Response of the Dartmoor Society to DNPA’s “Development Management and Delivery Development Plan Document, Consultation Draft July 2011”

General comment

In the Introduction to this document of 193 pages, paragraph 1.1.2 states ‘The DMD provides the more detailed policies that are needed to supplement the strategic policies in the Core Strategy Development Plan Document’.

In our Newsletter 35, June 2009 we noted that ‘It is slightly disconcerting to be told that somehow the Core Strategy and Management Plan (to which very significant resources have been applied) are not sufficient in themselves to guide the decision-makers, but we must welcome the principle of more detailed policies being developed in some areas of management.’

It would now seem that our cautious optimism was misplaced as, apart from its inclusion of Settlement Maps, there is little to distinguish this document from the Core Strategy. The consequence is that we now have a second layer of policies, not clearly distinguishable from each other, as well as a third layer of policies in the DNPA Management Plan. This is totally unnecessary bureaucracy (imposed by Government) and a patently obvious waste of resources when one policy document should suffice for all three.

In May 2009 we sent very specific comments to DNPA on some of the sixty-nine Topics included for discussion in the draft DMD document, plus comment on other issues. Our comments are published in our Newsletter 36, October 2009, 7–10.

It is disappointing that scrutiny of the present document reveals that most of the Dartmoor Society’s comments of May 2009 have been ignored, without any opportunity for discussion. There are two significant exceptions where our views have been supported, at least partially – a) DMD 28 Replacement Dwellings in the countryside – this gives greater control over replacement dwellings. b) DMD 31 Low Impact dwellings in the Countryside  – this is the first DNPA policy to recognise the potential benefit of ‘alternative’ forms of dwelling, and has relevance to the Steward Wood Community whom we have consistently supported in the face of aggressive opposition from DNPA.

The Settlement Maps, which in principle are a valuable addition, are actually disappointingly bland. Some show nothing at all apart from the layout of the settlement. This is a missed opportunity – they should show, for example, all those buildings which are statutorily listed, the location of all known archaeological features recorded on the HER, and the presence of open space and gardens, plus significant natural features such as trees covered by Tree Preservation Orders. Some simple colour coding would enable such information to be clearly presented. Without such information, the parish community and the lay person is little the wiser about what is known and protected in their place.

Many of the proposed policies are stating the obvious, given that national parks  are ‘confirmed by Government as having the highest status of protection in relation to landscape and scenic beauty’ (para 2.1.4). Somewhat worryingly, in the same paragraph ‘conservation of wildlife and the cultural heritage’ appear to be given a lesser status as ‘also important considerations’.
The more specific policies (DMD17–DMD31) are the most useful ones.

The successful outcome of all policies depends on the dissemination of sound information and the constant training of both officers and members of DNPA.

Detailed comment (numbers are taken from the DMD document)

2.4 Military related development

It is high time that DNPA recognised and stated that the current  management of the Dartmoor Training Area is not ‘in conflict with national park purposes’ and indeed makes a positive contribution to many of them.

2.7 National Park landscape

Core Strategic Aim – Landscape Evolution – the phrase ‘archaeological qualities’ is a strange one. Perhaps ‘tangible presence of the past’ would be better.

2.7.2 ‘drivers of future landscape change’ – there should be a statement in this paragraph about the negative influence of increasing population pressure and the increasing consumption of resources.

2.8.4 Moor and Heath of Conservation Importance –  the ‘conservation importance’ of Moor and Heath needs to be defined/expressed more fully – ‘natural beauty’ is not a sufficient description to justify conservation alone and there needs to be inclusion of the cultural landscape.

2.8.6 Orchards – the fact that only 76ha of orchards survive (780 separate orchards existed within DNP in 1960) should be a matter of major concern and there should be a strong policy to actively encourage their renovation/recreation.

2.9. Built Environment and 2.10 Historic Built Environment

There is much mention of ‘heritage assets’ (‘not designated but which have heritage value and which are therefore a material planning consideration’) arising out of the Government PPS5 – Planning for the Historic Environment. While the concept has some merit, DNPA has for many years been notoriously bad at giving non-designated features of archaeological or historic interest due consideration when giving advice on, or taking, development control decisions. Policies DMD (iv), DMD9, DMD10 and DMD12 and paras 2.10.2.–2.10.6 and 2.10.9 have a hollow ring to them in view of the recent fate of historic buildings within the Conservation Area of Princetown, of Yellowmeade Farm,  of a granite barn at Two Bridges Hotel, and of Mount Pleasant Farm, Murchington, besides numerous other sites. It is good to have a policy in place, but it will have no effect unless officers and members are constantly trained and informed about new data and ideas relating to the historic environment.

