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Letter to Cllr M Williamson, Chairman of the Development Management Committee, EDDC

Sidmouth Chamber of Commerce

President : Mr Derek Parry
Chairman:
Mr Steven Kendall-Torry
Vice-Chairman: Mr Edward Willis Fleming
Treasurer: Mr Matthew Portman
Membership Secretary: Mrs Edwina Ford
Secretary : Mrs Sylvia Brownlee

Please reply to: The Secretary

Cllr M Williamson, The Chairman, Development Management Committee, EDDC

Dear Sir,

Submission by Sidmouth Chamber of Commerce
Local Plan Consultation

Employment Land

We would like to draw attention to our submission in January 2012 which dealt specifically with the allocation of employment land across the District and for Sidmouth in particular. We identified flaws in both the methodology employed and also in the calculations used.

The miscalculation, which has been admitted by the Policy team, is very serious. There can be little doubt that the compiler of the tables concerned intended to use ‘net out-commuting’ figures but used ‘out-commuting’ figures instead.

Had the correct numbers been used, the employment land allocation across the District would have been radically different. The total allocation would have been about 20 hectares less. In Sidmouth, the allocation would have been 1 hectare rather than 5. The over-provision in Sidmouth is especially high because Sidmouth enjoys an exceptionally high level of job retention and is a net in-commuter of jobs.

Members will be aware that the over-provision of employment land in Sidmouth has been hugely controversial, with a petition signed by almost 4000 in protest against the allocation. In all probability, if the allocation had been correctly calculated, the protest would have been restricted to the choice of site alone.

Our submission of January 2012 was a crucial contribution to the debate over employment land allocation and we are extremely unhappy that this document has been deleted from your web-site, and therefore not available to the general public.

These problems were compounded by a misrepresentation of the Chamber position regarding employment land provision in Sidmouth. Minutes of the Local Plan Panel indicate that Sidmouth Chamber of Commerce was in favour of employment land provision in Sidmouth of 3 hectares. This is emphatically not the case, as previous minutes and submissions (those that are still available and not deleted) confirm. We understand that this error is to be corrected, but would point out that it has existed throughout this crucial consultation period, so the general public has been seriously misinformed.

This unfortunate situation has been further distorted by a misrepresentation of Sidmouth Town Council’s position regarding employment land in Sidmouth that occurred in the last consultation document. This stated that Sidmouth Town Council supported an employment land allocation north of the A3052. We pointed out in our consultation response of January 2012 (since deleted ) that this was not the case. The Town Council’s submission during this consultation phase confirms this.

Remarkably, the Chairman of the Local Plan Panel, Councillor Mike Allen, has recently stated publicly that he was ‘misled’ by an officer as to the views of the Town Council prior to the allocation of employment land in Sidmouth and specifically with regard to the Sidford site. He has indicated that he is likely to refer the matter to the Scrutiny Committee. We can only assume that other members of the Local Plan Panel were equally misled.

We conclude that the process by which employment land allocation in Sidmouth has emerged is very seriously unsound – a shambles in fact. The wrong calculation, the wrong report of Chamber and Town Council opinion, and the wrong information to the Chairman. What, if anything at all, was right?

It is perhaps therefore not surprising that opposition to the proposals has been so strong, and that confidence in the integrity of the Local Plan process has collapsed.

We urge that the Development Management Committee look at the employment land allocation with a fresh view. Had all these mistakes not been made, we think it extremely unlikely that the employment land allocation of 5 hectares at Sidford would have been even contemplated.

There is no evidence to support such a huge allocation and the site is clearly unsuitable. Our reasons for saying this occur in previous contributions, and will be very well explained in other submissions, so we will not repeat them here. However, we will emphasise the following points that may not have been made previously:

