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.

Please write, quoting 12/1847/MOUT, to Mrs Anna Herbert at EDDC, Knowle, Sidmouth (or email her at AHerbert@eastdevon.gov.uk or register comments online on EDDC’s website) by midday on Friday 16^th November.

Sidmouth Town Council will consider the plans at their next meeting (dates to be confirmed) and the EDDC Management Development (i.e.planning) committee will meet on Dec 4 at 2pm at Knowle.

Some examples of reasons to object:

1. Misinformation and selective presentation from EDDC undermine the need to demonstrate exceptional circumstances to advance an OPA (Outline Planning Application) which goes against many EDDC and government policies.

2. The savings on carbon outputs in the new building will take 50 years to balance the carbon emissions that come from the demolition of Knowle and new construction at Honiton.
3. 
Even allowing for 6500 homes in Cranbrook, Sidmouth will on average be closer to people across the District. A move to Honiton by EDDC would increase the average resident’s journey to EDDC by 18% compared with that to Sidmouth.

4. As EDDC staff only need half the current floorspace, EDDC could halve its energy use by moving all activities into the 1975 offices at Knowle; they could halve energy use again by modest improvements to the 1975 offices and investment in renewables. EDDC could sell the land in Honiton earmarked for the new offices to part-fund the improvements. Once staff have moved into refurbished offices, EDDC could sell the historic Knowle buildings to contribute further to the provision of renewable energy installation, probably leaving a balance of funds for other projects elsewhere in the District. Conversion of the old Knowle Hotel into 50 luxury flats would meet the dwellings target for Knowle. All these steps could be taken with minimum environmental damage and no impact on greenfield land or ecology whatsoever.

5. EDDC claims that 70% of Knowle parkland will remain unscathed by development. They do not state however that at least 60% of the formal gardens will be lost under housing in zones D & E which extend beyond draft LDP map outlines. The Knowle site will only have 8% gardens after development, down from 28% now. The parkland known as the Arena Field will lose 30% of its grassland and many trees to buildings in zones A & B of the OPA, both also extending beyond the draft LDP map outlines.

6. Knowle Drive is narrow with single-track stretches, blind bends and inadequate passing places, especially near zone E. Getting into and out of Knowle Drive is difficult at either end, with blind junctions and hazards like the pinch point on Station Road. It is impossible for lorries safely to enter or exit Knowle Drive at the lower end and nearly as difficult for them to come down to zone E from the top.

7. Devon Wildlife Consultants recommends actions which should be considered obligatory to avoid contravening UK and EU wildlife legislation pertaining to the proposed development. They say the Local Planning Authority will likely require information relating to further protected species surveys, prior to determining any outline or full planning permission relating to the site:
- If any mature trees are to be disturbed, an assessment of these trees should be undertaken along with, where appropriate, a bat dawn re-entry survey prior to commencing such works – this has not been done;
- a bat activity survey should be undertaken comprising fourteen surveys to be undertaken during April to September/October – this has not been done;
- the mature woodland and vegetation structures distributed throughout and around the site should be retained and enhanced in order to retain the historic nature of the site and provide foraging for bats, badgers, and other terrestrial mammals, invertebrates and bird species; this is not planned.
In terms of public open space, the proposed development at Knowle will reduce to below the ‘standard’ area (1 hectare per 1000 people) of ‘parks and recreation land’ in Sidmouth (the Byes is ‘natural and seminatural open space’ and should not have been counted by EDDC as ‘parks and recreation land’ in their assessments). This contravenes the East Devon Open Spaces Study, 2011, adopted June 2012 by the Development Management Committee of EDDC to inform planning policy. It contravenes the aims of: the Adopted Local Plan 2006-2026; the draft Local Development Plan; the Green Infrastructure Study for the Exeter Area and East Devon New Growth Point: April 2009; and the National Planning Policy Framework. And it does so without making an indisputable, let alone exceptional case for accepting the proposal. Nor does it offer alternative areas. It must therefore be rejected by the EDDC Planning Committee.

PLEASE NOTE: DEADLINE IS NOW 16TH NOVEMBER, BY MIDDAY, for objections to revised Knowle Plans.