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Report and recommendations of the members of G4BW
CONTENTS Summary of Position Recommendations Detailed Position Statement
SUMMARY OF POSITION following a series of meetings held between G4BW and TQ9 and their architects from March to May 2010 The G4BW group was set up under the auspices of the Housing & Built Environment Forum and comprises Paul Bennett (Totsoc) Charles Fox (Preservation Trust) Louis Victory (Traffic and transport Forum) and Tony Whitty (Town Council). The Group’s purpose was to represent community organisations in seeking a more appropriate development than that envisaged by TQ9’s previous application, which members of SHDC planning committee had refused. The Group held its first meeting on 11 March with TQ9, which welcomed the Group’s involvement and expressed a willingness to co-operate with it. The Position Statement shows the areas of negotiation and the parties’ approach to these. This Summary is intended to encapsulate the principal areas of negotiation set out in the Position Statement and the outcome of the negotiations. Major areas of amendment to first Planning Application Reduction of housing numbers from 250 to c.180 Reduction in employment parking by c. 15% Overall parking spaces will be reduced to no more than 400 from 587, with residential parking ratio reduced to 1:1. Higher percentage of affordable Housing. Modification of greenfield take The group welcomes the considerably reduced scale of the new proposals. There will be no podium upon which a considerable part of the development comprised in the earlier application stood and hence building height reductions, which TQ9 is prepared to express as Conditions. Dwelling numbers are reduced from 250 to 180 with assisted living dwellings forming part of the Retirement Village also down to around 75 from the 100 in the original Application (thus a total reduction of about 96 dwellings). There may be fewer jobs (about 350 as opposed to 440) but the marine employment space will be maintained with space for increase as will boat storage albeit with some changes. The reduced parking provisions will significantly help to ameliorate the impact of additional traffic but much work remains to be done on the green travel plan to which TQ9 is commendably committed.
RECOMMENDATIONS G4BW believes that TQ9 wishes to create a development, which will make a valuable contribution to the 21st century built environment of Totnes. This has been demonstrated by the considerable concessions made during the course of discussions. There remain areas where the Group has reservations, such as traffic generation, and inevitable scepticism that the “green travel plan” can successfully mitigate this. Regrets too that more cannot be done in the provision of affordable housing. The door will be left open for South Hams District Council to buy land or houses within the site should circumstances change and enable it to do so. It is hoped that the County Council can be persuaded to involve itself in the Care Home to fund places for those of limited means. Although employment provision will be more than tripled as a result of the development there are many who will be concerned that the majority of new jobs will be low paid. G4BW’s view is that notwithstanding these reservations the proposals presently outlined by TQ9 merit the community’s support. TQ9 has worked hard with its Architects (HSP) to meet the objections raised by the community in respect of the planning application rejected by members of the Planning Committee. We therefore recommend that those organisations whom we represent and the Totnes Town Council give their support to these new proposals.
DETAILED POSITION STATEMENT BY G4BW G4BW has requested on several occasions that South Hams District Council prepare a design brief or masterplan for this site, but it feels unable to do so. This leaves the community in something of a vacuum in discussing revision of proposals in the wake of the refusal of the Outline Application. In these circumstances TQ9 has, on a number of issues, requested that G4BW should more precisely define its interpretation of community views about development of the site. The notes below were therefore intended to add focus to the debate, and in this dated version indicate the conclusions that G4BW wishes to present to the organisations it represents. The descriptions of TQ9’s position on any issue are provided by G4BW, and represent its best understanding of what has been said. VIABILITY TESTS G4BW has requested TQ9 to provide factual evidence to support its claims about the financial viability of various aspects of this scheme. TQ9 has agreed to do so, subject to the usual caveat of commercial confidentiality. LAND USE AND SITE ZONING G4BW remains concerned about the marine employment land area available on the site for the future. It feels that the more ‘intensive’ land use and new buildings proposed for this area could mitigate against the type of low cost/low intensity uses on which such activity thrives. It is also concerned about the potential unsuitability of road access to the main employment areas through the rest of the development. TQ9 says that the open boat storage ground area is about the same as existing (and that demand is falling); and that whilst undercover storage is will be about half what it is now, this should be sufficient for the requirements of wooden boat owners and those requiring repairs. It is claimed that this is compensated for by more racking for small boats and pontoons for on-water winter storage, which would also increase seasonal visitor capacity. It is also claimed that marine industries floorspace at 18,000 square feet is about 3000 square feet more than existing, with capacity for addition of a further 17,000 square feet of office accommodation over the workshops with the potential or more if future demand dictates. TQ9 says that it has plans to enlarge the size of boat which can be accommodated in