South Hams Friends of the Earth

SHDC will soon produce new DPDs relating to market towns and rural areas. The Totnes and Dartington DPD which was at the Preferred Option Stage has been shelved - we don't really know why - and a new DPD will be written which will be issued at the same time as DPDs for Dartmouth, Kingsbridge, Ivybridge and the Rural Areas. These DPDs are intended to allocate sites for employment land and housing and our concern is that any other local considerations will not be included. Below is SHFoE's response to the invitation to contribute to the potential content of the new DPDs. Sorry about the planning speak!

Comments on the potential general content of SHDC’s 5 new DPDs

The proposed new DPDs must form, with other documents, a comprehensive planning strategy. These DPDs represent the opportunity which exists no where else in the LDF to set locally specific planning objectives.

The Core Strategy states in Section 5: Spatial Strategy, paragraph 5.17:

“Apart from providing a focus for housing and employment development, the Area Centres and Local Centres should also develop their important role of supporting the diverse needs of their own communities and the surrounding hinterlands they serve.”

The same paragraph also states:

“Town Centre Zones will be identified in the appropriate settlement specific DPDs in association with more detailed policies”.

Therefore, a focus on site allocation is a meaningless planning strategy and it is certainly not a spatial plan. In order to be able to fulfil the Core Strategy’s Spatial Strategy the new DPDs need to provide detailed policies for each area settlement:

1. Planning must take into account not only the site allocations for housing and employment, it must also include detailed area specific strategic policies and targets, (and take into account any relevant Government Legislation since the adoption of the Core Strategy). These must include local policies on sustainable development, resource conservation, affordable housing need, flood risk and the effects of climate change, local infrastructure (especially in relation to schools, sustainable integrated transport systems) etc.
2. Dartmouth, Ivybridge, Kingsbridge and Totnes & Dartington are identified as Area Centres in the Core Strategy and so their DPDs must enable each to deliver the requirements of an Area Centre. These settlements have their own distinctive qualities recognised by the Core Strategy. The DPD for each settlement must reflect this and not merely allocate land.

In addition there must be a minimum requirement that:

3. Each new DPD must have detailed, area specific, Strategic Objectives which deliver the Core Strategy’s Strategic Policies, updated to incorporate new Government legislation, especially in relation to sustainable development, resource conservation, affordable housing, climate change, and infrastructure;
4. The DPD Strategic Objectives must recognise the individual requirements of each area, as identified in the Core Strategy, and allow for individual settlement development;
5. The Rural Areas DPD must enable the Local Centres therein to fulfil their role.

Finally:

PPS12 states: “Area action plans should be used when there is a need to provide the planning framework for areas where significant change or conservation is needed.”

6. Given the number of dwellings and amount of new employment land proposed for Totnes and Dartington in the Core strategy and the need for conservation, we suggest that the Totnes and Dartington Area Centre should be the subject of an Area Action Plan as a solution to the problems of a site allocation only DPD.

Kate Wilson