All representations received are shown on EDDC’s website. Here are some samples, which individuals have copied to SOS, with permission to reproduce them here for your information. These samples will be archived in the EDDC Category on this website.
Local Plan Response.
‘EDDC Leader Paul Diviani’s New Year’s message ‘.. There have been some mistakes along the way and we need to get better at informing our residents and listening to them in 2013″
Few people across the district have any confidence in the new East Devon Local Plan 2006-26 which is considered unsound and inconsistent. It pays lip service to sustainable development and climate change while seeking to permanently destroy vast areas of landscape through the supply of unnecessary amounts of commercial and industrial land. With its emphasis on development over the protection of the environment the Local Plan threatens to jeopardise the future socio-economic status of East Devon as a tourist destination. The whole procedure has been contaminated by malpractice, secrecy and a lack of evidence to justify the unsustainable amounts of houses and employment land. Excessive allocations of housing and employment supply in areas of outstanding natural beauty AONB amount to an attack of planning vandalism across the much cherished East Devon countryside. Due to the lack of community consultation and involvement while favouring the undue influence of vested interest the process is democratically and legally flawed. EDDC has lost the trust of the population it is meant to serve which has resulted in a furious backlash with scores of objection letters, petitions to the DECC and a mass rally against the Local Plan proposals.
It is revealing the current Local Plan privileges the interest of developers in preference to the views of the community. In contradiction to the spirit of the Localism Bill It begs the question in whose interest is the Local Plan serving?
R6.38 Employment Land Provision and Allocation
I disagree with the employment land allocation of 195 Ha (including the intermodal)
What concerns many is the plethora of commercial premises creeping over the picturesque landscape, increasing traffic movements on narrow roads throughout East Devon. Occupying valuable agriculture land this industrialisation will damage the natural habitat while impacting on food security in generations to come. Ruining the holiday trade in the process such green field development will erode the future prosperity of local market and coastal towns. An allocation of 195 hectares of “employment land” in green fields will suck the life out of high streets and fetter economic recovery.
There is considerable spare capacity on the existing employment sites and there is sufficient currently with planning consent to be brought forward prior to additional allocations. To the majority of observers including Devon and Dorset County Councils the overwhelming amounts of unsuitable employment land in the district is the cause of major concern. It is widely accepted that the oversupply of employment land in the local plan was determined through irregular practice under the influence of the East Devon Business Forum a lobby group of major landowners and developers. EDDC policy of promoting development over protection of the landscape was an invitation to secretly encouraged disproportionate amounts of industrial land to be brought forward by local landowners who are also members of the EDBF. This over allocation gives the developers more opportunities and as under the NPPF any land designated for employment that does not come forward can be much more easily changed to housing which is far more lucrative than business units.
Having commissioned two independent reports by Atkins in 2007 and Roger Tym & Partners in 2011 which recommended only a small increase in employment land these have been ignored by EDDC officials in favour of the East Devon Business Forum which after carrying out their own projections recommended exaggerated increases. It is now clear the landowners and large companies have plotted through EDBF to inflate employment land to 195 hectares with the consent of senior EDDC councillors. Lacking transparency this rear channel arrangement between EDBF and the EDDC officials is then legitimised by incorporating it into the local plan and nodded through by approving council members. Many of the recent large scale applications are suspicious and conflict with the current Local Plan 2006. This inappropriate behaviour is consequently the subject of formal complaints against the EDDC Leader and its CEO, and the EDBF chairman for failure to abide by the council’s own Code of Conduct.
I believe a more modest total of 120 Ha of employment land as recommended by consultants Aktins and Roger Tym would provide a more sustainable allocation.
R6-40 Scale and Distribution of Residential Development
I disagree with the current residential totals of 15000 homes.
It is unclear where the evidence for so many new homes originated but it was noted that the Local Plan panel chairman supported EDDC officer Kate Little’s recommendation of 15000 while other panel members considered 12500 new homes to be sufficient. Clearly for the highest financial return EDDC officers have without evidence inflated the housing supply to 15000 + which in turn further inflated the demand for employment land. (It is just such unsustainable property speculation which first in the USA sub-prime market, then Ireland and Spain created the current financial credit crisis) In their report to the LP Panel consultants Roger Tyms & Partners predicted by 2026 an increase in the East Devon population of 22500 (17%) equivalent to 13,700 homes. More recently the East Devon branch of CPRE applying the 2011 Census figures estimated a total of 11000 homes to be adequate.
