Local Plan – CoSERG response New!

CoSERG’s commentary on the Local Plan: Strategic Policies pre-submission version

1. A flawed approach: top-down and developer-led

1.1 The fundamental flaw of the Local Plan stems from the fact that it is a misnomer. It is neither ‘Local’, nor is it a ‘Plan’.

1.2 First, despite lip service paid by central government to ‘Localism’, this is a top-down and not a bottom-up strategy. It is imposed by the central state and willingly being delivered by its local agents. Moreover, the Council has not properly consulted those who ought to be the principal stakeholders in its plan – the people of Cornwall.

1.3 Second, ‘to plan’ implies identifying an appropriate end to which planning instruments are then applied. It is unclear from this strategy what the ends are. The ‘Local Plan’ claims it will deliver a ‘sustainable community strategy’ and ‘manage future development to ensure all communities in Cornwall have an appropriate balance of jobs, services, facilities and homes’ (p.6). This ill-defined and inchoate ‘vision’ leaves out all reference to those other communities that the strategy benefits. These include the externally based community of developers and construction companies, the internal community of landlords, estate agents, solicitors, architects and others who profit from house building, not to mention those communities currently living outside Cornwall but who will benefit from moving to Cornwall, either permanently or temporarily.

1.4 Furthermore, it is unclear how this vague ‘vision’ relates to a de-facto strategy as enumerated in the themes and objectives. These amount to little more than ‘business-as-usual’, continuing the policy regime of the past half-century and a strategy of housing and population-led growth. Moreover, policies contradict the stated objectives. This most glaringly occurs in the ‘presumption in favour of sustainable [sic] development’ of Policy 1, which would seem to be in tension with Objectives 4, 5, 6, 7, 8, 9 and 10 (p.11).

1.5 In short, the plan lacks a long-term vision. It fails properly to assess the long-term consequences of continuing a never-ending cycle of housing and population-led growth. It fails to provide evidence to justify its supposed economic benefits. It fails to enumerate the longer term costs of pursuing the sterile strategies of the last half-century. It fails to identify those particular aspects of the Cornish context which call for special consideration, instead applying one-size-fits-all policies. Finally, it is abysmally complacent about the major challenges which we as a society face in coming years because of a more generalised failure of policy-makers at all levels to address climate change.

1.6 In 2007 the then County Council commissioned a Quality of Life survey. Among other questions, this asked residents in Cornwall what they felt were the biggest threats to the natural environment. Almost two thirds identified housing development as one of the ‘greatest threats to the natural environment’ while over a half cited a growing population as another major threat. At the same time more than two thirds thought that the rising level of traffic was the third threat the environment faced. What therefore does it say about living in a democracy when these concerns are so bluntly dismissed in the Local Plan?

1.7 Rather amusingly, journalists on the UK-wide press have recently been pointing out how, without a Local Plan in place, local authorities ‘stand to lose detailed control over planning decisions … [becoming] … more vulnerable to property developers making questionable applications’ (for example Guardian, 27 Mar 2013). This is supposed to occur because of the policy of the National [sic] Planning Policy Framework (NPPF) and its ‘presumption in favour of sustainable development’. Yet Cornwall Council’s strategy, far from pointing out and trying to mitigate the inevitable consequences of a central government policy heavily weighted towards the private sector and the construction industry, explicitly and enthusiastically embraces it. Policy 1 states unequivocally that ‘we will work with applicants to find solutions which mean that proposals will be approved whenever possible’ [our italics] (p.11). It is difficult to see therefore how having this particular ‘Local Plan’ in place will make much difference, other than in the Council’s ability to negotiate and extract ‘planning gain’ from developers and re-direct some building from one part of Cornwall to another. People in Cornwall are already exposed to residential housing development applications at a per capita rate three times that of England. Those applications are then ten percentage points more likely to be accepted (Live tables P135, P136 at http://www.gov.uk). Such an enthusiastic commitment to the NPPF merely emphasises the close relationship between Council planners and developers and the Council’s commitment to a failed policy of housing and population-led growth (see 2.1 below).

