EDDC Planning Application 12/1847/MOUT

Note that Objections and Comments to this Application have to be submitted to EDDC either on the web site or EDDC offices at the Knowle. Mark your letter with the Application reference (given above) for the Attention of Mrs A Herbert.

 

Please state  that you wish any previous objections and comments made to the earlier application to stand.

The following are the main points of comment from SOS on the revised documents.

1. Derogation tests, Protected species      and Trees and Bats Survey. Conservation of Habitats Regulations 2012
   1. Test       1 ; (Proposed Development preserves Public Health or Safety).. No  evidence provided by EDDC
   2. Test       2  requires that there is no  satisfactory alternative to The development. There is no evidence  provided by EDDC to that effect
   3. Test       3 requires that the proposed development will not be detrimental to the maintenance of the population of the species concerned.. Given the  acknowledged lack of data regarding bats and their roosts, (as noted by EDDC/DWC) it is impossible to  conclude that the Derogation tests are satisfied.
2. Planning Support Statement , (Bell  Cornwell),
   1. Para       2.14 acknowledges that the emerging LDP does not carry any significant  weight in the determination of this application. Nevertheless Emerging policy ED02 is quoted in support of this .
   2. Policy       A4 of the current Local Plan, requires 40% Affordable Housing subject to  the viability of such provision. This has not been done
   3. LP       policy E3 requires that it be established that there is a surplus of  Employment Land in he vicinity, where a proposal involves the loss of  Employment Land. This has not been established
   4. Para       2.27 asserts that the proposal does not envisage the loss of employment of Council staff. Para 3.10 acknowledges he loss of 55 jobs in the Sidmouth area.
   5. Para       3.12 makes reference to efficiency gains cost savings and a reduction in  the local tax burden. No evidence of this has been provided.
   6. Para       3.27 downplays the loss of0 .89ha of recreational land as a “small area”   However LP policy RE1 envisages no loss of such land except where the  criteria of this policy, RE1, are met. This has not been demonstrated.
3. Transport Statement
   1. No   traffic counts on Knowle Drive have been undertaken  to justify the assertion (para 6.6.7),  that the projected increase in vehicle movements  from housing developments  D and E are “not considered to be of a  level as to affect safety or operation “ of the southern end of Knowle  Drive. In reality, the Drive is single lane, wit no pedestrian  facilities, with very substandard access to Station Road. Any increase in  traffic on this section of the Drive adds to the risks.
   2. Para       2.7.1 assets that the loss of the weekend parking at the EDDC offices   will have no effect on parking in the town. In fact the loss of this car park, (which seems to be used by 30-50 vehicles at ant one time) will  have a great effect, since there are only 329 long stay car parks spaces  available, (299 at manor Road. Thus Sidmouth will lose about 10% of the  available car parking spaces.
   3. Para       2.9 asserts that  the provision of  a Park and Ride facility will be built at Woolbrook to accommodate 90 vehicles. In fact this was to be a “Park and Change” facility for  intermodal change for Exeter destinations, but more importantly this has  not been included in the emerging LP. The Traffic report is therefore seriously wrong in this regard.
4. Revised Plans.
   1. Zone       C now has provision for 26 3 storey houses, instead of 19. This is a  gross overprovision in  a  residential area.
   2. 14       3 storey houses are shown in a straight line some 13 m south of the  existing old hotel area. They cover the existing upper lawn, a designated “recreational area”
   3. More       trees are planned to be felled than before.
   4. There       is a great loss of “recreational land”, particularly on the west side of  the town, where other such land is non existent.
5. Heritage statement
   1. Very       cursory and limited in extent.
   2. The       report considers that because “trees are alongside the eastern side of  Station Road”  and are not to be  felled, that “”views in and out of the Conservation Area will not be affected”. Yet it is clear that  the construction of the Care Home on the  car parks will have as considerable  impact on the current Parkland approach to the town.