  1. In recent months, we have entered the second phase of a ‘double dip‘ recession. Economic growth has been significantly negative since, for example, the now-discarded Regional Spatial Strategy was developed in 2008. This further diminution in economic activity has not been reflected in EDDC Local Plan policy. It is, however, reflected in experience on the ground where employment sites lie vacant in considerable numbers across the District. Moreover, predictions of economic growth going forward are also significantly lower.
  2. The lack of economic growth will also be reflected in reduced demand for housing. Economic growth is a key driver of housing need, so demand for housing is going to be less than anticipated. This is reflected in the first responses to the Cranbrook development, which are reported to be disappointing, and in the continued low levels of house sales in the District.
  3. The inter-modal freight facility is effectively no more and has been superceded by a large Sainsburys distribution centre. The inter-modal facility was not included in employment land allocation as it was ‘a special case’. This was a highly dubious position in the first place, but must now be ripped up. The land in question should be added to the employment land allocation for the District.
  4. There has been widespread concern over the role of the East Devon Business Forum in the generation of the employment land numbers, and persistent complaints from members of the public concerning the undue influence that the Forum has enjoyed over Local Plan policy. The Forum’s name is misleading. East Devon businesses are predominantly small. The membership criteria thus debar 95% of East Devon Businesses.
  5. In the case of Sidmouth, we strongly support the Town Council and others in advocating the full use of the Alexandria Industrial Estate. This area of employment land is chronically under-used at present. We are very much opposed to development outside the Built-Up Area, and therefore within the AONB, whilst this land is available.
  6. Throughout the development of the Local Plan thus far, EDDC has consistently exaggerated the level of unemployment in the District. This stems from a rare mistake by Roger Tym and Partners, who in other respects have produced a good report. Roger Tym used Nomis data to produce their unemployment figure, but Nomis is known to be extremely unreliable at District level due to the small sample sizes used. Nomis does not, in fact, publish District-level figures for this reason. Sidmouth Chamber challenged the unemployment figures when they first appeared in the Tym report: we knew that the figure quoted of 7% was incorrect and we doubted that unemployment was rapidly accelerating across the District as Tym indicated. Our challenge was rejected at the time, but our concerns have since been vindicated. Tym now concede that Nomis should not have been used, and we believe this is also the view of the Policy team. It is fair to say that proponents of large scale employment land provision within the authority seized on the Tym figure of 7% as justification for their position, and it became something of a ‘scare story’. The true figure for East Devon is somewhere between 2% and 3.5% depending upon the way in which unemployment is assessed. Buried in the Sustainability Assessment by LUC is the genuine figure of 2%. In Sidmouth, the figure is very low at around 1%. We wonder what the employment land allocation in East Devon would have been if the Local Plan Panel had been given the correct figures for local unemployment.

Housing

We will not repeat points previously made, but would reiterate our call that Members be made aware of ALL submissions made previously. If documents cannot be recovered, we can supply copies, but we are not sure how many other papers have been lost from other submissions.

As with employment land, the housing allocation is clearly too large and is not justified by evidence. Specifically, relying upon the Regional Spatial Strategy of 2008, discarded and now hopelessly out-of-date, is not appropriate. If the Regional Spatial Strategy were to be re-created today under the same terms as used in 2008, but using current economic data, the housing recommendation for East Devon would be less than 13000 rather than 17000.

With regard to Sidmouth, we feel that the allocation of a further 150 houses is reasonable, and we agree that these should be incorporated within the existing Built-Up Area. We think that the opportunities for ‘windfall’ sites have been underestimated and we anticipate that these will come forward regularly throughout the Plan period. We are prepared, reluctantly, to accept the Manstone Depot allocation.

Knowle

The debate over the proposed relocation of EDDC from Knowle is not the remit of the Local Plan, but we take the opportunity to point out that the relocation is fraught with problems, and is highly unlikely to be financially deliverable in the short to medium term. However, we acknowledge that if the property market improves significantly over the next few years, a move may perhaps be possible towards the end of the Plan period.

Parking

However, we strongly object to the boundaries drawn by the Policy team with respect to the redevelopment of the Port Royal and Knowle sites. In both cases, they involve the loss of substantial car parking, which is of vital importance to the vitality of the town centre. Parking is of major importance to the economic future of Sidmouth and it is completely unacceptable to have a Local Plan which commits to its reduction. When the vitality of Sidmouth’s town centre was discussed at a recent meeting of the TAFF created by the Scrutiny Committee specifically to consider town centre vitality, the issue of parking was the major subject. Everyone present agreed that Sidmouth’s biggest problem was parking provision. A Local Plan which exacerbates the problem is inconceivable.

We recall that the Chamber of Commerce participated in an EDDC-organised group charged with considering the redevelopment of Port Royal. This group received only one instruction from Ms. Kate Little, Chief Planner: ‘on no account must a single parking space on the Ham be lost during the redevelopment process‘. We suggest that nothing has changed since that instruction was issued.

We therefore strongly urge that the boundaries of these two sites on the Inset Map be changed so as not to include vital car parking capacity. We would like to point out that car parks in Sidmouth are ‘cash cows’ for EDDC and that reducing car park capacity is therefore counter-productive to the delivery of the two sites, as well as having an adverse effect upon town centre viability.