1.8 The Council claims that consultation has been ‘extensive’ (p.5). This is questionable. There is mention of ‘community aspirations (pp.89, 93, 97, 99, 101, 102), although community demand for more ‘affordable housing’ hardly implies approval for the 60-80% that is not presently ‘affordable’. More critically, it is unclear where, when and how these ‘aspirations’ were expressed. Rounds of consultation have been low-key and scarcely user-friendly, with over-complicated web pages and difficult to use consultation portals. One could be forgiven for assuming these were likely to deter responses rather than encourage them. We would therefore suggest that, on the contrary, ‘consultation’ has been woefully inadequate. There has been no discernable attempt to stimulate a debate on the policy of housing and population-led growth and its consequences for the future of Cornwall.

1.9 We conclude that the Local Plan is a developer-led builders’ charter. The failure to define ‘sustainable’ anywhere in the document makes the use of this descriptor a rhetorical device designed to distract people from the consequences of the business-as-usual policies that are being imposed.

2. Shortcomings of the Plan: economic, environmental, cultural and technical

While its approach is fundamentally flawed, the Council’s centralised, top-down and unsustainable ‘Local Plan’ contains four specific shortcomings.

  • It fails to address the economic consequences of its policies, not heeding the lessons of the past half-century.
  • It is stunningly complacent about the necessity for action to reduce carbon emissions sufficiently to limit global warming to 2O centigrade.
  • It entirely ignores the cultural dimension of its housing and population-led growth policies. As a result it fails to ensure due care and protection for the Cornish as a national and regional minority group.
  • It applies policy-led conclusions rather than evidence-led policy. The data in the supporting ‘evidence base’ are far from robust or credible, as is claimed on page 3. On the contrary, much of it is either selective, misinterpreted, out of date or, on closer inspection, turns out to be groundless assertions.

2.1 An ahistorical cul-de-sac

2.1.1 The ‘Local Plan’ housing target of 42,250 (Policy 2) effectively condemns us to a continuation of the same policies pursued over the past 50 years. According to the Council’s own ‘evidence base’ this will cater for an additional population of up to 90,000 plus people in the next 20 years. While this conclusion is extremely questionable on the evidence of the past decade (see below), this not only continues current growth rates but would lead to a sharp increase in them. Already Cornwall’s population has grown since 1961 by around three times that of England, four times that of Wales and 28 times that of Scotland.

2.1.2 And yet such a relatively rapid growth, increasing the population by 190,000 (or nine Truros) in just 50 years, has not brought material ‘prosperity’. This ‘Local Plan’ admits that Cornwall ‘remains the second weakest economy’ in the UK, with wages 19% below the average and with median annual pay lagging behind by 16% (p.2). Moreover, it remains the only region eligible for the highest level of European Union grant aid, while wages and household income in Cornwall have lagged even further behind the UK average.

2.1.3 Similarly, at a lower spatial scale there is no evidence at all for a relationship between population growth and economic wellbeing. Indeed, if we compare population growth since 1961 with an index of multiple deprivation at the parish level (Census 2011) we discover a (weak) positive correlation of +0.026 rather than the strong positive correlation we should expect if the Council’s claims for the economic benefits of rapid population growth were valid.

2.1.4 One assertion that we meet regularly in the media from councillors and council officers is that housing creates jobs. In a similar fashion, the ‘Local Plan’ states that its policies will create ‘jobs and wealth’ (p.5) and ‘jobs and homes’ are gratuitously coupled together at other points in the text (pp. 13, 15, 50) to convey an impression that housing automatically creates jobs. This is correct at a superficial level as an increase in population will produce a multiplier effect on local demand (though a proportion will leak out of the local economy). But in a context of stable, slightly rising or in the longer run falling natural change, additional housing also attracts additional job-seekers. This key relationship between jobs and job-seekers is rarely articulated. Estimates of the number of jobs created by extra housing are basically guesswork and may misunderstand the mechanisms of job creation entirely.

