Totnes DPD response (old document)

The Totnes site allocation DPD was adopted in 2011. What follows is from the old SHFoE website. It’s here for information rather than instruction.


Specific comments on this DPD:
The comments which follow are just guidelines to which you can add your own comments. Remember if you use the form, each representation will need a separate sheet unless you are discussing a single issue in relation to all proposals, or a single proposal in relation to a number of issues.

Affordable Housing is SHDC’s stated top priority, and a priority in the local community, but nowhere in this document is there a commitment to achieving the 50% Affordable Housing as in the Affordable Housing DPD. There are also no targets which relate to the delivery of Affordable Housing or the delivery of infrastructure. The DPD objective TO1 to “ensure the current and future housing needs of Totnes are met, particularly affordable housing” is too general, could be applied anywhere (it’s used in the Dartmouth DPD) and not supported by the rest of the document. For example, some proposals refer to “including affordable housing”, others say “as much affordable housing as is viable”, others, including T5, T6, T7, T9 make no mention of affordable housing at all. This is inconsistent. The DPD is not effective in terms of clear objectives for affordable housing or how those objectives will be met. Specific local targets must be apparent and if it is foreseen that a site will not meet the 50% Affordable Housing targets the reasons for this must be explained.

T1 Baltic Wharf: Policy EC2.1 of PPS4 requires planning bodies to reflect the different location requirements of businesses and consider sustainable transport including water. Policy DP14 Protection of Employment Land, of SHDC’s recently examined Development Policies DPD protects marine employment sites. The Baltic wharf policy does adequately consider the potential of the waterside setting and so the content of the DPD is not justified by the evidence. At a push you could say it’s not consistent with national policy because sustainable transport hasn’t been fully considered in relation to water.

Baltic Wharf fails the justified test of soundness because the proposals do not represent the most appropriate strategy given the alternatives: the proposal calls for 150 dwellings on this site – houses can go anywhere but most marine employment needs to be near water. There is a risk of flooding on the site which might make it unsuitable for dwellings – especially vulnerable dwellings such as retirement communities – and car parking. There are more appropriate sites for housing than Baltic Wharf.

The proposal T2 KEVICC is split into different parts. The main area of concern is 110 homes on the Lower School Site in addition to the relocation of the Grove School. Provided the existing school buildings are retrofitted for the Grove School, there is no real objection to the school being relocated. However the distance from the existing Grove School to the new site means people will probably drive to the school thus increasing traffic along the A385. The will have an impact on SHDC’s Bridgetown Hill, Station Road, Ashburton Road Air Quality Management Area (AQMA)
An AQMA means that there is pollution (nitrogen dioxide) on these roads caused by traffic which Is serious enough to require monitoring. There are only three AQMAs in the South Hams: one is on the A38, one is near the A38 in Ivybridge and the other is in Totnes.

The sensible solution would be to site development away from the AQMA, but 5 sites in this DPD are beside and will have an adverse effect on the AQMA. Part of T2 KEVICC lower school, T5 Dartington Lane End field and the Lane End plantation; T6 Land at Ashburton Road and T8 Borough Park border the AQMA. T4 Dairy Crest will also have an impact on the AQMA. T1 Baltic Wharf with 150 houses will certainly have an effect as will T7 Riverside. These sites haven’t been considered in respect of their impact on the AQMA. Unless these developments are totally car free there will be an increase in traffic along the AQMA and a commensurate increase in pollution. Selection of all these sites is not good planning and is not justified; there are other sites in the town which could be used for development which would not add to the problems of the AQMA.

All the selected sites refer to “contribution to the A385 corridor management scheme”. It is not clear what the contributions will be or how they will be able to mitigate the consequences of so much house building. It is also not clear how each site can contribute positively to the A385 corridor management scheme, or whether contributions are to be realised via a 106 agreement or planning considerations. This is not effective.

T2 KEVICC lower school site and T8 Borough Park are not justified because the South Hams Public Space Strategy is not robust enough evidence of surplus open space to allow these sites to be built upon.

SHDC’s audit of public space assessed the type of open space, the number of hectares and calculated the hectares per 1,000 head of population across the whole South Hams District. The result is an average figure which does not reflect the actual amount of open space, especially public open space, available to people in specific towns and it does not reflect the amount of open space available in Totnes. It also does not recognise local needs which vary considerably from place to place. Totnes needs recreational land, allotments, formal and informal pitches and this would have been identified if an effective catchment area not an arbitrary catchment area had been identified. Open space, especially recreational space (as opposed to artificial pitches), will also be increasingly important as the effects of climate change increase and this has not been taken into account. An audit of different types of open space and an identification of need in Totnes should be carried out before open space can be built upon.

