLAA, the STA and the SID, and there is widespread dissatisfaction at the level of community participation in the process of evidence gathering and analysis. There are many among us who will acknowledge that, for this reason alone, it is dubious whether any part of the DPD for the South Hams can be considered sound, in that the proposals it has put forward have not been justified with sustained community engagement and participation in the development of the DPD, or good quality and adequate amounts of consultation.

11). We conclude by highlighting the inter-relatedness of key themes and the tensions which exist between them (Afterword, p44) - affordable housing and good quality jobs, over reliance on unlimited levels of new market housing, and the desire for economic, social and environmental resilience. Current trends are neither healthy nor sustainable, and there is a crucial need to find more innovative solutions, with supporting policies from local and national government, to enable this.

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2.0 Our Approach

2.1 The Need for Effective Consultation
We are all concerned about the limited amount of community involvement in drawing up the DPD, and the limited publicity being given now to the proposals across the South Hams to ensure meaningful consultation and feedback.

However, we have had a number of significant advantages over neighbouring towns:

• the 2007 DPD consultation had already brought the issues to public attention;
• community networks such as the Housing and Built Environment Forum, which was formed in response to the earlier consultation, have enabled local groups to debate the outline plans as soon as they were agreed in December 2009;
• unlike other local towns, a substantial group of more than 30 community representatives participated in the EbD day in June 2009. This group provided a strong starting point for this round of our own consultation process.

2.2 Our Consultation Process

• The Housing and Built Environment Forum of the Strategy Group met in January to discuss the outline proposals agreed by Councillors at their December meeting:
   
• The EbD Consultation Group met in February 2010 and confirmed their initial responses to the DPD proposals.Totnes Town Council set up an exhibition outlining the DPD proposals, which ran in the Guildhall throughout the consultation period.The Town Council wrote to community groups, drawing their attention to the DPD, and encouraging groups to respond to SHDC (and the Town Council).The Town Council held a public meeting in the Civic Hall on 27th May, which was attended by more than 100 people. Their views are reflected in this report.
   
• The proposals were debated by Totnes Town Council on four separate occasions, culminating in a meeting on 21st June.
• The Traffic and Transport Forum of the Strategy Group provided inputs into this response, specifically looking at transport issues.
   
• An early draft of this document was developed with the Housing and Built Environment Forum, which drew on the previous DPD consultation, the Focus Group and EbD Consultation Group’s conclusions, and then refined drafts in response to new feedback as it emerged.
   
• Drafts have been circulated as widely as possible to try to ensure that the views expressed do properly reflect community concerns.

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3.0 Context

3.1 The first DPD Joint Response, September/October 2007

SHDC initially decided to draw up DPD documents for the towns in the area sequentially. Totnes was first, with consultation starting in September 2007. This version was more substantial than the “site only” proposals now put forward, and covered the period to 2016.

The plans were widely promoted and discussed. In a frantic six week period, a joint community response was developed entitled Totnes: the Next Decade (see Appendix B). It reflected the views of Totnes Town and Dartington Parish Councils, 20 local groups, and views expressed at public meetings. This new document builds on and takes full account of the views expressed in 2007.

However, key elements were missing, most notably from Devon County Highways and the Environment Agency assessments of flood risks, and SHDC agreed to create a forum to discuss how the DPD might be taken forward. This became the Community Focus Group.

3.2 The Community Focus Group, Spring 2008

Community representatives were asked to facilitate a forum, comprising c20 representatives selected by SHDC from groups which had responded to the DPD.

Two subgroups looked at Housing and Employment issues, receiving presentations from officers and two potential developers of key sites. A third group reviewed the STA with officers. Finally the whole group agreed their conclusions in May 2008 (see Appendix C). These findings are also reflected in this report.

Later in May, without prior warning, SHDC announced that it was abandoning the Totnes DPD, in order to develop “site only” DPDs for the whole of the South Hams simultaneously. The Totnes DPD was thus delayed for two years. This decision contributed to mistrust and bad feeling in Totnes, where it was inevitably construed that planners simply did not like the outcomes determined by the Focus Group.

3.3 The Prince’s Foundation for the Built Environment

Through the Atmos Project (a local group interested in the Dairy Crest site), an introduction to the Prince’s Foundation for the Built Environment was arranged in September 2008. A group comprising local Town, District and County Councillors plus representatives from the Totnes and District Community Strategy Group, Totnes Preservation Trust and Atmos was set up to try to raise the necessary funds for a masterplan for the town. However, the RDA, Devon County Council and the District Council were not prepared to support this financially.

