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Choose a) b) c) or d) – Too few, not affordable, lost opportunity to address the Housing crisis being replaced by holiday accommodation.
DO ADD to ALL objections that South Hams District Council and Totnes Town Council have declared a Housing Crisis
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
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
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
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
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:
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:
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.
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