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.
- Derogation tests, Protected species and Trees and Bats Survey. Conservation of Habitats Regulations 2012
- Test 1 ; (Proposed Development preserves Public Health or Safety).. No evidence provided by EDDC
- Test 2 requires that there is no satisfactory alternative to The development. There is no evidence provided by EDDC to that effect
- 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.
- Planning Support Statement , (Bell Cornwell),
- 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 .
- Policy A4 of the current Local Plan, requires 40% Affordable Housing subject to the viability of such provision. This has not been done
- 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
- 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.
- 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.
- 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.
- Transport Statement
- 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.
- 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.
- 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.
- Revised Plans.
- Zone C now has provision for 26 3 storey houses, instead of 19. This is a gross overprovision in a residential area.
- 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”
- More trees are planned to be felled than before.
- There is a great loss of “recreational land”, particularly on the west side of the town, where other such land is non existent.
- Heritage statement
- Very cursory and limited in extent.
- 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.