SHDC and the Prince’s Foundation subsequently reached agreement for the Prince’s Foundation to run eight community consultation days to support the DPD Planning process across the whole of the South Hams.

3.4 The Enquiry by Design (EbD) Day

• The EbD day comprised a wide-ranging debate followed by work in four subgroups to assess specific sites proposed by the Foundation. Afterwards, participants concluded that:
• overall, the process had been positive. The day allowed key issues to be aired, and a pleasing consensus amongst community representatives was confirmed.
• the place making principles which the Foundation put forward were helpful. The methodology employed was a pragmatic one which generally worked satisfactorily.
• an independent facilitating organisation was beneficial. However the four sub groups were facilitated very differently, with some using a very “blue sky” approach.
• the decision to discuss Totnes and Dartington separately meant that some key sites, adjacent to the town, were excluded from debate.
• it was misleading to describe the event as an EbD - it was really an exercise to identify a land bank. The more strategic issues of town planning were not covered.
• the process was incomplete - the groups had not concluded discussions, nor had a shared conclusion been reached. There was some concern that the Prince’s Foundation report might go further than was actually achieved on the day.

We therefore held a further meeting of the community participants to agree a shared position. The Prince’s Foundation and the Planning team proved unable to attend.

The Totnes Community representatives at the EbD came from:
Elected Representatives
Totnes Town Councillors
Dartington Parish Councillor
South Hams District Councillors
General/ Built Environment/Heritage
Totnes Community Strategy Group
Bridgetown Alive
Totnes Development Trust
Design Our Space
TotSoc
Co-housing Group
Totnes Heritage Group
Dartington Against Detrimental Development

Business
Totnes Chamber of Commerce
Totnes Market Traders
Totnes Food and Farming Forum
Dartington Shop

Children and Youth
King Edward VI Community College
KEVICC Students
Mansion House Children’s Centre
Grove School

Elderly and Vulnerable/Health and Wellbeing
National Pensioners Association
Dartington Church (Vicar)

Environment
South Hams Friends of the Earth
Transition Town Totnes

Sports and Leisure
Allotments Association
Totnes Living Community
Save Our Fields Association
Totnes Boating Association

Traffic and Transport
Traffic and Transport Forum
Dartington Traffic Action Group

Arts and Culture
Public Art Group

3.5 The Prince’s Foundation Report

The Prince’s Foundation Report was initially planned for July, later revised to September 2009. Community representatives were to be sent a copy at the same time as SHDC Planners.

There proved to be considerable delays. SHDC presented the principle conclusions to community representatives and Councillors in mid October, but these were still subject to possible change. As delays continued, the position of the Foundation as an “honest broker” was increasingly questioned, amid concerns that the report would move away from the focus of debate and community concerns highlighted during the consultation day. Ultimately the report was published on the SHDC website in December, concurrently with the paperwork supplied to Councillors for them to debate the DPD recommendations.

The report made the following site recommendations:

2016 total:   13.45ha

2026 total: 19.95ha

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4.0 Community Priorities

SHDC’s decision to demote the DPD from a full development plan to a “site allocation only” DPD eliminated the opportunity to consider the broader issues which underpin all planning decisions. Yet, these are core to managing development, and important to the people of Totnes. We have therefore briefly re-stated them here. Where appropriate, we call for our proposals to be reflected as firm commitments in the DPD document.

4.1 Priorities

These areas have been consistently raised by the community as matters of concern.

Collectively, we continue to share the desire for:

• affordable housing, which gives priority to local residents and reflects local needs. We would ideally like to see a target even higher than the 55% set by SHDC, and are unwilling to support any development of market housing unless it fully contributes to this goal.
• improved employment opportunities and job quality;
• high quality, locally distinctive building, sympathetic to the historical core of the town and its natural setting;
• low carbon, sustainable development which addresses climate change, affordable warmth and other environmental concerns;
• the most efficient use of already developed land, with green field sites used only when no alternative exists; and
• smaller convivial, neighbourhood communities, not large housing estates

4.2 Areas of Concern

As a community we remain concerned about:

4.2.1 The Need for an Effective, Long term, Strategic Plan
The issue: the central infrastructure of our historic town, positioned on the river, provides challenges to achieving good quality, acceptable growth, and we remain concerned about the town’s capacity for further growth without damaging the essential nature of the place. Any development needs adequate infrastructure to support it. We must “future proof” development proposals to ensure that we do not preclude future strategic developments, and ensure resilience. In short, Totnes needs a long term and more strategic plan to provide a context in which future planning decisions can be made if we are to achieve a quality environment for future generations.