the yard and that its plans will make provision for the appropriate size lorries to gain access. A minimum of 3000 square feet will be available initially for start-up businesses, and TQ9 would be willing to work with local authorities interested in economic development initiatives (rent subsidy etc.) 2. G4BW seeks a clear plan showing potential viability for a future water- borne transport interchange with adequate ground area, adequate vehicular access, and suitable tenancy arrangements to protect associated uses. G4BW wishes to see development, which would allow for any future revival of water-borne transport. It feels that current proposals may militate against this in terms of the size of the marine-related zone and its position on the site, which creates problematic vehicle access. TQ9 is in principle willing to protect this area for such use, and will prepare proposals for doing so, including protecting adequate vehicular access, setting up suitable tenancy arrangements for land and buildings, etc. 3. G4BW has sought a significant reduction in the size of the retirement village (assisted living dwellings and care home); undertakings to protect a degree of local low-income occupation; consideration of relocation on the site. G4BW is concerned that locating a large retirement village here will cause further skewing of the age profile of Totnes, and will cater for wealthy incomers drawn to the riverside site, rather than for the people of the area. It believes that location next to the marine employment area could ultimately damage and restrict the latter, whatever precautions are taken to reduce noise nuisance. TQ9 believes that residents are likely to be primarily local. It says that it is unable to move the location, or reduce the 2x30 (industry standard) format for the care home. However, it is keen to consider a social partner for the extra care housing (reference current County Council initiative in Totnes); and has offered to reduce the number of assisted living dwellings (ILUs), initially from 100 to 90, but now to around 75. It will also arrange for the proposed private sector care home operator to come to speak to G4BW. 4. G4BW in principle opposes greenfield take other than in small areas on the southern and eastern boundaries of the development site. It has reluctantly been prepared to consider modifying this position if either a) TQ9 absolutely guarantees there will be ONLY ‘social housing’ on the first (north-western) field or preferably b) the prospective co-housing development is moved to a lower and less visually damaging greenfield area further south than currently proposed. G4BW is opposed to the levering in of greenfield land outside the Development Boundary on the back of brownfield development, unless there are compelling reasons for doing so although it accepts that the minor boundary ‘tweaks’ (on the southern boundary of the site) should not necessarily be opposed. G4BW is 100% supportive of the co-housing initiative in its own right, but recognises that the attachment of this ‘social purpose’ to the proposed greenfield take in the north-west of the site has been construed by parts of the community as an attempt to persuade the public (and Planners) that altering the Development Boundary at this point is acceptable; it is noted in that context that TQ9 will not guarantee that the land may not ultimately be used for ordinary market housing. G4BW particularly opposes loss of the field involved because of the adverse landscape implications looking both into and out of the town on the NW-SE axis, and from the other side of the river. It also feels that the apparent position of Planners, that this part of the development would be a reasonable infilling of a ‘plan gap’ in local development, is inappropriate in terms of protecting the character of the town and the precious River Dart landscape. After much discussion G4BW has therefore reluctantly put forward a compromise solution involving greenfield take on a lower and less view- obstructive area of another field to the south-east. TQ9 has responded positively by producing optional revised layouts which ‘flex’ the development boundary by a slightly larger greenfield take to the south; redesign the layout of the co-housing significantly; and enable retention of more of the first open field (off Moat Hill). The end result is restoration of a reasonable connection and view between the open countryside and the town, as well as the potential for a softer green interface between the co-housing and Moat Hill. The minimum width at one point between the hedgebank along Sharpham Drive and the closest point of any building will be no less than 6.0metres, and TQ9 will try to increase this up to 7.5 metres during the design process. HOUSING AND JOB NUMBERS G4BW has sought restriction of the number of dwellings on the site to 150, particularly in view of the fact that if there had been a further 100 assisted living dwellings (technically, but open to challenge, excluded by their Use category from the dwelling count), then the development would even then have been accommodating 250 dwellings. G4BW believes that SHDC Forward Planning made a reasonable assessment of the housing capacity of the site when it put forward a figure of ‘about 150’ dwellings in the DPD Site Allocations consultation document recently put before (and approved by) SHDC Members. This figure accords with the original community view at the time TQ9 proposed its original 180 dwellings (subsequently raised to 250 in the Planning Application). G4BW considers that ‘about 150’ would be ideal to limit the landscape impacts of developing this enormously sensitive area; to allow sufficient space for the development of employment (as prioritised by the local authority); and to restrict the traffic flows emanating from this poorly accessed cul-de-sac site. G4BW is also of the opinion that the assisted (independent) living dwellings should, rationally, be considered in the total dwellings calculation in order to make a realistic assessment of the site’s housing contribution and development impact. TQ9 initially responded by reducing its total housing provision (excluding assisted living dwellings) from 250 to 200. It has now offered a further reduction to around 180 (plus the reduction of 25 assisted living dwellings described above). The site would therefore now be accommodating a total of 255 dwellings as compared to the 350 in the first Planning Application. It claims that it can show that further reductions will impact severely on numbers of affordable housing and viability; if that can be fully demonstrated, G4BW would accept this as a reasonable compromise. 