2.1.5 Moreover, the ‘Plan’ implies that houses are built in response to demand but this laughably simplistic understanding of market mechanisms ignores the context of a housing market in Cornwall geared to encouraging external demand. It is perhaps counter-intuitive, but increasing supply in the context of an externally-oriented marketing framework may actually increase demand.

2.1.6 Inexplicably, this ‘Plan’ refuses to look backwards more than a decade, thus ignoring the clear lessons of the past half-century of rapid population growth. That experience would suggest the Council is conforming to Einstein’s definition of insanity: ‘doing the same thing over and over again and expecting different results’.

2.2 Climate change

2.2.1 One would be hard put to guess from the ‘Local Plan’ that the biggest challenge facing us on a global scale is climate change. As governments fail to confront this issue, paralysed by a combination of corporate lobbying and democratic failure of will, we rush headlong towards the point of no return. The stresses are becoming ever more obvious – extreme weather patterns, mass extinctions of wildlife, declining bird populations, threats to the honeybee, diminishing biodiversity. On a less apocalyptic scale here in Cornwall we experience growing congestion, a mounting litter problem, increasing difficulties in attaining peace and solitude.

2.2.2 Radical action is required. But all we are offered is ‘business as usual’. Even though business as usual is carrying us to disaster. This was recognised in Cornwall Council’s own environmental evidence report of 2010. That concluded that ‘population growth and the associated growth in housing and development are likely to increase pressure on the environment’. Yet Cornwall Council has chosen to ignore its own report, which pointed out how the ‘ecological footprint of the area’ was already well above a level of resource use considered to be ‘sustainable’. It is therefore difficult to see how the Council can define continuing to pile people into Cornwall as ‘sustainable’.

2.2.3 The UN Organisation for Trade and Development (UNCTAD) looked at what would be necessary to hold global warming below 2o centigrade, the point at which unpredictable feedback is in danger of triggering runaway climate change. It established that we have be a staggering 99.2% more efficient in our use of carbon by 2050 (Ulrich Hoffmann, Some reflections on climate change, green growth illusions and development space, Geneva, 2011).

2.2.4 The ‘Local Plan’ ignores this evidence and instead blithely pursues unsustainable growth that locks us, on a local scale, into the behaviour that produces irreversible climate change. From 205 to 2010 carbon emissions per capita in Cornwall fell by 11%. This sounds encouraging but we need an annual fall of something like 11% to meet the UNCTAD estimate. And of course, because our population is rising by 6-7% every decade, the total fall was actually only 9% from 2005 to 2010, nothing near that required. Given this ominous scenario, the precautionary principle needs to be reactivated. If we are to play our part in combating destructive climate change we have to reduce our profligate levels of housing and population growth. And quickly.

2.2.5 Cornwall has the opportunity to lead the way in green technology and greening our society. Wind power is the quickest, safest, most efficient, and most potentially open to community-scale ownership (Andrew Simms, Cancel the apocalypse: the new path to prosperity, London, 2013, pp.259-62 and 278-79). And Cornwall is supremely well placed to access a large proportion of the 40% of European wind energy that the British Isles enjoy. We could be self-sufficient in clean energy within a generation. Yet Policy 15 (p.32) is woefully weak and insufficient to encourage the large expansion of wind power that is urgently required.

2.3 The Cornish Question

2.3.1 If the ‘Local Plan’ and its central policy of business-as-usual housing and population-led growth is inherently unsustainable environmentally, it has long been pointed out that it is unsustainable culturally (for example, see CoSERG, Cornwall at the Crossroads, 1989). Mass in-migration since the 1960s, combined with a net out-migration of the native population, has steadily reduced the proportion of native Cornish in the population from somewhere near 80% in the 1950s to around 40% nowadays. While the Council masks the unsustainable environmental consequences of its plan in a rhetoric of greenwash, its attitude towards the Cornish question is, shamefully, to ignore it entirely.