The Plan: most sites refer to development according with a “Masterplan” previously approved by the Council. Paragraph 6.6 clarifies this and says that the masterplan will be prepared by “key stakeholders”. Site specific plans drawn up independently cannot constitute an overarching strategic plan which is what is necessary if we are to achieve a strategic overview in which such site specific plans can then be developed. It is the planning authority’s duty to set the parameters which could then form the basis of a concept plan, which should be arrived at with the involvement of local people. Site specific targets and objectives which are currently lacking in this DPD should be identified.

It is too late to consider the development of Totnes in the round for the period to 2016, and the proposals which have been put forward must therefore be considered development (and developer) led rather than a matter of effective place building.

Our response: we need to see
i) a commitment to develop a substantial, integrated strategic plan for the town which

• addresses infrastructure concerns, and covers the key areas from Babbage Road through to KEVICC, and the whole of T3 the Central area.
• “future proofs” the area to safeguard future requirements
• identifies parameters within which individual site masterplans can be developed
• helps build resilience in the face of fossil fuel depletion, and
• protects our historic centre with its independent retailers.

4.2.2 Access and Transport
The Issue: Totnes sits on the junction of roads from Torbay, Plymouth, Newton Abbot and the South Hams; the A385 is one of the most congested roads in Devon. The A384, particularly at Riverford Bridge and Dartington, cannot cope with greater volumes. Seasonal peaks and the expected growth in regional traffic will exacerbate the position. High Street/Fore Street remains unsatisfactory, due to vehicle numbers and pressures on parking, potentially jeopardising trading in this market town and adversely affecting our historic buildings. A more effective pedestrian priority/traffic calming scheme is required.

The problems of parking remain acute in many residential areas. Quality of life, pedestrian and cyclist safety, and economic success are all adversely affected by the current congestion and pollution. Pollution levels are regularly dangerously high on Bridgetown Hill, which constitutes part of SHDC’s Air Quality Management Area (AQMA) in Totnes, one of only three in the South Hams.

The Plan: we welcome the new emphasis in the planning system on infrastructure needs. It is encouraging that DCC are developing an integrated Transport Strategy for Totnes, and are considering using Totnes as an exemplar for green travel policies. Recent discussions with the Town Council and the Traffic and Transport Forum lead us to hope that effective policies can be put in place to mitigate traffic issues.

However, we remain concerned that the current evidence base is inadequate and/or out of date; the DPD has been drawn up before effective traffic strategies are in place; and DCC input into the selection process does not differentiate between sites, and is thus completely unhelpful in the creation of a site allocation DPD. Several of the sites selected will adversely affect the AQMA. Additionally the current economic climate/pressure on public services will make it difficult to implement effective initiatives, and traffic will inevitably remain the major concern in the town. New site proposals will be scrutinised to see their impact on traffic in the immediate vicinity, and at key junctions.

Our response: before any new development is approved, we need to see in place:

i) an up to date assessment of the impact of the site on the immediate vicinity and on key junctions throughout the town, including during peak times of traffic flow;

ii) the development of an integrated traffic management strategy for Totnes,

iii) initiatives to address the growth in regional traffic between Torbay and Plymouth;

iv) the implementation of a series of green travel plans;

v) short term plans to develop temporary park and ride facilities for seasonal visitors;

vi) ongoing development of long term plans to localise the economy; and

vii) significant reductions in the amount of car parking places available in all new builds, limiting the ratio of parking places to dwellings to no more than one per household.

(See also section 7, Grounds for Considering the DPD Unsound)

4.2.3 Affordable Housing for Local People
The Issue: average house prices in Totnes rose by 93% in the years 2001 – 2005, and there was a 17% increase in the Totnes town population in the ten years to 2001. The average Totnes house price in 2005 was £243k, in a county where wages are only 80% of the national average. Levels of owner occupiers here are below the national average at 63.8% (68.7% nationally), with greater dependence on the rental market

Housing developments must address the needs of people from the immediate area, and be available in ways which are genuinely affordable to them. It is a false economy to build cheap homes which are expensive to heat and maintain, at odds with sustainable development requirements to reduce energy consumption; and unhelpful to prospective residents. Recent developments have been out of reach for many, and opportunities have been missed to deliver affordable warmth.

