RESPONDING TO THE JOINT LOCAL PLAN FOR MODBURY The Joint Local Plan (JLP) is proposing an additional 80 homes for Modbury on three sites adjacent to the Bloor Homes development where 93 homes are currently under construction. Having undertaken some detailed research on the methodology for determining the 20 year requirement for new housing in the JLP the Neighbourhood Plan Group (NPG) and Modbury Parish Council (MPC) now consider the target for the South Hams to be unsound. The total for the District has been artificially increased by some 2,000 homes above the need for local population growth. Some of this is due to an arbitary “market uplift” (800)*, some to meet the demand for second homes (300) and some to make up for an under-supply in West Devon (900). * ‘Market uplift’ is an attempt to bring down house prices by creating an over-supply of new homes. The NPG and MPC believe that it is wrong for the South Hams to have to absorb such increases, based as they are on unsound evidence, and consider that the target of 80 additional homes for Modbury should be reduced to 40 for the following reasons: Modbury should not be required to absorb more housing because West Devon has not earmarked enough housing for its own natural growth and because of arbitary allowances for market uplifts and second homes. The transport infrastructure supporting the town is inadequate to take higher levels of growth. The local economy is unlikely to provide sufficient jobs to support higher numbers leading to increased commuting. The rate of growth being imposed on the town is greater than any time in its history and threatens to damage its historic core and overwhelm the community and existing services. The NPG and MPC also believe that the choice of the sites for development – all on the western fringe of the town – are the wrong ones for the following reasons, each of which is linked back to the JLP’s own strategic objectives (SO) and planning policies (TTV, DEV): It will further exacerbate the creation of a separate community outside the natural boundary of Modbury – a community which will look outwards rather than into the town. DEV20 – the quality of the relationship between the development and surrounding areas It will have a major impact on the surrounding countryside because the sites occupy elevated and visually exposed agricultural land. SO6.8 – The plan will preserve and enhance the beauty of the countryside SO10.2 – The plan will protect and manage the landscape TTV2 – Development will respect the character of the countryside TTV31 – Development will avoid the best and most versatile agricultural land There will be reduced diversity of the natural and built environment with new housing all being built in one area. DEV24 – Development will be located and designed to respect scenic quality and reinforce local distinctiveness Delivery in adjacent sites will make it less likely that development can be phased. TTV31 – Development will meet the essential, small scale local needs of the community and provide a sustainable solution It will be more difficult for residents’ needs to be met by walking to shops and facilities – so reduced sustainability and increasing congestion. SO6.6 – The plan will help to reduce the need to travel and provide more sustainable options SO10.3 – The plan will contribute to carbon reduction by reducing the need to travel SO11.6 – The plan will respond positively to the challenges of climate change DEV1 – Development should support good residential amenity, accessibility and bear in mind the wider health impacts DEV20 – Development should provide improved walking, cycling and public transport links around the town centre DEV31 – Locate new homes in places that can enable more walking, cycling and public transport connectivity alongside place-shaping objectives There will be a tendency for new residents to shop outside Modbury given the difficulty of parking and walking/carrying. TTV2 – Location of new housing where it will enhance or maintain the vitality of local communities It will affect the centre of gravity of the town, taking it away from the historic heart and departing from the balanced growth which characterised the last 500 years of Modbury’s development. SO10.6 – The plan will strengthen the links between rural settlements and the surrounding landscapes SO11.4 – The plan will provide high quality places which create a positive legacy for future generations and properly responds to the historic environment DEV20 – Development will have proper regard to the pattern of local settlements including their historic value and character It fails to comply with Modbury’s own emerging Neighbourhood Plan. SO6.2 – The plan will enable bottom-up planning processes in local communities by supporting neighbourhood plans DEV31 – The more strategic approach to neighbourhood plans is one of the tools the plan will use to achieve greater personal and community engagement Therefore, the NPG and MPC urge the inspector to amend the JLP to reduce the housing target to an additional 40 and approve the two sites on the eastern side of the town – east of Ayleston Park and east of Silverwell Park – for this development. If you agree with this assessment and want to see the plan changed to accord with the community’s previously expressed views then please use this template (especially the text in bold) to compose your response which should include your name(s) and address as a respondent. Deadline for responses is 26 April 2017: Online - www.plymswdevonplan.co.uk Post - Joint Local Plan Team, Floor 2, Ballard House, West Hoe Rd., Plymouth PL1 3BJ Modbury Neighbourhood Plan Group on behalf of Modbury Parish Council 14 April 2017
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