Tourism

We note that EDDC are proposing to employ three Communications Officers to promote the image of the District Council, but continue to refuse to employ anyone to promote the District as a whole. This reflects a depressing attitude within the authority towards tourism which is a major employer in the District. This argument is well-rehearsed and again we will not repeat things said in previous submissions. However, we take the opportunity to remind the Committee that South West Tourism reported East Devon as ‘going downmarket’ faster than any other West Country District. We see this as an alarming trend, which the Local Plan should seek to correct.

We can only urge the Development Committee not to listen to those who have previously held sway and demean tourism.

Supermarkets

It has become clear that the employment land allocation proposal for Sidford has arisen from an approach to Fords and other Alexandria landowners from Morrisons. The Sidford site is being proposed in order to facilitate a new large scale supermarket at Alexandria.

There is no justification for another supermarket in Sidmouth. We already have Waitrose and Lidl, and also the Co-Operative and Tesco in the town centre. We also have a good range of independent providers of groceries and basic essentials. In the past twelve months we have seen Sainsburys open in Ottery St. Mary, Tescos in Seaton, Lidl in Exmouth and Waitrose in Exeter. We therefore strongly endorse the recommendation of Grimleys, consultants to EDDC, that another supermarket would adversely affect the viability of the town centre. We have consistently opposed any further out-of-town retail provision for this reason.

Moreover, the Alexandria location is not suited to a new supermarket for highways reasons. Many of the users of the supermarket, i.e. residents of Sidmouth, will inevitably access the facility via the already heavily congested Alexandria Road. We think a new supermarket, even with a new access off Bulverton Road, is unlikely to obtain consent on highways and viability grounds. We face the prospect of a very unpopular employment land allocation at Sidford in order to accommodate an unwanted supermarket proposal that has little chance of coming to fruition.

If EDDC are minded to promote a Morrisons when their own consultants advise against, and when the townspeople are opposed, we ask: ‘What is to prevent it all happening again with another supermarket operator on the site at Sidford?’ Nothing, apparently. We understand from the Policy team that there would be no technical restriction upon retail uses at Sidford. We predict that this would be the inevitable outcome, as it has at Liverton Business Park at Exmouth, now the home of McDonalds, and Heath Park at Honiton, where retail is taking over.

Yours faithfully,

Steven Kendall-Torry
Chairman

The Secretary, Sidmouth Chamber of Commerce
3 Fortfield Chambers, Sidmouth, Devon, EX10 8NY
Tel: 01395 514011
E-mail: sidmouthchamco@tiscali.co.uk
www.sidmouthchamber.co.uk

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Submission to East Devon Local Plan

1. Listing of Knowle, Station Road, Sidmouth: 1951

Knowle, described at e. below, appears to have been listed in 1951 and to have lost its listing since then. Its owner, East Devon District Council is considering selling it for redevelopment. Certainty about its protected status and clarification of any confusion is urgently required.

The two buildings named Knowle in Sidmouth are located on two sites, Station Road and Harcombe. There is no concern about Knowle Harcombe (a.).

The buildings/features associated with the two sites are:

a. HARCOMBE C17 country house rehandled ca 1840-50 near the hamlet in Sidbury parish to the north-east of Sidmouth. Listed 12 Nov 1973; English Heritage Building ID no. 402406

b. STATION ROAD Grotto in the garden of Knowle Grange. Listed 1951; no. 402406

c. STATION ROAD Summerhouse in the grounds of Knowle, Sidmouth Urban District Offices. Listed 12 Nov 1973; no. 1228078

d. STATION ROAD Lodge at the entrance to the drive leading to Sidmouth Urban District Offices. Listed: not stated, probably 12 Nov 1973; no. 1227917

e. STATION ROAD Knowle, formerly Knowle Cottage (1810-1885), Knowle Hotel (1885-1950), Sidmouth Urban District Offices (1964-1974). East Devon District Council Offices (from 1974). Finished 1810 as large cottage ornée for Lord le Despenser. Listed 1951. No longer listed.

(note 1)

Knowle Station Road (e.) is recorded (as Knowle Hotel) as having been scheduled on the statutory list of the Ministry of Housing and Local Government in 1951 as being of outstanding historical and architectural interest. (See attached copies from Sidmouth Observer 9 July 1952)Other hotels/inns were similarly listed. All the hotels/inns in the Sidmouth Observer’s record appear on the current English Heritage list; Knowle does not.

(note 2)

Note 1: In the British Listed Buildings and English Heritage lists, the address [Knowle Dr, Sidmouth, Devon], postcode [EX10 8HL] and OS Coordinates [312042, 87954] for Knowle House Harcombe’s had been recorded as those of Knowle, Station Road. This was conveyed to English Heritage on 16th May 2012 and these details were subsequently corrected.

