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In June 18 there were two new Applications from PCL acting for the Rew Family at Wolborough Barton. The time to act is again upon us, because comments (for and against) will not carry forward from the previous application.

 

Wolborough View2 Feb18

To Residents of Abbotskerswell, wider Teignbridge and surrounds

                                                                                                                                                 

TDC Planning References: Initial application17/01542/MAJ; New application 18/01276/MAJ;

Second new application18/01314/FUL

Abbotskerswell Parish Council - OBJECTIONS TO PCL APPLICATION 18/01276/MAJ

Background - PCL Planning (on behalf of the Rew family at Wolborough Barton) have submitted a new hybrid planning application for full approval for the conversion of the Wolborough Barton Farm building into a pub/bistro and outline permission for the development of the “Rolling Fields”, NA3. The new application is in almost all respects the same documentation as that which accompanied their application lodged with Teignbridge last year under reference 17/01542/MAJ.

In addition, PCL have just submitted an application for change of use of the farm buildings at Wolborough Barton to use as a pub/bistro/boutique 12-bed hotel (Application reference 18/01314/FUL). At present there are no supporting documents on the portal. You can view the application at: (If this does not open, copy & paste this link to your browser https://www.teignbridge.gov.uk/planning/forms/planning-application-details/?Type=Application&Refval=18/01276/MAJ)

Last month PCL Planning lodged an appeal against Teignbridge for non-determination of the original 2017 application (18/00035/NONDET). PCL have pushed for this to be heard in January 2019. TDC don't expect that it will happen before March/April next year. Input from all stakeholders, letters from residents, etc. will stand and will be considered during the appeal (which at this stage appears to be a desk study by the Planning Inspectorate; we will advise you of the process as soon as we are aware of the format).

Application 18/01276/MAJ: NEW APPLICATION. We believe that there is little or no difference between the old application 17/01542 and the new application; thus, all the reasons given in objecting last year can be resubmitted against the new application (Don’t forget to change the reference to 18/01276/MAJ).

Abbotskerswell Parish Council have summarised about 2,400 pages of information for you below and outline our comments which form the basis of our objections to the proposal which have been submitted to TDC.

NA3 Master Plan 2018

Your Submissions

PLEASE NOTE: the new application MUST be treated as a stand-alone application and if Residents of Teignbridge want their previous input to stand against 18/01276/MAJ, then you must write in againIt is the democratic/statutory right of the applicant to run a twin track application. It is suggested that as there is little substantive difference between last year and this year’s applications you could resubmit objections changing the date and reference number to that of the 2018 application. Otherwise copy and paste relevant parts onto a new letter (best submitted in pdf format to This email address is being protected from spambots. You need JavaScript enabled to view it.
 
Over the last twelve months Abbotskerswell Parish Councilhas submitted several letters expressing grave concerns about how PCL Planning’s Hybrid Application is being handled, the timing of the submission, and its content. The specific problems and grounds for objection are noted below under generic headings; these you can use to help with your own letters of objection (which can be submitted via the online form at : https://www.teignbridge.gov.uk/planning/forms/planning-comments/?Refval=18/01276/MAJ or by email (preferably in pdf) to This email address is being protected from spambots. You need JavaScript enabled to view it..
 
Please note that although the date for publicity expiry is the 3rdAugust, Teignbridge will accept submissions up to the eve of the Planning Committee meeting that determines this application – as yet no indication when this might be although the target date is the 21stSeptember.

 

Issues and Objections, plus Weaknesses and Unanswered Questions of the PCL Plan for NA3

Infrastructure – Link Road between A380 and Ogwell Cross

  • The link road between the A380 and A381 is essential and urgent and must be completed before any significant housing development takes place as detailed in the Devon County response to the 2017 application.

  • The application should be refused on the basis of undue delay because it indicates that the link road completion will only be once the third phase of development is underway (and even then with the proviso the other landowner is prepared to release the land and the final route agreed). This delay, which could stretch beyond 2027, would put an unacceptable strain on existing infrastructure causing significant disturbance, additional pollution and major inconvenience for residents of Newton Abbot. 

    Even PCL admit an increase in traffic of over 50% in Coach Road and nearly 200% in the Old Totnes Road; The Town can barely cope with current levels of traffic. PCL, from the comfort of their desktop study consider this increase is acceptable with regard to chemical pollutant but have not even considered noise pollution.