2.3.2 Cornwall is home to one of the indigenous peoples of these islands, although one could be forgiven for not realising this when reading the plan documentation. Cornwall Council has a special duty of responsibility to maintain this people as a recognisable and self-confident group. Indeed, it signed up to the Framework Charter for the Protection of National Minorities. Yet, Article 16 of this states that ‘All parties shall refrain from measures which alter the proportions of the population in areas inhabited by persons belonging to national minorities’. Continuing a strategy of housing and population-led growth flatly contradicts this article.

2.3.3 The ‘Local Plan’ remains dumb when it comes to the status of the Cornish and fails to examine properly the implications of its policies for the Cornish people. In fact, the phrase ‘Cornish people’ does not appear once in the 152 pages of this document, while ‘Cornish culture’ is mentioned just once, in relation to the Bude CNA (p.116). This is despite mounting evidence (see PLASC surveys and the national identity question of the 2011 Census) for a rising subjective sense of Cornishness among the population over the past couple of decades. This presents an opportunity to reposition Cornwall as a European region but this opportunity is being undermined by the unambitious agenda of the current plan.

2.4 Rickety data

2.4.1 The ‘Local Plan’ is supposed to be based on ‘robust and credible’ evidence (p.3). However, the data it employs turn out to be rickety rather than robust. We present here merely a selection of this questionable data.

2.4.2 In fact, very little hard evidence is provided at all in the Local Plan Strategic Policies document itself. For instance, the need for 42,250 houses is briefly summarised as ‘we must plan for the housing needs of our future communities’ (p.22).

2.4.3 This fails to specify those ‘future communities’. First, there is the presently residing community in Cornwall. We estimate that, on the basis of the recent slowdown in the mean household size, this community will require at most an extra 3,500-4,000 houses over the plan period. Then there is that community not yet resident in Cornwall but who will migrate to Cornwall over the course of the plan period. This will require another approximate 23,000 houses. But then there is a further community the Council does not care to mention. This is the community that will remain resident outside Cornwall but occasionally visit to stay in their second (or third etc) homes. Over the ten years from 2001 to 2011 approximately 18,000 of the additional houses went to this third community. While the Council rightly focuses on the need for affordable homes in its ‘plan’, it fails to balance this by making it explicit that many of the 42,250 houses proposed are required to meet the growing demand for second homes and holiday lets. Policies 6-11 and 13-14 relating to housing therefore require supplementing by a policy on second homes and holiday lets, the lack of which is a startling hiatus of the ‘Plan’, given their important role as a component of the housing target.

2.4.4 Furthermore, the Council is over-reliant on the confused consultancy work of Peter Brett Associates, for example in its ‘Housing Requirements Cornwall October 2012’. This document

  • admits that the Census results seriously undermine their earlier projections but then resort to precisely those projections
  • continues to employ the ONS 2008-base projection in preference to the more recent 2010-base projection
  • notes correctly that ONS projections have consistently overestimated the actual population growth in Cornwall but fails to amend its calculations in the light of that observation
  • asserts that MHS will fall to 2.1 by 2030 from its current 2.272 despite a reduction of only 0.015 in the ten years 2001-11
  • claims that the population will grow by 97,900 in the 19 years to 2030, despite the fact that it only grew by 63,000 in the 20 years previous to 2011 and that the long-term tend of population growth is downwards
  • maintains that the annual population growth rate in the 2000s was 3,920, whereas the Census clearly shows it to have actually been 3,200.

2.4.5 The planners are also cavalier with the demographic data. They assert, in their ‘Population and Household Change Update, version2, March 2013’, that the total resident population in June 2010 was 537,500. In reality the Census of April 2011, released in the summer of 2012, shows it was 532,400. This is just one example where this ‘update’ refuses to consider the implications of a changing demographic regime in the 2000s, when compared with the 1990s. Its conclusions that ‘the population of Cornwall is predicted to rise by 17% over the next 20 years and the number of households by 25%’ is completely unsupported by the evidence. To repeat, the latter show a long-term declining rate of population growth since the 1970s and a shorter term decline in household formation since the 1990s.