It seems that Knowle Station Road had become confused with Knowle House, Harcombe. If this is correct, there may not have been an intention to remove Knowle Station Road from the 1951 schedule.

Note 2: If the list of hotels in the article of 9 July 1952 is compared to that on the British Listed Buildings website, we notice the following:

  • All 14 hotels and inns except Knowle are listed in the 2012 list. Six were recorded as having been listed in 1951, the remainder in 1973. Knowle House Harcombe was listed in 1973.
  • Duffert’s Commercial Hotel is on the site now occupied by the Black Horse Hotel on 41 Fore St, Sidmouth. (source: Sidmouth Museum). It was listed in Nov 1973 and has the list entry no. 1288890.
  • This means that all the hotels and inns on the Sidmouth Observer list of July 1952 except Knowle Hotel are on the present English Heritage list.

These questions arise:

  1. Did the 1951 Ministry of Housing list become the present English Heritage list?
  2. Was the Sidmouth Observer correct in recording Knowle (e. above) as on the statutory list of 1951?
  3. Why is Knowle (e. above) no longer thus protected?
  4. Some buildings on the Sidmouth Observer list are recorded in the present English Heritage list as having been listed from 1973 and others from 1951. Why is this?
  5. Did Knowle Station Road ‘disappear’ from the 1951 list because Knowle Harcombe was added and given the incorrect co-ordinates?(Submitted to English Heritage 31 st May 2012)


2. Granting Knowle grounds Area TPO: 1956

In 1956, a Tree Preservation Order relating to Manor Park and Knowle Hotel was countersigned by the Assistant Secretary to the Minister of Housing and Local Government. The documentation specifically refers to the grounds as ‘parkland’.

The District Council has made recent references to this Order:

What impact will any future development at Knowle have on the many fine trees on the site? Are the trees covered by a Tree Protection Order (TPO)?

Trees are obviously a material consideration on this site and we will deal with them as sensitively as we can through the planning process. The grounds of Knowle are the subject of an Area TPO made in 1956. The effect of this order is to protect all trees that were growing in 1956 and therefore covers any tree over 55 years old. The TPO prevents trees being removed before any detailed planning consent and protects those trees shown as retained on the approved plans, both during and after construction. The potential to retain any tree is determined by the health and condition of the individual tree and whether it has significant amenity, historic or conservation value. The Council’s own policies and the criteria set down in BS 5837:2012 (Trees in relation to design, demolition and construction – Recommendations) ensure that all trees will be taken into account and considered on their merits.

Page last updated on 7 June 2012. http://www.eastdevon.gov.uk/movingandimprovingfaq

However, there are concerns that this TPO will not provide adequate protection for mature trees:

  1. There are contradictions in official maps of Knowle as to what signifies ‘parkland’ or ‘open space’. It is not clear whether the most recently adopted planning policy document supersedes an earlier document; or whether a planning application, if approved, overrules any TPOs.The 1956 Area TPO map A2 designates a clear boundary for the parkland at Knowle; it is within this area that all trees now 55 years old would receive protection. The ‘designated recreation parkland’ of the Sidmouth Urban Inset Map 58 of Knowle from 1996 seems to confirm this boundary. And yet, the Sidmouth Inset Map 45 of the 2006 and 2011 drafts of the Local Plan define a different boundary which excludes the ‘recreation area’ of the lawn in front of the present West Wing.Independent surveys have identified 16 mature trees including beech, Monterey pine, yews and hawthorn which lie in this area marked for housing development at Knowle in the 2011 Inset Map; that is, the proposed development line down to the depot offices would necessitate the felling of trees protected by the 1956 Order.
  2. There are concerns that the District Council will not respect the integrity of TPOs. The case of ‘Cedar Shade’ from 2008 has thrown into doubt undertakings made by Officers.Sidmouth Town Council raised concerns in the Minutes of its Planning Committee at point 08:9/P15.5:On 16th May, the Clerk wrote to the District Council regarding the above application expressing concern regarding the behaviour of the Property Developers at Cedar Shade in respect of the trees. The Clerk reported that a reply was still awaited. www.sidmouth.gov.uk/PDFs/Planning%20Minutes%202008/Plan%20Min%20-%202008.09.24.pdfAt the development of new homes at ‘Cedar Shade’ in April 2008 it appears that the District Council gave permission for the TPO to be:… suspended in order to allow redevelopment to take placeThe council decided that all the trees that were in the developer’s way were either “over-mature” or were diseased or more dangerous (and couldn’t be made safe?) What a convenient coincidence!! The County Highway Authority had recommended refusal of the planning application. That recommendation was rejected by EDDC. (Letter to Sidmouth Herald: 17th June 2008) http://www.edp24.co.uk/lifestyle/we_must_all_make_planning_concerns_known_1_457957?ot=archant.PrintFriendlyPageLayout.otConsequently, there are fears that no TPOs are safe in the District:This must not be allowed to become a most dangerous precedent to wholesale wrecking of Sidmouth’s heritage.