Building on The Borough Park and the KEVICC lower school site is not consistent with national policy and so is unsound. PPG17 states in paragraph 10: “Existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertaken which has clearly shown the open space or the buildings and land to be surplus to requirements. For open space, ‘surplus to requirements’ should include consideration of all the functions that open space can perform”.

The SHDC open space assessment does not show that the KEVICC playing field or the Borough Park are surplus to requirements. The part of T3 Totnes Central Area relating to the Grove School site playing field would also be covered by PPG17.

PPG17 states in paragraph 13. “Equally, development may provide the opportunity to exchange the use of one site for another to substitute for any loss of open space, or sports or recreational facility. The new land and facility should be at least as accessible to current and potential new users, and at least equivalent in terms of size, usefulness, attractiveness and quality. Wherever possible, the aim should be to achieve qualitative improvements to open spaces, sports and recreational facilities. Local authorities should use planning obligations or conditions to secure the exchange land, ensure any necessary works are undertaken and that the new facilities are capable of being maintained adequately through management and maintenance agreements”.

Development on the Borough Park is proposed in order to improve sports provision; however, this cannot be the case. Any development on the park will reduce the amount of public open space available and no replacement has been proposed. This is contrary to PPG17. Although developing the KEVICC lower school site is intended to improve sports provision, the attractiveness and recreational facility of, and the access to the new provision will be far worse that it is now which makes it contrary to PPG17.

Brownfield v Greenfield sites: SHDC has a stated aim of 60% development on Brownfield sites, but this DPD identifies too many Greenfield sites for development: Proposals T2, T5, T6, T7, T8, T9 are all Greenfield sites.

Most sites refer to development according with a “Masterplan” previously approved by the Council. Paragraph 6.6 clarifies this and says that the Masterplan will be prepared by “key stakeholders”. This sounds like landowners and developers making decisions. It is the planning authority’s duty to set the parameters which could then form the basis of a concept plan which should be arrived at with the involvement of local people. This plan needs to be drawn up in advance of any development. Site specific targets and objectives which are currently lacking in this DPD should be identified.

Development along the river Dart: a considerable amount of development is planned for beside the River Dart which raises concerns about the quality of the water environment and biodiversity. A level 2 flood risk assessment (SFRA2) has not been carried out on many of the sites – i.e. T2, T7, and T8 and there are no clear indications as to how the cumulative effect of riverside development will be managed. Not enough evidence has been produced to justify development.


If you are using the form you need to identify (in Q3) what you are concerned about in the DPD. If there is a specific paragraph you would like changed, then put its number in the “paragraph no” box. If you want to do respond to a proposal put its number in the “Proposal No” box. If you want to respond to something else – for example Appendix 1 Infrastructure Delivery Programme or Appendix 2 Monitoring Framework – you need to write that in the “other” box. SHDC advises that you need a different form for each representation you wish to make, but if you are commenting on one proposal or making the same point about many proposals you can use one form. As long at it is clear what you are referring to it doesn’t matter.

The proposal numbers are: T1 Baltic Wharf; T2 KEVICC which comprises the Sheepfield site, the lower school playing fields and the site earmarked for replacement playing fields; T3 Totnes central area which comprises the market square and civic hall, the southern area and the Grove school site;T4 Dairy Crest; T5 Dartington Lane End field and the Lane End plantation; T6 Land at Ashburton Road (next to T5) T7 Riverside (south of Culverdale in Bridgetown);T8 Borough Park; T9 Bourton Lane (Bridgetown)

You will be asked on the form and on the portal if the DPD is legally compliant and if the DPD is sound. It’s probably best (unless you’re really well up on planning issues) to tick yes for legally compliant. Tick “no” for soundness and decide which test your objection comes under. Read on!

There are three tests of soundness: is the DPD justified; effective; consistent with national policy. You must tick one box and you may tick more. The inspector who examines the DPD, will assume the DPD is sound unless there is evidence (in the form of responses to the DPD) to say otherwise. None of these tests ate easy to argue and SHDC is very good at providing supporting evidence for the decisions it makes. However, there are instances where it could be argued that the DPD fails each test of soundness.

1. Justified: means the DPD is founded on a robust and credible evidence base which involves evidence of community involvement; that the choices made in the plan are backed up by facts; that the DPD is the most appropriate strategy when considered against reasonable alternatives.

2. Effective: is decided by whether the DPD is deliverable: this includes whether there is sound infrastructure delivery planning, whether the DPD contains objectives and how these will be achieved.

3. Consistent with National Policy: means what it says. (The national policies referred to in this SHFoE document are mainly Planning Policy Statements or Planning Policy Guidance. They are identified as PPS and then a number or PPG and a number).