Cornwall Local Plan Examination

CORNWALL LOCAL PLAN EXAMINATION

INSPECTOR’S ADVISORY COMMENTS PRIOR TO CONSULTATION ON PROPOSED CHANGES

1. The Examination remains suspended whilst the Council undertakes consultation on its proposed changes. However, I have briefly reviewed the proposed changes and the related new evidence documents (as available at the end of December 2015) to see if there are any obvious gaps in the new material or other points which might usefully be clarified before the consultation commences. I emphasise that I am not seeking to comment on the soundness of the proposed changes. My aim is solely to make the consultation process as effective as possible for all parties in the hope that swift progress can then be made when the Examination resumes. There will, no doubt, be many issues that need to be considered and discussed in due course. The mention of any matter below (or the absence of any mention) does not have any significance for what I will eventually identify as the main issues for further consideration.

2. I could not see any evidence document explaining the changes in employment floorspace in each CNA (Proposed change 39, old table 2, new table 3) or a response to my concern in my Preliminary Findings about how the choice/scale of location for new employment floorspace reflects the Council’s/LEP’s economic strategy and targeted sectors.

3. Responding to concerns raised early in the Examination my understanding is that the Council is no longer proposing that this plan specifically allocates the sites for the Eco-communities (ID.01.CC.2.1), but intends them to be strategic locations only. Proposed change 25 states that the site for the eco-communities will be identified through the Site Allocations DPD. (Is that intentionally singular or should it be sites?) Consistent with this approach, the current plan should not identify specific boundaries for the Eco-communities and thus the plan on page 167 would seem inappropriate. The location(s) should however clearly be identified on the Key Diagram. From my quick read, I am rather confused as to whether the figure of 1,500 dwellings now ascribed to the Eco-Communities in Policy 2a and in Table 1 (as proposed to be changed) is intended to refer to West Carclaze/Baal and Par Docks or just to the former. Policy 2 does not include any guide as to the scale of development in the 2 locations. Whatever the position, there should be a brief note of the evidential justification for the change from the submitted plan. (When the Examination resumes it would be helpful to know the timetable for the determination of the extant planning application for West Carclaze/Baal.)

4. The Report to the Council’s Cabinet (3 December 2015) included Appendix 3: Cornwall Local Plan Housing Distribution. In relation to the figures for Previous Delivery in each CNA, a little more explanation of how this has been calculated would be helpful to everyone. Over what period has past delivery been assessed? Do the figures quoted refer to the past annual average delivered? If so, is the percentage for any uplift required being measured against what the pro-rata provision would be or against what is now proposed in the changes?

5. I have not seen any further explanation/justification for the windfall calculation (see my Comments on Other Matters, July 2015, 3.6). This would be helpful to me and to other parties. New document K is a trajectory of affordable housing delivery. Given the detailed scrutiny previously given to this issue and the bespoke mechanisms used in Cornwall for some aspects of this delivery, it would be helpful to have a note of explanation of the different categories in the table. Also, for Council funded projects, what of this provision is clearly committed and what requires future commitments be made.

6. In my Comments on Other Matters I gave detailed advice on the way that I would wish information to be presented on various matters relating to housing supply and delivery. I note the detailed Housing Trajectories (for each CNA town/residual) in new document J. I presume the first table in that document is the Trajectory referred as Appendix 1 in Proposed Change 24. It would be very helpful if an additional column on the right could be added to all the tables to sum the total of each of the first 11 rows in each table. This would make it easier to cross-reference different types of provision with figures elsewhere. In particular, I want to be able to see at a glance the total of additional allocations which need to be made for each CNA town.

7. I also highlighted in the note of July 2015 (2.4) that I wanted to be able to readily see for each CNA (town and residual) how the identified capacity in the SHLAA of deliverable/developable sites compared with the scale of new allocations (row 11 of the trajectory) still required to be made. I want to know if there is adequate headroom each CNA and each main town/residual area to provide some choice in the selection and allocation of sites for development in the Site Allocations DPD from the SHLAA “menu”. Given that some SHLAA sites may already have permission and that some SHLAA sites are now identified in the Housing Trajectory separately from proposed allocations considerable care will be required in making this comparison to avoid double counting.

8. It is up to the Council how it responds to the above points. I do not need any response direct to me at this stage. Clearly it is best if all the information which the Council provides to me when the Examination resumes has been made available at the start of the consultation period so that parties’ comments on the proposed changes have been informed by all the evidence on which the Council ultimately relies. If any additional document is to be made available after the consultation has begun, the Council should flag that intention at the outset so that parties know that it will be forthcoming. If such late material is significant, then it may be necessary to extend the consultation period on that matter, or the consultation as a whole if it has wider implications for the plan.

9. Finally, there is an important point about recording representations. Until I have studied the new representations I will not know how it is best to structure the hearings. However, it is likely that I will need individual hearings on most, if not all, the CNAs to hear points about the scale of housing provision (and possibly employment space). The proposed changes in this regard are only in the table in policy 2a, Table 1 and Table 3. It is essential that the Programme Officer is able to readily identify for each individual CNA town or residual all those who consider that the proposed changes are unsound and would want to participate in a hearing on an individual CNA. This means that representations on each row of these tables must be readily identifiable in the data base. If new representors have not indicated whether they wish to be heard, it would be helpful if this is clarified with them immediately, rather than waiting until the Examination has resumed.

10. I would reiterate that the above comments are solely intended to be helpful (to all parties) in making the most efficient use of the consultation process and of minimising delays when the Examinations resumes.

Thank you.

Simon Emerson

Inspector

7 January 2016