There is concern the original estimates were calculated during a period of growth prior to the current recession and due to the slump in demand I would therefore consider 11000 homes to be more realistically achievable
R 6.129 Development of Sidmouth
Located along the UNESCO World Heritage Coast Sidmouth is respectfully nestled in the Sid Valley bordered with AONB on all sides. It possesses a historic Georgian townscape of national importance and is blessed with green surroundings which are highly valued by visitors from the UK and abroad. As it stands the local plan will destroy this sensitive balance between a high quality built environment and tourist attraction of special distinction transforming it to an ubiquitous industrial economy.
In Sidmouth to maximise return EDDC intends to sell historic popular amenity and public employment land to developers for private homes. By asset stripping EDDC is exploiting Sidmouth’s value as a cash cow to relocate to a place which is further away from the more populated coastal wards. EDDC’s are in effect parcelling up the existing employment spaces to relocate it on fields which have been offered by local landowner in an AONB. Instead of concentrating on diverse mixed use sites within existing boundaries the EDDC local plan is transferring commercial provision to an out of town green field location. Such a move will of course have a detrimental effect on Sidmouth as a high quality tourist destination and will impact negatively on the future sustainability and prosperity of the resort.
The local plan map indicates a change of use for employment land at the Knowle, Manstone and Port Royal to accommodate new homes. There was no mention of the relocation of the EDDC HQ in the local plan which will shift 380 full time equivalent jobs from Sidmouth to Honiton. Yet by approving the outline planning application for fifty houses (and a large care home) to facilitate the relocation EDDC will effectively be predetermining the outcome of the Local Plan before it is inspected. Rather than serving the local community, the EDDC cabinet is effectively exploiting the local plan procedure for their own self-interest. The repercussions of manipulating the local plan in this way is job losses from the Knowle and elsewhere will determine the need for alternative work places on the “employment” land at Sidford.
The Knowle development would also involve building on parkland which the Government NPPF guidance says is not brown field. Installing this amount of homes on the site will require the destruct/on of a historic landmark and the loss of a townscape of considerable merit with an impressive relationship between the existing building and the setting. The car parks were located on the Knowle nature reserve which is the property of the town and as such should remain for use of the public and not be converted to private residences.
The proposals for Sidmouth were added at the last minute and were therefore unavailable for public consultation. The employment land supply and distribution is entirely fabricated to accommodate the relocation of the EDDC HQ to Honiton (see planning application 12/1847/MOUT) Sidmouth currently has a well balanced distribution and mixture of employment land and residential accommodation within its existing boundaries and I strongly disagree with the change of use at Knowle and Manstone to relocate employment capacity elsewhere in the Sidford Fields. It is wholly inconsistent with the evidence based ethos of the Local Plan and there is no correlation between the quantities of new homes and the excessive employment land supply. There has been no consultation over the amounts of employment land allocation and unsurprisingly the Local Plan fails to reflect the real needs of the community. EDDC has had plenty of time to adjust the Local Plan but has regretfully chosen instead to ignore local feedback and has tried to repel overwhelming opposition in the valley.
For the long term benefit of the town the Local Plan for Sidmouth must therefore be thoroughly re-appraised and revised.
® 6.133 Employment Land in Sid Valley
I strongly object to the despoliation of an AONB by allocating 5Ha on the north edge of Sidford as an additional employment site.
Consultants Atkins and Roger Tyms found there is sufficient spare capacity within existing boundaries to accommodate future employment demand and advised EDDC that Sidmouth required 1 Ha of employment land. The Sidmouth Chamber of Commerce also submitted an informed study to the LP Panel which found demand for employment land in the Sid Valley was extremely low. EDDC simply ignored this modest amount of employment growth and increased the allocation to 5Ha. According to email received by the Chamber of Commerce the LP Panel chairman was “misled” by EDDC officers about the allocation of employment land on AONB in Sidford. (Note in Autumn 2011 the Scrutiny Committee criticised the EDDC planners for failing to communicate with elected representatives.) Following a packed public meetings in April 2012 the Sidmouth Town Council rejected the proposal for 5 hectares of employment land on AONB north of Sidford. Proposing employment land on AONB has more than anything else created outrage within the town and was the main recruiter for the Save Our Sidmouth Campaign and petition. (See SOS Local Plan Response.)