The Plan: we recognise that high levels of affordable housing may impact on the viability of development, particularly in a harsh economic climate, but we question the merits of building substantial amounts of market housing if the percentage of affordable housing drops too low. It is a price which simply becomes too high. Unless the merits of employment development or affordable housing are clearly seen to justify development, any large scale development in Totnes is likely to be opposed.

The DPD is also open to criticism in that objective TO1, to ensure that affordable housing needs will be met, cannot be achieved whilst government policy remains as it is, with funds simply not being available (we also question whether “predict and provide” is the appropriate policy for open market housing). TO1 is not carried through consistently within the DPD - some proposals refer to “including affordable housing”, others say “as much affordable housing as is viable”, others make no mention of affordable housing at all.

Our response: we therefore wish to see

i) rigorous assessment of the viability of all developments to ensure the highest possible number of affordable homes, with the clearly stated option to abandon the development if the percentage drops too low;

ii) consistency in requiring affordable housing on each site. If a site is not likely to meet the affordable housing targets, the reasons for this should be explained.

iii) appropriate conditions set so that schemes provide genuinely affordable homes, with greater emphasis put on building standards which deliver affordable warmth.

iv) social housing being made available first to people who live or work in Totnes;

v) efforts to bring empty houses back into use and new policies to use the existing housing stock more effectively; and

vi) new and innovative ways of addressing the need for affordable housing, including policies to aid self build, cooperative housing and community land trusts.

4.2.4 Community Buildings
The Issue: the library and youth facilities are too small for the existing need, and the Grove School and St John’s School are close to capacity. We must identify requirements and suitable sites in the centre of Totnes now to avoid them being lost in the next round of development. We are concerned that 106 money will be prioritised exclusively to highways and housing, leaving this key part of our social infrastructure neglected. The Town Council is keen to engage with SHDC and DCC on how the allocation of 106 money is calculated to ensure that the priorities identified by the community are reflected in their allocation.

The Plan: in general, we welcome the proposal to move the Grove School to KEVICC, and enlarge it to provide greater capacity, and support plans for new youth facilities and a library. We are concerned however that DCC recently announced plans to build a youth centre and library on a site different to those selected in the DPD. This suggests a lack of rigour, clarity and co-ordination.

Our response: in addition to achieving the move of an enlarged Grove School to its new site, new youth facilities and a new library, we need to

i) clarify where the youth centre and library are to be sited;

ii) ensure suitable facilities for after school clubs;

iii) safeguard the future of the Scout Hut, Totnes Boating Association site and Rowing Club on Steamer Quay.

4.2.5 … And Open Space
The Issues: data collected for the SHDC Open Space Strategy confirms that Totnes is short of amenity space in almost every aspect, with informal open space for children and play facilities a high priority amongst residents, and a need for additional sports pitches. Many homes lack private gardens. There is a shortage of, and demand for, allotments. Densification of housing should not be at the expense of public open space provision.

The Plan: We welcome recent upgrades to existing facilities, particularly play sites, and the Heath’s Garden and Leechwell Garden projects. However, there is almost universal opposition to proposals to develop Borough Park, the last piece of flat open ground in central Totnes for sports and informal play, once the KEVICC developments take place (see also Section 6).

Our response: we would like to see

i) every sizeable new development to have space allocated for allotments as part of its infrastructure planning, and allotments included in the DPD for each relevant site

ii) a guarantee that the public open space at Borough Park is not reduced

4.2.6 Heritage buildings.
The Issue: our historic and listed buildings contribute to the economic life of the town, as a key element of why people visit Totnes, as well as to the quality of our public realm. Yet, many are in a state of disrepair. One has been on the At Risk register for twelve years without intervention by SHDC. Heavy traffic on the High Street takes its toll.

The Plan: despite Strategic Objective SO2 committing SHDC to policies which will conserve and enhance our heritage buildings, there is no indication within any part of the LDF suite of documents how it intends to do this.

Our response: we would like to see:

i) more emphasis on preserving heritage buildings in traffic management plans

ii) more proactive management of the conservation zone, and the development of policies to support this, including action when buildings are known to be at risk.

iii) greater efforts to support retrofitting and energy efficiency in historically important buildings to enable ongoing or extended usage.