In particular, there needs to be a policy statement specifically relating to 20th century buildings and their importance in architectural, historical and social terms, as they are the buildings often most at risk through a misplaced assumption that somehow they are of lesser importance than older buildings.

Para 2.10.6 – mention of ‘Boulton & Paul’ needs expanding such as ‘Boulton & Paul bungalows of the early 20th century’.

2.10.16, line 1 – add ‘or heritage asset’ after ‘listed building’ as many heritage assets are not listed.

2.11 Archaeology

This is not a clearly written section, and contains repetition. There needs to be a clearer statement about the extent and time-frame of archaeology on Dartmoor, including mention of 20th century features such as industrial and wartime sites. Is the correct terminology ‘Scheduled Monument’ or ’Scheduled Ancient Monument’?  The former seems increasingly used (and is used in the Ancient Monuments & Archaeological Areas Act 1979), so why is the term ‘ancient monument’ used in the text?

We remain critical of the concept of PALs (Premier Archaeological Landscapes), claimed to be of ‘international importance’ (2.11.2), as an inappropriate (and ineffective) management tool of open moorland or moorland newtakes because they create a hierarchy of value which implies that non-PAL areas are somehow less important. Para 2.11.3 reveals a very muddled and unsatisfactory state of affairs. What is needed is a strong statement giving an overall designation for all open moorland, moorland newtakes and access land as ‘culturally significant’ with a presumption against any development.

Para 2.11.4 ‘The skeleton of the present day enclosed landscape is of some antiquity and contains many archaeological sites’ is a very odd sentence, and needs rewriting. What exactly is meant by ‘skeleton’  and ‘some antiquity’ in this context?

2.12 Biodiversity and geological conservation

Figure 2 – Strategic Nature Areas – this map and its key are curious, and needs careful checking. Much Woodland seems to be missing from it, and much of what is shown as ‘Neutral Grassland’ is surely Woodland? The heart sinks at yet another designation ‘Strategic Nature Area’.

2.14.4, line 27 Renewable energy – add ‘and archaeological’ after ‘ecological’.
DMD21 – Telecommunications Development. The final paragraph of this policy states that a ‘condition will be applied requiring the removal of all structures and the reinstatement of the site if the development becomes redundant’. This should be deleted as such a policy is in conflict with good archaeological management practice of leaving at least the foundations of any abandoned structure. It is specially important in relation to modern structures which are easily labelled as ‘eyesores’ once abandoned and yet have an important story to tell, and are silent historic witnesses once abandoned. A good example of management has recently been implemented by Sibelco UK relating to modern clayworking structures south of Cadover Bridge (see ‘In Focus’ in Dartmoor Online, Autumn 2011 –

If such a condition had been applied to Dartmoor in the past we would have no archaeology left at all!

2.20 Housing

This must be considered one of the most important issues, and more data is needed.

2.20.6 Housing provision – There needs to be a Table showing the numbers of dwellings built and permissions given in the period 1996–2011 (this corresponds to the Devon County Structure Plan period for which there was a ‘target’ of 800 new dwellings within that 15-year period). The ‘target’ figure has been greatly exceeded and there needs to be a statement about this in the present document. The ‘indicative level’ of 50 units per year 2006-2026 also needs context, including the fact that in the two-year period 2006-2008  permissions for 247 new dwellings had already been given (see Newsletter 36 p.9).

2.20.11 Definition of ‘local people’ – Consideration should be given to including ‘essential service providers’ under the definition of ‘local people’.

2.20.19 ‘larger cohorts’ is a strange expression.

2.20.22 Domestic gardens – These should not be defined as ‘previously developed land’ but should be redefined as ‘open space of wildlife, cultural, social and visual importance’.

2.20.25 and DMD25 – Extensions – There should be a policy presumption against extensions as they diminish the stock of smaller dwellings. Permitted Development Rights should be removed within Dartmoor National Park.

2.20.28 and DMD28 – Replacement dwellings in the countryside – We welcome the stronger protective statements here, including the removal of Permitted Development Rights, but it would be helpful to reinforce them by stressing the importance of many 20th century buildings which are often seen as candidates for replacement.

