Fastglobe's planning application. Ref: 1271/23/OPA

• Closing date is June 22nd 2023
• Emails and letters must include the planning Application Reference Number in the subject line: Ref: 1271/23/OPA
• Emails to dm@swdevon.gov.uk
• Letters to Planning Dept, SHDC, Follaton House, Plymouth Road, Totnes, TQ9 5NE.
• Please DO NOT refer to ATMOS as objections should relate to the Fastglobe application being considered.

Using the Planning Portal.

• Click on: Comment on this application
• Enter your details
• In the dropdown box select Other or Planning Policies and Guidance before adding your comments.
  
  You will need to list reasons relevant to the council granting or refusing planning permission. See Reasons below
  ‍
• Please select  ‘OBJECT’ in Overall View
  If you email or write a letter please say clearly that you OBJECT.

Six reasons to object

1. LACK of Affordable Housing
   The application states it will abide by affordable housing numbers but expect to use Vacant Building credit, para 64 of NPPF to offset this. As it is in outline, no information is given on volumes so it is possible no affordable housing will be planned.
2. Inefficient Use of the land
   Underdevelopment of the site which should bring jobs and commerce to the town to replace the 160 jobs lost by closure of Dairy Crest. Circa 1100sqm of commercial space, when 6 times that could be accommodated.
3. Heritage
   Insufficient information to assess impact of development.
4. The Community Use of the Listed Brunel Building
   ‍No information given.
5. Ecology
   No baseline assessment other than trees to judge ecological impact.
6. Construction Management Plan
   No Plan provided.

Six Detailed Reasons to Object

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1&2. Affordable housing and inefficient use of land.

Choose a) or b)

• a) The amount of commercial space at 1100sq m. This must be viewed as an under delivery and inefficient use of the site without justification. This is contrary to the intent of the NPPF and para 125 c). 
  
  "Local planning authorities should refuse applications which they consider fail to makeefficient use of land, taking into account the policies in this Framework. ‍   
  
  “A minimum of at least 30 % on site affordable will be sought for all schemes of 11 or more dwellings.”  It is possible the stated intention to use Vacant Building Credit could remove any affordable homes dependant on how this interpreted. A continuing national issue due to the lack of guidance on interpretation.
  
  OR
  ‍
• b) The application does not indicate the volume of potential employment or training opportunities, and there is no level of affordable housing provision stated which should be in the region of 24 given the c 80 outlined. No justification for the housing mix proposed.
  
  Spatial Priority SP6  -  Spatial priorities for development in Totnes
  “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.

3. Heritage

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. No details of the works are given in the application.

The development must be considered against the relevant paragraphs of the `National Planning Policy Framework (NPPF)- specifically paragraphs 199-202  See extract at end of doc
‍“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.

4. The Community use of the Listed Brunel Building

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.

5. Ecology

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.

6. Construction Management Plan

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 Plan as required by the local validation checklist. Especially given the risk of contamination to the site and local waterways.