  • Currently, it is acknowledged that there is no agreement that the link road can be constructed across land owned by a third party.

  • The application should be refused given the inadequate detail of the carriageways and junctions; the absence of agreement on routing and timing. Projected traffic volumes indicate the link road design must enable unhindered passage. The proposed carriageway width of 6.1m is not sufficient unless parking is prohibited on its entire length.

  • The application proposes each dwelling will have one garage and one visitor space. Given that most households have at least two vehicles this provision will inevitably lead to private and commercial vehicles being parked on the estate roads (only 4.8m wide) so the design must take account of this to avoid congestion and parking disputes.

  • The application should be refused given the absence of sufficient detail on the treatment of highway run-off which must be treated utilising proven technology to ensure the continued integrity of the Site of Special Scientific Interest (SSSI), Wolborough Fen. To our knowledge SUDS systems currently cannot remove many of the chemicals produced by internal combustion engines. [SUDS =Sustainable Drainage Systems]

  • The street lighting proposals lack clarity and sufficient detail. They must demonstrate that there will be no impact on greater horseshoe bats and other light sensitive species.

  • An incomplete link road will mitigate against providing an economic bus service leading to more vehicles having to use the surrounding roads.

  • Development of 1275 houses from the western end will put additional and unsustainable strain on Coach Road, Priory Road, Stonemans Hill and the Old Totnes Road.

  • The Local Development Framework indicated an “avenue” styled southern link road which the application does not provide for over its length.

  • When complete, phases 1, 2 and 3 will generate the need for 318 primary and 191 secondary school places; under PCL proposals children will have to travel to existing schools in Newton Abbot and Ogwell. With the distances involved and the lack of suitable footpaths outside of the NA3 allocation, this is likely to generate a considerable additional volume of traffic at peak times; a situation that will exist until “phase 4” is completed.

  • The primary and secondary schools should be co-located nearer Decoy to share facilities, enable progression from primary to secondary education in a single site and be located further away from Canada Hill Primary School.

  • It is highly unlikely that the proposals will provide a “viable alternative to the private car”.

  • Further details of the traffic calming measures referred to in the application documents and how they will be  funded as well as the proposed traffic management measures for Coach Road and Decoy Road are required.

Access to the Development

  • Phase 1 will involve a new junction onto the A381 Totnes Road south of the Ogwell Cross roundabout and adjacent to the Denbury Road spur. This will be a dangerous exit given the volume and speed of traffic at that point.

  • Phase 2 access is on a right-angle bend of the Old Totnes Road near its junction with Stonemans Hill. It will also be close to a temporary access for construction vehicles to the Brunel Lodge site which was granted planning consent recently. The permanent entrance to Brunel Lodge is on the short stretch of road between the proposed new roundabout on the Old Totnes Road and the existing Ogwell Cross roundabout posing a further traffic issue for vehicles turning right towards the A381.

Traffic

  • The traffic assessment for the impact on travel within the Town is limited to nine junctions when there are cumulative effects of heavy traffic volumes on how well they work when taken in conjunction with other turnings, traffic lights and pedestrian crossings. It is often the case that vehicles cannot progress through one set of lights because another set further ahead is holding up the traffic.

  • Some of the data is out of date; the Penns Mount traffic data and the South Devon Link Road (SDLR) data are from 2015. New traffic surveys are required to fully assess the impact of the SDLR and the other housing developments underway around Newton Abbot.

Air Quality

  • The measurement locations identified in the Application do not include the most serious air quality area of Wolborough Street which will be heavily adversely impacted by the additional traffic flows, particularly if development begins from the western end of the NA3 allocation without the entire link road going in first.

Construction Traffic/Pinch Point Funding

  • Considerable public funding was given to improve Kingskerswell Road and provide access to NA3. Development must start at the eastern end of the site to avoid construction traffic having to pass through the Town or attempt shortcuts using the narrow country roads (Coach Road, Priory Road, Stonemans Hill etc.).

  • Figures cited in the application for traffic volumes using Coach Road are suspect as a Devon Highways survey conducted in 2009 showed higher volumes. Traffic volumes have increased considerably over the last decade.

  • A weight limit is required on Coach Road/Old Totnes Road except for access to properties on that road.