4.2.7 Flooding and the Impact of Sea Level Rises
The Issue: we are all aware of the greater risk of flooding caused by climate change. The Environmental Agency classes Totnes as a high risk area, and many key sites are potentially liable to flood. Anticipated rises in sea level need to be planned for effectively.

The Plan: the DPD cites flood risks on several sites, though has, as yet, failed to undertake level 2 flood risk assessments (SFRA2) of the sites at KEVICC, Riverside and Borough Park. It says little on low lying and strategically important areas of the town. It is not clear how substantial the acknowledged risks are thought to be, nor the impact on the overall layout and working of the town. The Environment Agency and others are only now getting to grips with the impact which rising sea levels may have, and what strategies should be adopted to mitigate the risk, by protecting existing parts of the town or placing future restrictions on development

Our response: as flood risks increase, it is important that valuable land and facilities are simply not abandoned. We would like to see Totnes become part of a pilot project, working with all the agencies to determine appropriate strategies and assess their feasibility in a town such as ours. This would provide a meaningful input into the national debate, and form an important part of an overall strategic/master plan for the town.

4.2.8 Sustainable Development and Achieving the Vision for Totnes
The Issue: Totnes has long been aware of environmental issues; the global Transition Towns movement, which started in Totnes, is evidence of our concern for finite natural resources and the impact of global warming. Environmental awareness provides a pervasive ethos within our community, and this distinctive trait should be properly reflected in all aspects of our approach to development. We need to consider the impact of these development proposals on our local resilience and biodiversity.

The Plan: the developments which will flow from the DPD provide an opportunity for the town to demonstrate national leadership if we resolutely require the highest environmental standards and encourage innovation, but it is currently impossible to deliver the Totnes Vision under the existing SHDC LDF policies. Too often, our efforts to achieve environmental standards higher than the legal minimum are thwarted by the District Council and/or the planning process i.e. the removal of the Sustainable Construction and Renewable Energy Targets from the Development Policies DPD. We need a mechanism to ensure that our aspirations in this area, recognised in the Vision developed for Totnes by SHDC, can be converted into results, and adhered to in any planning decisions which affect the town.

There is no evidence that the DPD has assessed the impact of development on biodiversity and in the light of climate change (see section 7).

Our response: we propose that

i) a distinct mechanism should be put in place to enable Totnes to achieve its Vision by ensuring, if necessary, higher standards than those required elsewhere in the South Hams (without this, the Vision is meaningless);

ii) all potential housing developments should be limited to a size which ensures compact convivial neighbourhoods;

iii) greater emphasis should be placed on retro-fitting, renovating, or extending buildings before new build takes place;

iv) policies to aid self build, cooperative housing and community land trusts are developed;

v) passive solar gain and other factors which can enable renewable energy provision, are fully evaluated in all site selections;

vi) the strong community desire to use local materials and the vernacular style should be made more prominent in plans affecting Totnes;

vii) there is ongoing commitment in cooperation with DCC to developing and connecting pedestrian and cycle paths wherever possible to create an effective network;

viii) there is a commitment to a policy of “filtered permeability” i.e. one in which pedestrians, cyclists and public transport have priority over other forms of transport;

ix) there is effective assessment of the impact of any development on biodiversity and its contribution or effect in response to the challenges of climate change.

4.2.9 Community Ownership and Management
The Issue: the community remains suspicious of developments in which they do not feel fully involved or consulted.

The Plan: we welcome South Hams proposal to create a new forum to discuss planning issues, and would wish to see more flexible approaches to development, such as:

i) community ownership or management of sites, through community land trusts and asset transfer (in accordance with the joint community/District Council response to the government’s Sustainable Community Act consultation).

ii) robust financial models for genuine affordability including “mutual home ownership”

iii) policies which enable self build of affordable homes

iv) co-housing and housing co-op initiatives to manage affordable housing

v) efforts to localise building, such as a consortium of small, local developers to partner larger national/regional developers and given a mandate to develop the more innovative housing, such as self-build and co-housing.

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5.0 The Planning Process and Underlying Assumptions

5.1 Consultation and Feedback

We remain very disappointed at the level of publicity given by SHDC to this round of the DPD consultation. If we had not decided to promote the DPD consultation period ourselves, then it would not have qualified in any commonsense assessment as a public consultation.

