a) b) c) d) – Too few, not affordable, lost opportunity to address the Housing crisis being replaced by holiday accommodation.
“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:
“A minimum of at least 30 % on site affordable will be sought for all schemes of 11 or more dwellings.”
“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.)
ADD to your 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 `NationalPlanning Policy Framework (NFPP)- specifically paragraphs 199-202
“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. 617 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.
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.
No air quality assessment
The local validation checklist makes it clear that proposals that impact on air quality orare 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.
No Plan provided
The application as submitted lacks the information required for an application of this nature and scale. The application must be supported by a Construction Management Planas required by the local validation checklist. Especially given the risk of contamination to the site and local waterways.
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