2.4.6 The Council employs the HomeChoice Register as an over-simplistic surrogate for housing need. Other measures, for example overcrowding by the ONS definition, or the change in the number of people living in caravans or other temporary accommodation, indicate that levels of housing stress in Cornwall are relatively no higher than in areas of south west England. Furthermore, they are a good deal lower than in Bristol or Bournemouth, both of which have had lower pro rata housing targets accepted by government inspectors.

2.4.7 Often, no evidence is provided at all to back up subjective assertions. For instance, it is claimed in Policy 3 that population growth will ‘promote vibrant local communities’ (p.14). No evidence at all is offered in support of this outrageous claim. It runs counter to the conclusions of academics at Sheffield university who in 2008 found that ‘high levels of geographical mobility were associated with social fragmentation, with breakdown of trust and increasing levels of loneliness’ (http://sasi.group.shef.ac.uk/research/changingUK.html).

2.4.8 We can only conclude that the so-called ‘evidence base’ is being used to justify earlier political decisions rather than to inform those decisions. The use of data by the Council looks suspiciously like policy-based evidence. It’s a smokescreen of data designed to deceive, to give a technical veneer to questionable policy decisions that have been subjected to minimal public debate. The way the evidence is utilised shifts that minimal discussion onto safer and less threatening ground for those set to make a large amount of money from the ongoing Cornish building boom. It’s part of a wider strategy of ‘perception management’ pervading this ‘plan’, a classic example of a self-interested manipulation of reality in order to distract from the true purpose of the exercise.

2.4.9 Our own data suggest that, in order to continue to meet the likely demand from in-migrants and assuming no change in policy, the latest evidence available suggests a housing target of 29,000 (see CoSERG Local Plan Briefing paper 1, January 2013). This should replace the 42,250 target of Policy 2.

2.4.10 In addition, the allocation of housing appears to have been arrived at by a process more akin to horse-trading than strategic planning. The distribution determined at the meeting of the full council in February 2013 was driven by the parochial pro or anti-building politics of local councillors rather than by strategic planning rationale. CoSERG proposes that, if local needs are as important as the Council asserts, then this should be the sole basis for the geographical distribution of housing, providing us with the distribution in the Appendix.

3. A fair planning deal for Cornwall

3.1 The ‘Local Plan’ merely legitimates the population and housing-led growth we have suffered since the 1960s. It fails to establish the longer term consequences of this approach – that it locks us into unsustainable housing growth that will produce a resident population of at least 850,000 by 2100 and that a large proportion of the building is aimed at expanding the second home/holiday let sector. It fails to assess the success or failure of this policy in the light of our experience of the past 50 years. It fails to confront the fact that in Cornwall we have to build over more of our countryside in relation to population growth than elsewhere in the British Isles. Thus, in England from 2001-11 for every extra 1,000 people 377 houses were built. In Wales this figure was 517 houses. Yet in Cornwall for every 1,000 rise in the population we had to build 770 houses. We are paying up to twice the environmental price for population growth, a cost that is unsustainable.

3.2 In order to work towards a fairer planning deal for Cornwall and parity in planning with the other nations of the UK the Local Plan needs to be

  • more inclusive. It must recognise and incorporate the Cornish dimension in order to argue for long overdue special treatment
  • more honest. If we are unable to plan properly for our communities, our culture and our environment, then the Council should openly and transparently identify those constraints within which it operates. The contextual difficulties of an imposed, centralised planning framework and the limits of a narrow, neo-liberal, market-led housing policy regime should be spelt out
  • more ambitious. The plan could set out possible longer-term policies that might help us escape the dead-end of endless housing and population-led growth that has failed us since the 1960s. For example, these might include the desirability of
  • a tourist tax such as that widely levied by our neighbours in Brittany
  • doubling the council tax on second homes
  • a 100% affordable homes policy linked to a policy of new building only for local need

3.3 In short, this ‘Local Plan’ is unfit for purpose. Unfortunately, it does nothing to establish the contingency planning required for an uncertain world. Unpredictable climate change, resource depletion, environmental and cultural stress all demand a newer, more radical approach and not the old business-as-usual policies of suburban residential communities distanced from places of work, consumption and leisure and linked by private motorised transport. Here is a chance for the Council to lead a debate about the kind of Cornwall we could build. But it’s an opportunity it sadly spurns.