5. G4BW seeks a minimum provision of 35% affordable dwellings, with a ceiling of 50% in good market conditions. TQ9 maintain that an expensive brownfield site cannot generate as much affordable housing as a cheaper ex-agricultural site; and that the quantum of affordable housing will in any case be set by independent appraisal before the scheme starts. Nevertheless, it has offered to raise the threshold to 25%, and the ceiling to 50%. As above, it has also agreed to provide viability information to G4BW. Further, TQ9 has said it will be willing to offer completed dwellings and/or land to SHDC for purchase as social housing. 6. G4BW seeks a clear ‘offer’ of capacity for at least 150 new non-care home jobs on site, and measures to ensure that as many as possible of these are skilled jobs. There should also be protected space for low- rental start-ups. G4BW remains concerned that there is insufficient employment provision planned for this site, but accepts that development of housing is necessary to finance employment facilities. Total job numbers have (at 200 dwellings) now been reduced from the Planning Application’s 440 to 350, of which about 250 would be new; taking out the 100 new jobs in the care home (of which only about 22 may be skilled/high value), this leaves a maximum of about 150 new jobs in marine-related office and retail sectors. These numbers (and employment floor/groundspace) are being defended on viability grounds, but the community has no access to viability testing, and – again – cannot take it on trust. TQ9 has offered to demonstrate that the scheme provides employment space for at least 150 new jobs outside care services (based on 180 dwellings plus 75 assisted). 7. G4BW accepts that the floor area (and type) of retailing now proposed is acceptable, provided that substantial numbers of parking spaces are not attached thereto. 8. G4BW believes that the Totnes community will potentially pay a very high price for the development of this site, because of greatly increased traffic flows generated by the parking spaces that were to be allocated. This matter is dealt with under ‘External Impacts’ below, since it is the town as a whole which would suffer. CONTEXTUAL DESIGN 9. The revised Planning Application will still be Outline only, and G4BW therefore feels it is inappropriate and potentially misleading to be drawn into detailed design discussions except insofar as principles and Conditionality may be involved. 10. G4BW seeks confirmation of detailed conditionality on maximum building heights on all parts of the site, expressed as AOD. G4BW believes that Baltic Wharf is one of the more sensitive development sites in Devon, impacting on an area of outstanding natural beauty which is famous nationally. It is a visual gateway both to the Dart Valley and to the historic settlement of Totnes. A key concern has been the large scale of development which had been proposed, leading to areas of inappropriate density and building height for a small market town and for such a sensitive site. It is to be welcomed therefore that TQ9 has now reduced density, removed the storey of undercover parking with podium over, and restricted building heights to a maximum of 4 storeys, which it will be willing to Condition. 11. G4BW’s position on greenfield take is described in 4. above. G4BW opposes the greenfield take for housing development, not only for the reasons given in 4. above, but also because the elevation of that land raises built development to a prominent height in the valley landscape. G4BW believes that the only ‘deal’ acceptable to the community in sacrificing the greenfield land would be a 100% guarantee of a social housing use only (effectively an ‘exception site’). Since TQ9 cannot guarantee this, a compromise solution of moving the take of greenfield towards the south-east would lower the buildings and arguably have less visual impact, and might be more acceptable. TQ9 has responded by bringing forward an amended scheme which ‘flexes’ the current development boundary, amends the co-housing layout, and reinstates part of the first field off Moat Hill, in order to open up views in and out of the town. 12. G4BW seeks clarification of the proposal for parking on the roof of the marine employment sector office block, so that it can assess visual acceptability. It also wishes to ascertain what would happen to this parking if, as suggested, it might be moved off the roof to respond to demand for more office space. G4BW potentially opposes the proposed use of the roof of the marine services office block for parking. This could be visually disastrous, and cannot easily be screened from view from the high-level walks on the southern side of the valley. TQ9 has raised this proposal in recent discussion, and confirm that it is intended to construct photovoltaic array or other screening over this area. A drawn proposal will be brought forward. TQ9 adds that there is the potential for additional employment space in the car park if the traffic demand can be managed downwards. 13. G4BW seeks specific information on the likely impacts of flooding on buildings at the lower level on the site. G4BW seeks details of how it is proposed to deal with flooding situations. In particular, how will emergency escape be managed; and will any built areas (e.g. garages, retail) have to be abandoned to flood water at highest predicted water levels? TQ9 will produce a new Flood Risk Assessment within 2-3 weeks. 