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, for the Attention of Mrs A Herbert.

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

DEADLINE IS TOMORROW, Thurs   7th  February.

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 a considerable impact on the current Parkland approach to the town.

There’s still time, before tomorrow’s deadline, if you haven’t sent your own response.  Below is another example, if required, for inspiration (More at Knowle Watch category archive to right of this page,  esp January  31.30,26,25, and24 ):

Comment on OPA: 12/1847/MOUT

Jeremy Woodward: 1st February 2013

It is disappointing that the District Council has made no effort to evaluate the local heritage value of the Knowle site.
> The Heritage Statement of Significance makes no reference to the local significance of the site, preferring to mention only the nationally-listed building-work.
> The Design and Heritage Champion has submitted no comment; neither have any other Councillors or Officers at the District Council chosen to comment on the heritage value of Knowle.

The only public statement made by the District Council with regard to this has been in the form of a quotation from another statutory body. In its press release of 28th September 2012 entitled ‘Knowle does not merit national listing’, the District Council noted the following:
The English Heritage report concludes: “Knowle, formerly known as Knowle Cottage, with its prominent position overlooking the town of Sidmouth, and the remains of its landscape garden, which is now a public space, have clear local interest.
“However the house and the grounds have been heavily altered in their successive uses. The alterations that have occurred both to the gardens and the house mean that neither meets the criteria for designation in a national context, though they are evidently highly-valued by the local community”. http://www.eastdevon.gov.uk/communications_and_consultation.htm?newsid=711

In other words, there has been no proper recognition from the District Council of the heritage value of the Knowle site. It has taken the objections of several national and county organisations to underline the fact that Knowle has ‘clear local interest’ and that it is ‘evidently highly-valued by the local community’:

> The Devon Gardens Trust has had to remind the District Council that it added the Knowle grounds to its Devon Local Register of Parks and Gardens of Historic Interest in 2004. In its July 2012 objection to the OPA it stated that: We consider that it would not be acceptable, in terms of the historic designed landscape, to build on any of the existing parkland.

> SAVE Britain’s Heritage stated in its September 2012 objection to the OPA that: … the loss of the Knowle and development of the park on the scale proposed would represent a devastating blow to the history and character of Sidmouth. Furthermore: The council should be setting an example to the district and showing that historic buildings should be valued not discarded.

> The Victorian Society’s January 2013 objection to the OPA refers to: the historical and local significance of the building and the survival of some of its internal features, whilst reiterating SAVE’s comments that the heritage assessment is inadequate. Furthermore, the Society specifically mentions the District Council’s 1999 Conservation Appraisal for Sidmouth, which stated that the area up to Knowle should be assessed for potential inclusion in the designated area, and therefore that its significance should be properly evaluated. http://www.eastdevon.gov.uk/plg_sidmouth1-3caa.pdf

By these accounts, the documentation submitted to English Heritage for the national listing of Knowle is still relevant with regard to the local significance of the site.
I therefore submit this as an attachment to my comment to the OPA.