Water Services & Sewerage, Power Supply

  • What are the continuing cost implications of maintaining the SUDS systems on householders?

  • The statement that only 8% of the catchment (for Wolborough Fen) will be impermeable seems to be a low estimate that requires independent confirmation.

  • More detailed assessment is required on the impact of extensive earthworks associated with constructing the link road and erecting the buildings and how this will affect the water table and flows and water chemistry through aquifers, particularly as Wolborough Fen is fed from much of the development area.

  • The removal of part of Decoy Brake will further reduce the attenuation and purification provided by woodland.

  • The geologically unique “Rolling Fields” are underlain with sands and gravels which provide an effective filtration and attenuation facility for rainfall. The development will see a significant area become hard surfaced with roofs, drives and roads, which will impact on the rate of discharge and chemical composition of water into Wolborough Fen, a Site of Special Scientific Interest containing rare species and is the last remaining site of the greater fen-sedge Cladium mariscusin Devon. This site sensitivity demands proven methodologies and extensive survey work and results analysis, covering all field conditions, to determine whether Irreparable damage to this important site can be avoided

  • What long term SUDS management system will be put in place and who will meet the cost?

  • How will the efficacy any SUDS system be monitored over the long term (10+ years)?

  • The existing sewerage facilities, both transmission and treatment, are close to capacity and are unlikely to be able to cope with the additional load from 1275 houses (1575 when “phase 4” is complete) not to mention all the other developments around Newton Abbot (totalling over 6,000 new homes – 13,000more people).

  • The application is silent on the capacity of the mains water system to feed this development along with the other major developments in and around Newton Abbot. Coach Road (Victorian) water main has suffered four serious leaks, three requiring emergency repairs) this year.

Setting & Amenity

  • The setting of the historic listed St. Mary’s Church and the wider vista of Wolborough Conservation Area provide the last open space between the Town and Torbay which will be lost leading to excessive urban sprawl and is contrary to the recommendations in the Council’s recent Conservation Appraisal for Wolborough.

  • The substantial increase in population, likely to be some 3500 residents in Wolborough alone, will put an enormous strain on the already very widely used Green Flag Decoy Country Park possible jeopardising its current status and amenity. Its amenity value is overstretched already and the loss of peace, from noise generated by traffic travelling through Decoy Brake, will degrade the currently quiet woodland walks. This will not enhance public amenity.

  • Far from the claim that NA3 will connect the countryside with the Town, it will significantly damage the open space and through dust, noise and light pollution, have a much wider impact on the surrounding houses. There is a significant danger that from Kingsteignton to Torbay will become one enormous urban sprawl; bad for residents, disastrous for tourism.

  • Once houses are complete, at a density of 30 – 40 per hectare for all but a small parcel and ranging between 2 and 2.5 storeys, the visual impact on the Rolling Fields will be considerable with most of the green aspect severed from view, particularly from lower ground such as Decoy.

Environment & Biodiversity

  • Part of the western development area is already used as a mitigation site under a Stewardship agreement for Cirl Buntings in lieu of territory lost following construction of the SDLR. This area should continue to be allocated as such. The approach of using biodiversity offsetting means residents lose a population of birds in their local area and have to travel to newly designated reserves to hear and see them.

  • The development area impacts negatively on a strategic flyway for the South Hams Special Area of Conservation (SHSAC). The mitigation offered is mainly opinion and largely unsupported by current research.

  • PCL attempts to undermine Natural England’s longstanding and accepted planning guidance for the South Hams SAC (Currently subject to consultation on a redraft). PCL are planners NOT environmental scientists.

  • No detail is provided for long term monitoring and control of proposed mitigation measures.

  • The relevance of the SHSAC is dismissed when in fact the allocation area provides valuable inter-connecting greater horseshoe bat flyways between SHSAC roosts, designated and otherwise.

  • The removal of 1894 m of mature Devon hedgerows and 4 veteran oaks will further impact on bat flyways as well as destroying habitat for many other animals. Any newly planted hedges will take many years to mature into new habitat and existing flora and fauna using the current hedgerows will either die off or move away. We all lose.

  • The application identifies replacement hedgerow, which must be like for like Devon banks, but omits what effect this will have on wildlife during the long period of establishment.

  • The link road in particular and the layout of the three housing sites will cut across free movement of animals, fragment habitat and alter their feeding and breeding patterns.