14. G4BW seeks consideration of in-principle realignment of building blocks to create maximum landscape ‘flow’ viewed from the opposite bank of the river, and from the footpath above. G4BW, whilst reluctant to enter into any design issues which are meaningless for an Outline Application, supports the SW Design Review Panel’s view that most of the buildings should be orientated “parallel or at right angles to the river”. It further supports the Prince’s Foundation initial view that building blocks at the centre of this development would be best orientated (roughly) north east-south west, thus allowing the landscape to ‘flow’ through from river to hillside in the valley. This could considerably reduce the visual impact of development, and could be Conditioned. TQ9 are intending to introduce elements of this orientation into the design whilst also trying to ensure quality views for the public residents and employees. EXTERNAL IMPACTS 15. G4BW seeks very low levels of initial on-site parking, both for residential and employment parking, to accompany the very welcome travel plan measures proposed by TQ9, and the measures which the County Council hope to take in the forthcoming Local Transport Plan period. One of G4BW’s most serious concerns about the impact of development at Baltic Wharf is the generation of socially and environmentally unacceptable traffic flows across Totnes from one of the most inaccessible parts of town. Paradoxically, TQ9 is promoting the development as ideal on grounds of sustainability, being within easy walking distance of the town centre and bus and train services, yet it was until recently suggesting up to 1.25vpd residential parking (381 spaces including retirement village and visitors), plus 206 employment spaces (including visitors and retirement village)….achieved by 514 spaces with 73 shared. Traffic through adjacent entirely residential areas will increase dramatically, and there will be pressure on junctions across the town. Whilst Devon County Council can demonstrate technically that these flows alone will not cause Totnes to grind to a halt, G4BW is clear that they will cause a substantial deterioration in environmental and living conditions. Previous discussions with TQ9 and the County Council have indicated a willingness in both parties to work on traffic reduction measures for the town, and this is very welcome. Such measures are largely dependent on financial and other resources: these are very much at risk for the County, but could be achieved though commitments under Section 106 as TQ9 has put up interesting proposals for consideration. However, all measures rely on money, time and persuasion, and are inherently uncertain in impact. G4BW therefore believes that if TQ9 wishes to argue that this is a sustainable site it must ’put its money where its mouth is’ and heavily restrict parking on site, including allowing for less than 1.0vpd for dwellings. TQ9 has offered to reduce its residential parking ratio from 1.25 vpd to 1.0vpd. After further discussion, it has also offered to reduce the employment parking on site by 15% on SHDC/DCC standards, in direct recognition of the likely impact of the ‘green travel planning’ initiative which it will take. It is willing to guarantee that overall parking spaces on site will be limited to less than 400, compared to 514 residential, employment and visitors parking (including retirement village) in the Planning Application; and that further reductions will be guaranteed if specified and workable alternative travel facilities are made available by the County Council and other parties. 16. G4BW seeks evidence that the County Council is satisfied with the position of TQ9 on the education impacts of the development. G4BW has not seen evidence that the pressure on school places generated by the proposed development has resulted in adequate Section 106 payments to the LEA, and seeks reassurance on this matter. TQ9 states that the Section 106 contribution has been determined by the LPA in conjunction with the LEA. It was agreed that G4BW should seek independent reassurance about this from the County Council. 17. G4BW seeks evidence that there has been adequate consideration of health service impacts. G4BW had not been aware of any analysis of the impact from the development on local health services. TQ9 pointed to the fact that there was a Health Impact Assessment with the original Planning Application. G4BW would review this and comment further. G4BW believes that there has not yet been any analysis of the capacity of the local sewer system to cope with new flows to the Totnes sewage treatment works, and that this is critical given the fact that connection to the sewers runs below the river. Such analysis is now sought; or alternatively TQ9’s proposals for on-site sewage treatment. TQ9 has responded that they are in discussion with SWW about the necessary study. They also confirmed that if necessary the site could accommodate its own internal sewage treatment system. 19. G4BW seek commitment to building designed at CSH level 4 and above, and to ‘Lifetime Homes’ design principles. There should also be maximum commitment to other measures such as on-site resource conservation and best practice management. G4BW believes that a key aspect of the way this scheme is developed should be the sustainability of building layout and design: limiting their impact on the environment. TQ9 have made much of the sustainability of the project, but their minimum commitments to date have been disappointingly low in seeking to achieve only Code for Sustainable Homes Level 3 for buildings. However, they now state that it would be their wish to achieve Code Levels 4-6 on all houses if possible, and decisions on this will be made as the revised Planning Application is progressed.
G4BW 24/05/10
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