Cornish Social and Economic Research Group, April 2013

Appendix: revised housing distribution


Community Network Area

Houses 2010-30

West Penwith Penzance




Hayle & St Ives Hayle


  St Ives




Helston & Lizard Helston




Camborne, Pool, Illogan, Redruth Camborne-Redruth




Falmouth & Penryn Falmouth & Penryn




Truro & Roseland Truro/Kenwyn




St Agnes & Perranporth


Newquay & St Columb Newquay




St Austell St Austell




S Blazey, Lostwithiel & Fowey


China Clay


Wadebridge & Padstow Wadebridge




Bodmin Bodmin






Bude Bude-Stratton




Launceston Launceston




Liskeard & Looe Liskeard






Gateway Saltash









local people;[We question that eco-communities ‘protect the best agricultural land] and

Options that focus additional new growth in Bodmin and Saltash as a way of providing further local investment in key infrastructure.

2.1 Sustainable development is a global issue. Locally it is about creating a better quality of life for everyone, now and for generations to come. We have to recognise that our economy, environment and social wellbeing are all interconnected. In Cornwall we believe we should focus on what can make the most difference.   It is an industrialised world, we recognise this and aim to adapt positively to it.

2.2 We are a part of it, not apart from it. [Indeed.  Which is why we need to adopt a steady state population scenario and create a Cornwall, which is an exemplar for sustainability].

2.3 Our key challenge will be to overcome widespread deprivation and support the economic and housing growth needed to meet the current and future needs of our communities [But much of the housing growth is not to meet the needs of our communities].   in a way that protects and enhances the essential environmental and cultural assets of Cornwall. This is about managing development in a way that allows us to be resilient in the face of significant changes over the long term, whether they are social or economic factors or climate change challenges. [Resilience will come from a stable population, which has adopted a more sustainable lifestyle].

2.4 The implications of climate change and peak oil also require a pro-active response in a way that limits future harm but also optimises the opportunities for Cornwall. In the future there is likely to be less ability to rely on fossil fuels and this will impact on the way we live. [We need therefore to plan for this and not create an infrastructure which is car dependent and encourages car use].

2.5 This is a serious challenge to communities. We can help to achieve this by supporting development that helps communities to become more economically and socially sustainable. [It is, therefore we need to be serious in adopting appropriate measures].

2.6 We must plan in a way that reduces both the emissions that contribute to climate change and the consumption of finite natural resources. This will be by allowing development where there are options for travel other than just the private car, [Need to actively reduce car use.  That cannot be achieved by giving options.  The default use will be by car]. by supporting new models of service delivery in rural areas, and using buildings that are energy and water efficient through carbon neutral design.

2.7 We will continue to provide for growth in economic productivity, especially where there are concentrations of deprivation, and focus on growth in sustainable businesses. We are in a unique position to maximise our opportunities in marine industries and renewable energies and technologies. [Agreed].

2.8 We will seek to meet the needs of communities in terms of homes and access to facilities and reduce the need to travel. [Need to reduce travel].

2.9 We will safeguard vital environmental assets such as water and air quality as well as nationally important landscapes, to ensure they are here for future generations. We will enable our distinctive environmental and cultural character to evolve without losing what makes Cornwall a special place.

A. Sustainable Development

We will promote development that recognises the global context and helps to optimise what we can achieve for it.

It should;

One comment on “Local Plan – CoSERG response New!

  1. […] the housing figure (47,500 houses) projected by Cornwall’s ‘Local Plan’ is more about appeasing the housing targets of central government (Eric Pickles) than any form of […]

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