  • The mitigation measures proposed for Wolborough Fen are not unanimously agreed upon. Four reports differ in their conclusions. The geology of the area and the efficacy of SUDS systems has not been sufficiently investigated to support PCL’s conclusions on mitigation.

Arboricultural Impact Assessment

  • The proposed route of the link road will see the destruction of 2.2 hectares of woodland and give potential for further damage to surrounding trees from emissions.

  • Removal of such an area of woodland will create increased risk of flooding around Decoy.

Employment

  • The principal additional employment land is located on the eastern side of the allocation and has not yet secured the agreement of the landowners.

  • Exeter is the main draw for employment and with the development of a large industrial area at Kennford this will only increase the out-commuting risking turning Newton Abbot into a dormitory town rather than a sustainable, self-supporting community.

  • There has been little growth in employment opportunities in Newton Abbot in recent years which suggests the claim that 129 (152 without 10% leakage) full time jobs is optimistic. (Because of a switch of two parcels of land from residential to employment designation reducing total housing to 1210 they have increased the estimate of jobs that will be created to 411). However, the Teignbridge Local Plan Five-Year Review estimates that 748 jobs have been created since 2014 and admit that there has been a lack of employment delivery and a loss of business sites to other uses. Compare this with the 5,900 jobs created in Exeter between 2013 and 2016 and the prospect of a further 2,500 plus new jobs following the completion of the new Lidl distribution centre and West Exe Park. 

  • Development of the western side first will require travel to work to be through the already heavily congested Town centre.

Local Education & Health Provision

  • Given the resulting increase in population there must be certainty about the provision of schools. The proposed site for a Primary School and the land notionally earmarked for a Secondary School would be better co-located to make use of shared facilities.

  • When schools are built adequate provision must be made for children to be dropped off and collected in safety and without causing parking problems and traffic congestion suffered by so many educational establishments.

  • The proposed site for the Primary School is close to Canada Hill and would be more sustainably located towards the centre of the development.

  • The average number of GPs per 1000 of population is .58 requiring two for NA3. Healthcare and Social Care provision in the area is already under significant pressure.

Footpaths/Pedestrian Access/Cycle Routes

  • The PCL “masterplan” indicates pedestrians accessing the site will use either a junction onto the A381 south of Ogwell Cross, the new road onto the Old Totnes Road or via Magazine Lane into Coach Road. There is an additional proposal to create a footpath into Stonemans Hill. The A381 has only intermittent footpaths making it impossible to walk in safety into Town via this route; to the south towards Abbotskerswell/Ipplepen there are no footpaths. Coach Road has no footpath for most of its length and is a narrow lane carrying a high volume of traffic. Stonemans Hill is also a lane with no provision for pedestrians. On-site footways and cycle paths may be adequate but the surrounding infrastructure is not.

  • Routes over Wolborough Hill are steep and challenging for anyone with mobility issues or pushing prams etc.

  • Cycleways and footpaths should not be shared space particularly given the topography of the site when cyclists could be travelling at speed downhill.

  • There is insufficient detail on how existing public footpaths will be maintained and enhanced.

Full Application for Hotel/Pub at Wolborough Barton (18/01314/FUL)

  • There must be a question of need given that the Queens Hotel is being converted into residential use because of non-viability.

  • The indicative redevelopment plans for the Cattle Market area of Newton Abbot includes a proposal to build an hotel which further brings into question the potential viability of a small hotel on the edge of Town with difficult access.

  • The access to the site is on a very narrow stretch of Coach Road, blind to the south west.

  • The increase in traffic generated by such a facility would put unacceptable additional pressure on Coach Road.

  • The application is silent on the longer-term use of the farmhouse (although we believe Mr Rew intends to remain in residence).

  • There appear to be two potential locations of a new farm, on the ridgeline on both sides of Stonemans Hill; this should be clarified and be subject to a further planning application.

  • For centuries St Mary’s has been sited in a quiet rural setting. Many locals cherish this aspect and visit to absorb its serenity or to pay their respects to their departed loved ones. The proposed development will have a detrimental effect.

Housing Supply

  • With the ongoing developments at Penns Mount, Whitehills and Houghton Barton, Buckland plus smaller sites at Brunel Lodge and the former Bishop Dunstan School along with windfalls, there is approaching nine years housing supply which begs the question whether a further 1275 homes is appropriate at this time.

