South Hams Friends of the Earth

South Hams FoE Submission re soundness test 7

The Totnes and Dartington Development Plan Document fails Soundness Test 7: The strategies/policies/allocations fail to represent the most appropriate in all the circumstances, having considered the relevant alternatives, and they are not founded on a robust and credible evidence base.

Climate Change - Flood Risk: There is overwhelming scientific consensus regarding climate change and its expected impacts, but the DPD fails to take this into account sufficiently in the Sustainability Threshold Assessment, The Vision, or the Strategic Objectives.

The Intergovernmental Panel on Climate Change (IPCC) is the world’s leading authority on climate change. The IPCC fourth assessment report 2007says: Warming of the climate system is unequivocal, as is now evident from observations of increases in global average air and ocean temperatures, widespread melting of snow and ice, and rising global average sea level…….. Observations since 1961 show that the average temperature of the global ocean has increased to depths of at least 3000 m and that the ocean has been absorbing more than 80% of the heat added to the climate system. Such warming causes seawater to expand, contributing to sea level rise…….. Global sea level is projected to rise during the 21st century at a greater rate than during 1961 to 2003.

It is therefore very surprising that SHDC has selected sites for development which are in flood zones 2 and 3 without having procured an SFRA level 2 in advance of the DPD being submitted.

• The STAs of: Bidwell, Bourton Lane, Dartington Lane Field, and KEVICC indicate that parts of these sites are in flood zone 2.
• In addition STAs of Marlands Farm, Steamer Quay, Baltic Wharf, Copland Lane, and Meadowside, all indicate that at least parts of these sites are in flood zone 3.
• The Dairy Crest Site is in flood zone 3B, being a functional flood plain.
• This means that 11 of the 28 sites assessed are in flood zones, and 3 of these sites form part of the preferred options.

Before advancing any of these sites for development, detailed, site-specific flood risk assessments should have been undertaken to avoid the DPD being found to be unsound because of the lack of a robust and credible evidence base. They have not been done.

Indeed throughout the DPD it is apparent that decisions have been made which rely or poor or incomplete evidence: sites are advanced without thorough local traffic surveys being carried out (Bidwell, Riverside, Meadowside); sites are advanced without assessment of local need and audit of local provision(KEVICC re recreation and sporting facilities); Greenfield sites are advanced for housing development even though Government targets are for 60% of development on previously developed land – which suggests a lack of research. The entire DPD is undermined because so many decisions have been made with no sound evidence.

Without a site specific flood risk assessment it is impossible to be able to come to a reasonable conclusion as to what, for example, the effects of developing Dairy Crest, or Steamer Quay, or Bidwell, or Baltic Wharf, or KEVICC, or Meadowside might be on existing or proposed developments up river or in land, or whether or how such effects might be mitigated. These questions should have been posed, and answered satisfactorily, before any site (certainly in flood zone 3) made it to the preferred option stage.

The Choice of Preferred Option sites must be reassessed with climate change in mind. For example, the choice of Bidwell as an industrial site is questionable. It is a large undeveloped Greenfield site with poor access to the A38 because of the limitations of the A384. Creation of B1, B2 and B8 use will create more traffic and building development is likely to increase CO2 dramatically. B8 use is clearly inappropriate for an undeveloped Greenfield site in the middle of a village.

The DPD needs to address far more comprehensively the issue of climate change. The sentence, “Increasing importance must also be given to: Adapting to and mitigating the challenges of climate change” in 6.1 of the DPD is incredibly weak and is not underpinned with specific goals, targets or even explanation.

Climate change is real. The IPCC 2007 report says: “Fossil fuel combustion, with contributions from cement manufacture, is responsible for more than 75% of the increase in atmospheric CO2. Land use change accounts for a significant but smaller percentage. A 50% reduction in CO2 emissions would stabilise atmospheric CO2, but only for less than a decade. Complete elim¬ination of CO2 emissions is estimated to lead to a slow decrease in atmospheric CO2.” There are clear implications for the forward planning of our environment inherent in considering climate change, yet the DPD gives climate change scant regard.

To rectify this problem:

a) An assessment of the DPD, including the STA, in relation to climate change needs to be carried out.
b) The DPD must specifically identify the challenges of climate change and then identify how the proposals contained therein will help to adapt to, and mitigate against them. SHDC must recognise and accept that in order to achieve zero carbon building they must adopt radical changes.
c) Strategic Objectives must contain specific, measurable targets (see SHFoE submission re Soundness test 8).
d) Greenfield land take must be reduced to a minimum and in the light of increasing density of redevelopment, existing green spaces within the town need to be preserved to provide people with adequate recreational and sporting facilities and to protect biodiversity and nature conservation.
e) New development must conform to BREEAM excellent standard from 2008 or Code for Sustainable Housing Code 4 from 2008 rising to Code 6 before 2016. (Government target 2016)
f) Dairy Crest Site, Steamer Quay, Baltic Wharf: should be assessed especially re flood risk before further developments are proposed. Any development of the Dairy Crest site should be by an organisation committed to sustainability such as the Totnes Sustainable Business Park Project.

The capacity of all current employment land in the Totnes/Dartington Area needs to be assessed. The Webbers Yard Industrial estate is almost empty; its capacity needs to be properly assessed and then redevelopment could be carried out at appropriate densities for the site. Careful design could result in greatly increased capacity of a site (building upwards might almost double the area). A reorganisation, retrofitting and densification of existing sites could provide much more employment land and would be consistent with mitigating the challenges of climate change.

• Although the Adopted Core Strategy identifies a specific number of hectares of land as employment land, the DPD and the Core Strategy must be flexible enough to cope with changing circumstances, so a change of area allocation is possible.

Employment land should be measured in jobs created not hectares and SHDC should press for this change. Until then SHDC should consider the following:

1) There is no specific breakdown of what area is to be allocated to each category of employment use. This must be done. If an assessment of need in relation to each employment category has not been carried out, then this must be done.

2) A thorough assessment of current employment land capacity, which should have been carried out before this DPD got to the preferred options stage, must be carried out forthwith.

3) The need for additional employment land should be recalculated in the light of the above assessments.

The following should be considered:

4) Beacon Park, on the A384, is existing employment land. There is good access to the A38. Its capacity for B8 use should be assessed.
5) Babbage Road Industrial Estate has not been identified in the DPD and its capacity should be assessed with a view to sustainable redevelopment
6) Sheepfield site (27) could provide employment (B1) and housing. The Grove School could be relocated to the KEVICC lower School site where existing buildings could be retrofitted. The playing field must be retained for the schools’ and community use.
7) Riverside could provide for some mixed use (B1) and housing on the lower part of the site. The current housing proposals should be densified to significantly reduce Greenfield land take, and include open space and allotments. As there is already a primary school in Bridgetown, the primary school proposed site should be relocated to the KEVICC lower school site which is more central and is easily accessed by footpath and cycle path.
8) Brownfield sites are clearly important to reduce the Greenfield land take, but we must ensure that not every space is filled in. Increased densification means that it is vitally important to create as well as retain a variety of open space.
9) Sustainable transport links should be extended and joined together so that a fully permeable cycle network is created which gives cyclists and pedestrians priority over cars and other vehicles (filtered permeability). The existing cycle path network should join current and proposed developments, and the proposed new footbridge over the River Dart should contain a cycle path as well as access for wheelchair users. A clearly delineated, safe, cycle path should be created to continue from the Plains to Baltic Wharf. A cycle path from Follaton should be created to link to existing and proposed cycle networks