Fastglobe's planning application. Ref: 3136/22/OPA

• Closing date is November 17th 2022
• Emails and letters must include the planning Application Reference Number in the subject line: Ref: 3136/22/OPA.
• Emails to dm@swdevon.gov.uk
• Letters to Planning Dept, SHDC, Follaton House, Plymouth Road, Totnes, TQ9 5NE.
• Please DO NOT refer to ATMOS as objections should relate to the Fastglobe application being considered.

Using the Planning Portal.

• Click on: Comment on this application
• Enter your details
• In the dropdown box select Other or Planning Policies and Guidance before adding your comments.
  
  You will need to list reasons relevant to the council granting or refusing planning permission. See Reasons below
  ‍
• Please select  ‘OBJECT’ in Overall View
  If you email or write a letter please say clearly that you OBJECT.

Six reasons to object

1. Housing
   Too few, none affordable. South Hams has declared a housing crisis - why approve luxury holiday lodges?
2. Heritage
   The plan has insufficient information to assess impact of development.
3. The Community Use of the Listed Brunel Building
   No information given in the plan. What is the plan?
4. Ecology
   No baseline assessment in the plan to judge ecological impact
5. Air Quality
   Station road is extremely busy. Why No air quality assessment in the plan?
6. Construction Management Plan
   ‍No plan submitted

Six Detailed Reasons to Object

if your comments fail to upload, please send them by email

1. Housing

Choose a) b) c) or d) – Too few, not affordable, lost opportunity to address the Housing crisis being replaced by holiday accommodation.

• a) The number of dwellings is significantly below that envisaged by the allocation of 62. This must be viewed as an under delivery and inefficient use of the site without justification. This is contrary to the intent of the NPPF and para 125 c).
  
  "Local planning authorities should refuse applications which they consider fail to make efficient use of land, taking into account the policies in this Framework. In this context,when considering applications for housing, authorities should take a flexible approach in applying policies or guidance relating to daylight and sunlight, where they would otherwise inhibit making efficient use of a site (as long as the resulting scheme would provide acceptable living standards)”.  720ch
• b) The provision of holiday accommodation in this location, clearly at the expense of new dwellings, is not the most appropriate and efficient use of land and is therefore also contrary to the intent of policy SP6 and TTV22(5) which envisages a significantly higher number of dwellings. 284ch
• c) The proposals seek to provide 9 apartments and 16 terrace houses as set out at paragraph 2.2 of the Planning Statement. It is unclear as to how the proposals satisfy Policy DEV8: Meeting local housing need in the Thriving Towns and Villages Policy Area and specifically DEV8.1 and DEV8.3 which states:
  
  “A mix of housing sizes, types and tenure appropriate to the area and as supported by local housing evidence should be provided, to ensure that there is a range of housing, broadening choice and meeting specialist needs for existing and future residents. The most particular needs in the policy area are:
  i. Homes that redress an imbalance within the existing housing stock.
  ii. Housing suitable for households with specific need.
  iii. Dwellings most suited to younger people, working families and older people who wish to retain a sense of self-sufficiency. ‍
  
  ‍“A minimum of at least 30 % on site affordable will be sought for all schemes of 11 or more dwellings.”  960ch
• d) The application does not indicate any potential employment or training opportunities, or meet local housing need, and there is no affordable housing provision within the plans Spatial Priority SP6  -  Spatial priorities for development in Totnes“The plan seeks to enhance the vibrancy and sustainability of Totnes. This will include:Providing for mixed use development to help meet local housing need and increase employment opportunities to support the long term resilience of the town.) 488ch

DO ADD to ALL objections that South Hams District Council and Totnes Town Council have declared a Housing Crisis

2. Heritage

Insufficient information to assess impact of development

The Hybrid application prevents the impact of the proposals in terms of the setting and significance of the listed building from being fully assessed. The planning authority should request additional information in order to assess the impact of the proposals. The planning statement actually states the Plan for conversion of Brunel “to be similar to that already approved via provision reference 1225/19/LBC.” This is the Listed Building Consent gained by TCDS in 2019 which contained a commissioned 61 page Heritage statement for the building.

The development must be considered against the relevant paragraphs of the `National Planning Policy Framework (NPPF)- specifically paragraphs 199-202  See extract at end of doc
‍“National Planning Policy Framework – HERITAGE ASSETS Considering potential impacts”.   The supporting evidence relating to heritage and heritage impact is insufficient to allow this assessment to be undertaken. 933 ch

3. The Community use of the Listed Brunel Building

No information given

The application is not explicit in terms of Community Use of the listed Brunel building.Simply states “Change of Use”. Key deliverable in TTV22(5). Planning statement commentary states that “the future community management will be agreed through the S106 agreement”. How will this be achieved in practice? Community use should be captured in the description of the development alongside a suitable mechanism for delivery. 492ch

4. Ecology

No baseline assessment to judge ecological impact

The Ecological assessment confirms the absence of the Defra/Natural England Biodiversity Metric v3.0. Further survey work and the South Hams Special Area of Conservation (SAC) Greater Horseshoe Bat Landscape Connectivity Zone would indicate the existing baseline score of the site is likely to be relatively high.This does not conform to ensuring all new development does not have any negative impact on the greater horseshoe bat species and their flight paths within the protected South Hams SAC.

A Biodiversity Metric table which confirms the current score of the site must be provided as the existing score must be understood before the principle can be considered. If the redevelopment results in a negative score in terms of biodiversity net gain then this is a significant material consideration. 862ch

5. Air Quality

No air quality assessment

The local validation checklist makes it clear that proposals that impact on air quality or are potential pollutants must be supported by an air quality assessment. This should indicate the change in air quality resulting from the proposed development and outlining appropriate mitigation measures as necessary. This is vital given the fact the site is immediately adjacent to A385 AQMA and as required JLP policy SP6. Any adverse effects may result in mitigation measures being required. 528ch

6. Construction Management Plan

HERITAGE OBJECTION 2 - NPPF Extract - For Information

No Plan provided

National Planning Policy Framework – HERITAGE ASSETS Considering potential impacts 

199. When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.

200. Any harm to, or loss of, the significance of a designated heritage asset (from its alteration or destruction, or from development within its setting), should require clear and convincing justification. Substantial harm to or loss of:

1. a) grade II listed buildings, or grade II registered parks or gardens, should be exceptional;
2. b) assets of the highest significance, notably scheduled monuments, protected wreck sites, registered battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional⁶⁸.

201. Where a proposed development will lead to substantial harm to (or total loss of significance of) a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or total loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply:

1. a) the nature of the heritage asset prevents all reasonable uses of the site; and
2. b) no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and
3. c) conservation by grant-funding or some form of not for profit, charitable or public ownership is demonstrably not possible; and
4. d) the harm or loss is outweighed by the benefit of bringing the site back into use.

202. Where a development proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal including, where appropriate, securing its optimum viable use.