  • Plan Teignbridge is a 20-year plan with 15 years to run, so with 8.58 years Land Supply, Government targets have been exceeded. The pace of Heart of Teignbridge new allocations should be conservative, cautious and further developments deferred until the 5-year review of the Local Plan is published for public consultation, debated and adopted by the Council.

  • Further, the Greater Exeter Strategic Plan, which was due to be published within a similar timeframe, has been delayed until mid-2019. As this will provide a much-needed and long overdue strategic overview which takes proper account of all factors impinging on the wider community, not just the District, including a possible “new Village” of up to 10,000 dwellings, the Wolborough development should be deferred until full details of these exercises are known. Excessive overprovisioning of land will only increase an excessive land bank.

  • Over-provisioning of dwellings may result in falling house prices, which superficially is an attractive proposition, but conversely this may force many first-time buyers on low incomes and others into negative equity and potential financial loss.

Viability

  • With the essential infrastructure for roads, sewerage etc. and the additional requirements for archaeological, environmental and mitigation assessments along with the topography of the site, is the development viable if it is to be designed and built to mandated high standards? What measures can be put in place to ensure planning conditions are not subsequently watered down on the grounds of viability.

  • With the current developments around Newton Abbot approved and underway, the development of NA3 at this time is likely to adversely affect the local housing market without bringing the benefit of increasing the stock of affordable homes.

  • PCL dismiss green and efficient energy sources leading to the properties having high running costs. This conclusion must be re-evaluated in the light of future carbon reduction targets.

  • What measures can be taken to avoid original and approved designs being diluted as has happened at Sherford? If the development cannot be guaranteed to proceed at the high standard envisaged in the Local Plan, should it proceed at all at this time?

  • A similar question of viability hangs over the capacity of the power supply to cope with all the developments in and around Newton Abbot, likely to result in over 30% increase in population.

Land Allocation

  • There are conflicting entries in the documents for the future use of land south of Coach Road between the allotments and Wolborough Barton Farm.

  • The PCL “masterplan” takes no account of the constraints on the site nor does it cover the entire allocation. A comprehensive masterplan is essential to helping ensure the development will be sustainable and does least harm.

Process

  • The bundle containing supporting documents, with amendments, amounts to close on 2,500 pages of repetitive information with little clarity enabling individuals to distinguish between documents relating to the outline and full application.

  • Much of the documentation is not in correct PDF textual format. They are rendered as images which is highly unusual PDF format and this disadvantages all consultees who wish to make specific textual references within their response.

  • Much of the content is repetitive so the excessive amount of documentation supporting the application confuses rather than enlightens and in places the information is contradictory.

  • The documents are not indexed, numbered or in some cases paginated, with crucial documents printed in extremely small font (6), resulting in readability problems for many people.

  • Many of the legends on plans are font 6 and illegible even when enlarged as definition is lost

  • Within the documents there does not appear to be any scheduling for the development and in particular, the provision of essential infrastructure

  • This application has been submitted before the Teignbridge Draft Development Framework Plan has been published and made available for public scrutiny

  • There has been no consultation on a Masterplan for NA3 Wolborough contrary to Technical note for Development Framework Plans for master planning the Strategic Site Allocations.

  • In the absence of an agreed Masterplan that has been subject to public scrutiny and the scale of the development (effectively a new “town” the size of Ashburton) it is unacceptable to determine so much of the detail, particularly for those areas where there are serious questions about conclusions drawn by PCL and the effectiveness of mitigation measures proposed by the Applicant, as Reserved Matters.

  • The ‘Masterplan’ for NA3 has not been subject to public consultation contrary to Teignbridge’s own published Technical note for Development Framework Plans for master planning the Strategic Site Allocations.

  • With only three quarters of the allocation covered by the “masterplan” it is impossible to effectively judge the impact of the NA3 development on the wider community.

  • The application should not be considered until all land use within the NA3 allocation is legally agreed with the landowners to avoid an incomplete development compromising the inclusion of necessary schools, medical services and crucially, the early completion of the link road.

  • The PCL application documents, minimising impacts and dismissing guidance and concerns of bodies such as Devon County Council, Natural England and Historic England, are largely based on PCL’s opinion rather than proven facts. Their conclusions and recommended mitigation measures, of which there is insufficient detail, must be subject to public scrutiny and examined for viability and veracity before Officers and Councillors can be expected to determine the application.

