Good news for us all in Natural England’s representation. The extract copied below will be of special interest to Sid Valley residents (Highlights in bold, by SOS). Full text in DOCUMENTS page on this website.
‘Strategy 26 Sidmouth – additional comments
We advise that we consider this strategy unsound due to its allocation of 5 ha of employment land ( see below ). In addition the proposed loss of employment land within the town at Manstone Depot (which is now proposed for non- strategic residential land)although significantly smaller than that proposed within the AONB also appears to be contrary to the NPPF.
If residential land is to be allocated at the Knowle, there should be no loss of Green Infrastructure and surrounding parkland as this is an important green space within Sidmouth. Not only is it an important feature for balanced communities – Strategy 4, but because Sidmouth is only approximately 5 km from the East Devon Pebblebeds. It is vitally important that all existing Green Infrastructure within the town is maintained and enhanced to protect the internationally designated site from increased recreational pressure.
Given the importance of the environment’s important role to both residents and to the town as an all year round tourist destination, it is strongly recommended that a similarly worded statement as Strategy 25 (Seaton) bullet point 5 is incorporated.
This will also need to make reference to the nationally and internationally designations that surround the town.
Proposed employment allocation north of Sidford
We advise that we consider this non strategic allocation (phased or not phased ) unsound as it is not justified due to not meeting the tests in paragraph 116 of the NPPF.
In the report by Tyms in 2011 East Devon Housing and Employment Study 2011, we note that it is considered that the employment priorities at Sidmouth include: replacing existing poor stock;
occupier expansion land; the potential for small industrial/hybrid schemes; and work-hub to encourage entrepreneurs
It is also noted that the report concluded that there was some capacity at Alexandra Road within the town which we note is proposed to be allocated.
We therefore agree that some development may be required at Sidmouth which due to the constraints on the town, may include some development in the AONB. However, such development should be considered exceptional and in the public interest.
It is noted that employment allocations at Sidmouth are regarded as non-Strategic only (table following Paragraph 6.10 entitled Employment Land Provision and Allocations) and that allocation will be made at a later stage of site identification/ plan production. It is noted that the Alexandra Road site outside the AONB has been allocated together with the proposed allocation 1967 at Sidford in the Plan. Whilst another current employment site Manstone Depot is now proposed for residential land. It is questioned why, by default, the employment allocation in the AONB is exceptional and in the public interest whilst employment provision within the town itself is lost.
As proposed allocation 1967 is major development within the AONB, in order to show its deliverability, it needs to be in conformity with paragraph 116 of the NPPF; that is:
1. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
2. the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way;
3. and any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.
Whilst some assessment has been made in respect of the second bullet point, this is not considered sufficient and we advise we do not agree with its conclusions regarding the environmental impact of developing in this area.
We agree do with the appraisal within the report ENV 032 Strategic Landscape and Visual Appraisals – Honiton and Sidmouth that the Landscape Characterisation of the proposed allocation is Unsettled Farmed Valley Floor. This is a relatively rare feature within the AONB which is vulnerable to change. The sewage works and associated buildings in the landscape are noted but whilst that scale and massing is considered acceptable in this particular landscape, the additional development of that proposed would not. This is due to the impact from mass and scale that could not be mitigated against even with design guidelines.
We advise the proposed allocation is not compliant with the Management Guidelines of the District Landscape Character Assessment to maintain “the inherent absence of settlement and development” of this feature nor the AONB Management Plan Landscape key objective to ensure distinctive landscapes …. are maintained. Therefore this allocation is not compliant with Strategy 46 of the Plan.
It is advised that:
Even if evidence regarding need is clearer and justified
and further consideration of the impact on alternatives shows there is no scope for meeting the development elsewhere or some other way,
given the landscape character of the site, we do not consider that any proposal in the proposed allocation would maintain the distinctive landscape to comply with the Landscape Character Assessment and Area of Outstanding Natural Beauty management plan and Strategy 46 of the Plan and therefore would not be justified.
It is not considered that this allocation is exceptional and in the public interest due to both its non- strategic allocation designation and its non-compliance with both the NPPF and Plan’s own policies. Therefore, we advise that the allocation is not justified and the Plan unsound.