In respect to employment land EDDC officers have failed to listen to Sidmouth Town Council and have been unduly influenced by vested interest such as the East Devon Business Forum. The excessive amount of employment land has been recommended by the East Devon Business Forum who had been invited to consult without providing any evidence of substance. Recently Ford & Sons, a key company within EDBF has submitted a planning application to develop the employment land in the Sidford greenbelt. With such an oversupply, the Sidford site development would cause great problems for residents and traffic while contributing to greater flooding risk in the village and valley. A significant area of the East Devon Area of Outstanding Natural Beauty would be destroyed and the important Green Wedge between Sidford and Sidbury would be seriously eroded coalescing two ancient independent villages. It would however be inconsistent to reconsider this proposal as a previous application to develop the site at Sidford was rejected by EDDC itself 35 years ago, citing traffic, flooding, water pollution and AONB. More recently a nearby Garden Centre had a modest planning application on the same AONB refused. A waste water treatment plant was only permitted to be built with multiple conditions which could never be met by 5ha of commercial buildings. All these reasons still apply, but traffic is far heavier now, and there are serious warnings from meteorologists that heavy rainfall and flooding is becoming significantly more likely.
Employment Land in the Sidford Fields ignores the National Planning Policy Framework NPPF document which recommends there should not be development in AONBs unless it is in the public interest or there is an overriding and proven need. There is absolutely no over-riding requirement for such a provision. Asphalting this banking and interfering with the River Sid flood-plain (overwhelmed 4 times last year) will add to the risks downstream in the town. It is poor practice to promote a vast commercial zone and planners are advised to prioritise diverse brown field sites within existing boundaries. Rather than pursuing this fatally flawed plan, employment provision in Sidmouth would benefit from retaining existing sites as follows;
® 6.295 the District Council Offices at the Knowle with 380 staff is the largest employer providing much of the best paid employment in the town.
® 6.296 Manstone Workshops, conveniently sited near to Sidmouth Community College, which could offer training and job opportunities for young people.
® 6.132 the upgrading with a new access road and reconfiguring of the Alexandria site. In addition, more job opportunities would be provided by local companies
® 6.297 the mixed live-work development at Port Royal. To create innovative mixed use residential and employment space more consistent with the historic grain of Eastern Town. Increasing density EDDC should prioritise concentrating people and business in the centre of town. (As it is part of the Ham recreation ground the land occupied by the Drill Hall should be returned to the local community.)
The above measures would provide an adequate and sustainable supply of employment for the community.
Why in the Local Plan is Sidmouth described differently to the other resorts of Budleigh and Seaton with no mention of the high proportion of retirees? For a town with a large number of retired people and which enjoys high employment with fewer than 100 out of work there is simply no demand for a single provision with 1350 workers. The site in Sidford would greatly increase in-commuting, which contradicts an important EDDC’s policy aspiration within in the Local Plan. If EDDC is serious about creating more employment in Sidmouth, it must put an end to sacrificing employment sites to housing, much of which proves too expensive for local young people and may well be sold as holiday homes.
® 6.133, 6.415 New Houses
I disagree with 50 new homes on employment land at the Knowle
In Sidmouth during the last six years 594 new homes have been brought forward at a rate of 100 per year. To reach the target of 744, just 150 more homes are required (100 non strategic + 50 windfall) in the remaining 14 years. At 10 units per year windfalls can certainly provide this limited growth in homes well before 2026.
As the EDDC wish to identify sites for the remaining 150, then 50 homes as part of a mixed development at Port Royal would be appropriate. For reasons described above, I disagree with the plans to designate the Knowle and Manstone Workshops as residential, rather than employment sites. As EDDC however only require half of the footprint of their current workspace, they might explore accommodating staff in a retro-fitted office while reconverting the former hotel into 30 or so apartments.’