  • Separate applications are required for the two elements of this hybrid application and site-specific information relating to each of them must be presented to enable consultees, the public and other stakeholders to better appraise their individual merits.

  • All matters reserved bar access for the outline application will place an unreasonable burden on the Local Authority’s resources and make proper scrutiny by the Planning Committee much harder.

Weaknesses and Unanswered Questions of the PCL Plan for NA3

1. It is essential that the road through NA3 starts at the eastern end to give access to a better road system. TDC paid £500,000 to this end when the new Highway was established.  A second railway bridge will be needed to facilitate this link. Parking on the main through road through NA3 should be banned.

2. SUDS - can it be scientifically proved that there will be no harm caused to the Wolborough Fen SSSI?

3. There is a significant possibility that there will be broken sewage and/or water mains in Coach Road even without the NA3 development because of the existing volume and weight of traffic. We have had three bursts already this year.

4. There is no evidence, even from Natural England, that mitigation for Greater Horseshoe Bats (GHBs) works. We have tried to establish from Natural England if there is any evidence or scientific work that indicates successful mitigation.

5. In most houses both adults work. With 1250 houses this would suggest that 2500 jobs are needed. Is this covered in PCL's plan?

6. What about reducing travel to work distances, which the Local Plan set as a target. Will the jobs be at Exeter?

7. Will all houses be built with Solar Panels and have a high degree of energy efficient insulation? If not, why not?

8. In the process section why are mitigation measures placed as a reserved matter.  Two of the issues of most concern to local people are the GHBs and the SSSI.

9. 'Beyond all reasonable scientific doubt' was a phrase used in the Judgement re the GHBs (See below an extract from the Judgement). Natural England have accepted this as meeting their standard. This should also apply to the SSSI. Natural England are a Statutory Consultee whose advice should inform and direct the Competent Authority (Teignbridge).

10. The proposed development will have a very significant effect on the wellbeing of residents of Newton Abbot and people living in the new development. Wellbeing was a high priority in the Local Plan.

11. If NA3 is developed from the western end the traffic chaos caused will have a serious effect on the emergency services. This will add to the ever-increasing traffic chaos on the northern side of Newton Abbot.

12. This plan does not meet the visions and aspirations required by clause 150 of the National Planning Policy Framework, nor does it meet the consultation requirements of clause 155. (See below)

150 - Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities. Planning decisions must be taken in accordance with the development plan unless material considerations indicate otherwise.
155 - Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be proactively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.
 

13. NA3 should be designated as an Area of Great Landscape Value (AGLV) with the geologically unique Rolling Fields and providing the setting of St. Mary's Church - Historic England

 

Extract from Judgement of Lord Justice Underhill – Case No. C1/2015/0076

In essence, the argument seeking to quash the adoption of the Local Plan (that APC/WRA lost) was not regarding the protection of rare species in breach of the Habitats Directive, but the failure of TDC to produce adequate assessments before adopting the Local Plan in contravention of the requirements of the Habitats Directive. However, in his judgement in refusing leave to appeal (against the Judgement of The Honourable Mrs Justice Lang), Lord Justice Underhill noted the following: -

4. 1         Noted that “For some proposals, it will be necessary for a bespoke Greater Horseshoe Bat Mitigation Plan to be prepared, submitted and agreed prior to the grant of any planning permission.  Such plans will need to demonstrate with very high levels of certainty that there will be no adverse effect on the integrity of the South Hams SAC.”

6.            “A bespoke Greater Horseshoe Bat mitigation plan for [the site] must be submitted to and approved before planning permission will be granted. The plan must demonstrate how the site will be developed in order to sustain an adequate area of non-developed land as a functional part of the foraging area within the SAC sustenance zone and as part of a strategic flyway used by commuting Greater Horseshoe Bats associated with the South Hams SAC.  The plan must demonstrate that there will be no adverse effect on the SAC alone or in combination with other plans or projects.”

10.          It remains a requirement of the grant of planning permission that the developer can demonstrate that there will be no adverse effect on the site either as a result of his own development or (importantly) “in combination with other plans or projects” If he is unable to do so because that is impossible without a settlement-level plan of the type recommended in the supplementary report, then permission must be refused.


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