Local resident Peter Whitfield’s critique is set out below, with his permission:

‘ “Sidmouth has 52.6% more open space than is required….”

That is according to paragraph 3.32 of the Planning Support Statement compiled by consultants Bell Cornwell for the EDDC’s revised application to itself to build houses and a care Home on part of the Knowle parkland. So we should not be making such a fuss about it all!

Unfortunately for them this statement does not stand scrutiny – and it is feared that members of the Development Management Committee who will determine the council’s own planning application may not be as thorough in their analysis as members of SOS have been. It arises from a meeting of the DMC on 12 June 2012 when they adopted the East Devon Open Space Study as evidence in current planning applications and as policy under the emergent Local Plan. That means that the whole document is to be used, not just the parts that suit the council’s application.

So when we read in the Planning Support Statement that  “The current open space requirement as set out in the EDOSS 2011 sets out the standard of 1ha per thousand of population for Parks and Recreation Grounds in urban areas. Sidmouth currently has 21.26ha (or 1.53ha/1000 of population provision) which equates to an exceedance(sic)of the standard by 7.33ha – a significant amount more that the town actually ‘needs’.” we wondered where this so-called standard came from. It certainly was not from the OSS!

That document suggests a starting point of 1ha/1000 for Parks and Recreation Grounds (one of 14 classifications of public open space which it then carefully defines) but moderated this suggestion in a number of caveats elsewhere which the PSS chooses to ignore. The following are just some of these –

P5.2   The standards that have been proposed are for minimum guidance levels of provision. So, just because geographical areas may enjoy levels of provision exceeding minimum standards does not mean there is a surplus, as all such provision may be well used.

P7.5.1  The starting point of any policy adopted by the Council should be that all open space should be afforded protection unless it can be proved it is not required.

We have not seen any such proof from EDDC.

7.53      Policy R1  …….decisions related to the protection of open space need to be considered at a local level, and in close consultation with the local community and through neighbourhood plans.

The vast majority of expressed local opinion is in favour of maintaining the whole Knowle park as amenity open space and not have the residue spoiled by housing and Care Home development.

            Policy R3   Sites which have nature conservation, historical or cultural value should be afforded protection, even if there is an identified surplus in quality, quantity or access in that local area.

The whole area, including the original main building, is of great interest to the historical development of Sidmouth in its transition from a small fishing port, through the great Regency developments of cottages orne to its development as a tourist resort with the arrival in 1874 of the railway link to the national network.

But do we in fact have such a surplus? When we look at the 21.26ha of Parks and Recreation Grounds which we are said to enjoy we find that the list of sites in Appendix C of the OSS is:-

Connaught Gardens (1.34ha)

Blackmore Coronation Gardens (0.91ha)

The Knowle (3.63ha)

The Byes (13.81ha)

Sidbury Park (0.89ha)

Eastern Town Recreation Ground (0.26ha)

And Furzehill Playing Field (0.41ha)

The OSS gives careful definitions for the 14 types of open space they identify, and two of them are:-

Parks and recreation grounds refer to defined areas of green open space that have been formally laid out for public enjoyment. Typically they will include lawns, flower beds, paths, and occasionally facilities such as toilets or a food stand. This includes public parks and gardens such as Connaught Gardens or The Knowle in Sidmouth, as well as privately owned formal gardens that are open to the public such as Killerton Gardens in Broadclyst.

(This has a proposed standard of 1ha/1000 subject to the caveats above)

Natural & semi-natural open space. This essentially covers any area of open space that has not been formally laid out and is therefore natural or semi-natural in appearance. This includes common land, woodlands, moorlands, heathlands, grasslands, as well as beaches and cliffs amongst others, and might be considered nature reserves. These areas may or may not be managed, and include open spaces such as Woodbury Common, Budleigh Beach, and Ashclyst Forest.

(This has a further standard of 1ha/1000 also subject to the caveats above)

For those of us who know and use The Byes they do not fit this definition of Parks & Recreation Grounds but are an exact fit for Natural and semi-natural open space. So we should take 13.81ha from our 21.26, leaving just 7.45ha – a gross under-provision against our “need” of 13.93ha!!! Furthermore we doubt whether many people would regard Sidbury Park as part of the Sidmouth urban area! So lose another 0.89ha?

But, even if we accept the 21.26ha figure the fact remains that the OSS does not dictate a “one-size-fits-all” policy which reduces provision to a simplistic arithmetical calculation based on population statistics and makes no reference to the very different economic characteristics of east Devon’s seven urban areas. Such an approach is not what the document actually suggests.  Honiton and Axminster for example are largely industrial and commercial economies; there are hardly any hotels, guest houses, B&Bs or camping sites in their areas. Virtually no coaches arrive there with short or long stay visitors. Their needs for open space are mainly to meet the requirements of the local population. Sidmouth’s economy is essentially based on tourism and therefore needs to be perceived as different, welcoming, attractive, with lots of green space in which visitors can walk and relax. There are many hotels, guest houses, B&Bs, camp sites and very many coach parties arrive both as day trippers and holiday makers. To diminish or spoil the areas of open space by unwanted development would endanger this vital trade and ignores the caveats in the OSS.

The Sidmouth Town Council has reviewed the amended application and can now only “support development of Zone C within the footprint of the existing office buildings and subject to sympathetic and appropriate design in keeping with the character of the area and adjacent properties.”

This might be bad news for potential developers but is good news for Sidmouth.’

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.