2.20.31 and DMD31 – low impact dwellings in the countryside – We welcome this new approach to low impact dwellings but the phrase about restoration of the site to its former condition when occupation ceases (para 2.20.31, lines 16-18) should be deleted for the reasons stated above (DMD21).

2.24 Public conveniences

We feel there should be a policy about the desirability of having public conveniences in heavily-used recreational areas e.g. Cadover Bridge.

Part 3 – Settlement Policies and Proposals

3.2 Ashburton

There is no evidence to support the specific date of 1285. We suggest deletion of ‘since 1285’.

3.2.6 Stannary Town – The prosperity of the tin industry in Ashburton actually peaked in the first half of the 16th century, not the end of the 15th century.

3.4 Chagford

3.4.8 Stannary Town – In 1305 Chagford was confirmed as a coinage/stannary town. It had existed as a coinage town before then.

There are extensive ancient tinworks in Biera Wood which is shown on the east of the map p.97 – this should be mentioned in addition to Bellacouch Meadow (which is not shown on the map, and should be).

3.5 Horrabridge

3.5.3 There is no evidence that Horrabridge was established in the 14th century – it will have existed long before then as a settlement. Mention should be made of the important evidence of medieval and later tinworking at Fillace Park, linked to Furzehill mine, and to Wheal Franco which was one of the most important copper mines on west Dartmoor.

3.5.4 ‘Inappropriate development’ – DNPA needs to recognise that this development was approved by DNPA!

3.7 Princetown

More than any other Dartmoor settlement, Princetown has suffered a considerable loss of historic fabric in recent years through demolition and neglect of key 19th century and Edwardian buildings within the Conservation Area! The most notable recent casualties have been Morwenna/Stoneycliffe House and Bolts Stores, but include the Town Hall (designed by Richardson & Gill) and many other structures.

Thus the statement that the Duchy Square Centre for Creativity has ‘improved the character and appearance of the village centre’ rings very hollowly, as does much of para 3.7.5, especially the claim that the Conservation Area is ‘an important asset in its tourist appeal’, as well as the claim that there has been ‘conservation and enhancement of heritage assets’ and that (3.7.7) Princetown’s ‘architecture tells an important story’.  The reality has been the exact opposite, with the destruction of much of what should have been recognised as a unique settlement of the 19th and early 20th century.
It is vitally important that the present document recognises that errors have been made and that there are still key buildings at risk e.g. Grosvenor House, Prison Officers’ Social Club etc.

3.9 Yelverton

The importance of Plymouth/Drake’s Leat and the Devonport Leat needs to be mentioned, as well as the route of the Plymouth & Dartmoor Tramway.

3.9.1 Airfield – Correction needed – this is sited on Roborough Down and was known as Harrowbeer Aerodrome.

3.16 Cornwood

3.16.3 Bridge – There was an ancient bridge here – the earliest reference known to it is in 1568 (a tinworking deed).

3.19 Dousland

3.19.2 Correction needed: the quarry is on the north-east side of the village not the south-east side as stated.

3.20 Drewsteignton

Mention should be made of the lime quarries.

3.24 Ilsington

Mention should be made of the important restoration of several of the houses in the village in the late 1930s by Capt. C.W. Quelch (see Shears, R.T. (1968) Conservation of Devon Cottages). It is surprising that Ilsington does not have a Conservation Area.

3.27 Lydford

There should be a statement about the integrity and attractiveness of the 19th century buildings of Lydford. The site of ancient Lydford Mill should be included within the Conservation Area, as well as the road junction and field containing the prehistoric barrow (‘tumulus’)/gallows site/windmill site, WNW of the war memorial.

3.27.4 There never was a ‘stannary courthouse’ here, only the gaol. However, the Forest Court was held in the Castle. The Castle itself deserves mention!

3.29 Mary Tavy

The Conservation Area should include ‘Croftner’ at the junction of Bal Lane with the A386.

3.30 Meavy

3.30.4 Deserted farmsteads – these should be shown on the map. Warrens is known as a farm site but where are Bowdens and Palmers?

3.31 Murchington

3.31.1 – mention should be made of Mount Pleasant Farm having origins around AD 1400.

3.34 Peter Tavy

Mention should be made of its strong mining tradition, and of the rare presence of a working farm (Chubb Farm) in the centre of the village.

3.43 Walkhampton

What has happened to its proposed Conservation Area?

3.45 Widecombe-in-the-Moor

The whole of North Hall should be within the Conservation Area.