The South Hams Sustainable Community Strategy states “One of the key principles of community based planning is that of active community participation, and there must be real opportunity for people to influence and change decisions and services”. While we recognize that the EbD process goes some way to addressing this in Totnes (but not in the other towns of the South Hams, due to the lack of community representatives present) we feel the overall process falls well short of good practice (see also section 7).

Additionally, we are concerned that consultation needs to be meaningful – “to influence and change decisions and services”. In section 7, we draw attention to specific examples where the views of the community have been consistently voiced, yet remain unheeded, despite suitable alternatives being available.

.5.2 The Regional Spatial Strategy and Setting of Targets

It is becoming clear that the government’s decision to remove the RSS targets will require a review of all targets and policies applying to this DPD, and the establishment of new, verifiable targets. In principle, we support the need for affordable housing, but dislike the dependency on market housing to achieve this. We are thus likely to oppose any scheme where the amount of affordable housing falls significantly below the SHDC target of 55%. The continued influx of older people, and the flow out of Devon of our young people, is neither healthy nor sustainable for our communities. We need to give priority to developing planning policies which will support the retention of our young people, both in providing housing and jobs. We also need to contain overall development to a manageable level in keeping with the capacity of our infrastructure to support it.

It is hoped that this change in government policy will act as a catalyst for a radical review of housing policies and approaches, leading to a reduction in the overall level of housing development considered necessary, while ideally retaining or even increasing the numbers of affordable homes.

5.3 Transparency of Housing Targets

Since the very first presentation by South Hams to community groups in September 2007, there has been disquiet about the ambiguity, and possible lack of transparency, surrounding the numbers of homes to be built in Totnes. The issue of large sites which could potentially be defined as “windfalls” has been extensively debated. There are indications that development of sites outside the DPD may be supported and, on at least one site, that substantially higher numbers are being considered. Officers have confirmed that the numbers included in the DPD are only loosely indicative and could be changed upwards substantially.

We wish to restate our position that the community at large is willing to support development, even up to the levels proposed in the DPD and despite our concerns about infrastructure, in order to support the development of affordable housing and employment opportunities, but will strongly oppose any significant level of additional housing being proposed later - either as large scale “windfall” housing, or for reasons of viability, or to address shortfalls elsewhere.

It is not acceptable that the number of homes set for each site could be revised significantly upwards. If the targets set can be changed fundamentally at a later point, it makes a mockery of the planning process itself, of Councillors who have supported proposals, and of community consultation. To any reasonable person, the targets agreed, while needing to remain sufficiently flexible, should be clearly related to those outlined in the DPD.

We therefore propose the following:

a) that all targets currently quoted as “about…” should be clearly understood to mean in a range plus or minus 20% at most; and

b) in the event of a larger number of homes being approved on any one site, there will be a corresponding reduction in the number of houses built elsewhere, so that the overall level of building may match, but does not exceed, the agreed DPD levels;

c) that any large scale exception or departure site approved by SHDC during the period of the plan would count towards the DPD targets, and lead to other, (preferably green field) sites in the DPD not being utilised, so that the total levels agreed are not exceeded .

5.4 Densification

Densification of housing is an existing policy (SO5), which the community supports as a means of limiting green field development, subject to achieving high quality standards. Clever design can achieve high density, relatively low rise building, just as the traditional town centre achieves.

Additionally, we believe that existing sites can and should be used more intensively first, thus creating the new jobs undoubtedly required, while minimising development on green field sites. This applies particularly to the Babbage Road Industrial Estate

5.5 Employment Development

Targets for employment in the DPD remain unsatisfactory, with an amount of land still specified for employment within the overall number of sites rather than referring to the numbers and types of jobs to be created. The Prince’s Foundation advised at the EbD day that there is a legitimate case for defining targets in terms of numbers of jobs rather than hectares of land. The DPD needs to define the range of employment needs, and the types of spaces and facilities required, and relate the need to the optimal locations for such development. Further, we can find no up-to-date evidence which assesses journeys to work or commuting patterns. (see also the Afterword, p44)

5.6 Omissions from the Plan

5.5.1 Sites
There are a number of important sites which have been omitted from the plan. These are considered in section 6, and are proposed as alternatives to those sites considered unsound.

5.5.2 Policies
The move to a site allocation only DPD has meant that a number of key elements of planning policy are not in place. These are identified in Section 7.

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Totnes: Planning for the Future Part 2

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