3. Knowle declared as ‘Public Open Space’: 1973

Documents in the public domain clearly contradict District Council declarations that there is no Public Right of Way through the Knowle grounds:

  1. A cutting from the Sidmouth Herald of 28th July 1973 refers to the decision of Sidmouth UDC to make the order to dedicate the Knowle for ever as a ‘public open space’ before it became the HQ of the new EDDC authority on April 1st 1974.
  2. SUDC Minutes of 1973 make recommendations, in the Clerk’s Finance Report (headed 24th July 1973 and signed 2nd October 1973). The entry clearly states that the public have established access to the grounds prior to 1973 and recommends that they become a public open space under Section 164 of the Public Health Act 1875 as public open spaces. Of particular importance is the sentence: “It will moreover be recalled that a principal reason for the acquisition of Knowle was to preserve the gardens and field as an amenity for the district”.

Devon County Councillor Stuart Hughes, with Cabinet responsibility for Highways, wrote to the District Council CEO in May 2012, ‘requesting that the District Council dedicate footpaths within Knowle grounds as PROW’:

Dear Mark

Having taken advice from our PROW team at County Hall I am writing to request that the District Council dedicate footpaths within the Knowle grounds as public rights of way, through dedication or creation agreements as the landowners with the County Council under section 25 of the Highways Act 1980. They (the footpaths) would then be recorded on the Definitive Map as public rights of way.

As I understand it this can be done through the solicitors in East Devon’s legal department contacting Devon’s PROW section who can advise on the procedures.

As you are aware with the newspaper articles on the possibility of EDDC moving there is a vast amount of concern regarding this issue within the town and it is an easier procedure to record public rights of way than going through the investigation of evidence to add them to the Definitive Map by Modification Order as they are currently not recorded as rights of way, although there have already been queries from members of the public about how to do that.

I now look forward to hearing from you

Best regards

Stuart Hughes CC
http://www.devonconservative.org.uk/blog.htm

As already stated, there are contradictions in official maps of Knowle as to what signifies ‘parkland’ or ‘open space’. Versions of the Sidmouth Inset Map prior to the current 2011 version clearly show the grounds of the Knowle as ‘protected’, designating the whole of the undeveloped part of the Knowle site as ‘Land of Local Amenity Importance’.

Furthermore, District Council Policy EN1 relates to land which is within or adjacent the AONB – and Knowle is immediately adjacent to the AONB. And as such, Policy EN1 states that development will only be permitted within or adjacent the AONB where the proposal conserves or enhances the landscape character of the area and respects traditional built form  http://www.eastdevon.gov.uk/reportdc_211008_08.1800.ful.pdf

Proposals under the draft Local Plan to limit Public Rights of Way and to build upwards of 50 dwellings not only fail to meet these criteria but fail to clarify why there should be any change in the boundary designation, which should remain as it was prior to the latest revision.

Summary:

These documents throw into serious doubt the legitimacy and feasibility of the proposed relocation of the District Council from Knowle.

Firstly, relocation threatens to destroy the integrity of the parkland. The stately setting of Knowle – with its combination of magnificent parks, historic trees and palatial proportions – is of considerable importance to the quality and prosperity of Sidmouth.

Secondly, relocation would seriously undermine public confidence in the District Council’s commitment to observing its own stated principles. Many of the proposals relating to Knowle in the draft Local Plan fail to comply either with previous policies or with due process.

Jeremy Woodward
66 Temple St, Sidmouth, EX 10 9BJ
10th June 2012

(Letter from SVA Chair Handel Bennett: 18th April 2008)

A suspended TPO implies that it is temporary action, and will be restored. In this case it seems to have been a convenient way of allowing the destruction of healthy trees, of no danger to anyone, except the financial considerations of the developer. It suggests the re-developer must have intended from the start to destroy these trees, otherwise he would have planned to include them within his planning application.

(Letter from SVA Chair Handel Bennett: 18th April 2008)

http://www.edp24.co.uk/lifestyle/cedar_felling_must_not_set_a_wrecking_precedent_1_457777?ot=archant.PrintFriendlyPageLayout.ot

Members of the public as well as the Sid Vale Association have expressed doubt about the planning process: