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12/1847/MOUT | Outline application proposing demolition of existing buildings (retention of building B) for class D1 non-residential institution and park rangers station (Sui Generis), residential development of up to 50no. dwellings (Class C3 use), 60no. bed graduated care home (Class C2 use) and access (all matters reserved except access) | Council Offices Knowle Sidmouth EX10 8HL
  • Total Consulted: 1781
  • Comments Received: 1743
  • Objections: 1736
  • Supporting: 1

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R Thurlow (Objects)

Comment submitted date: Tue 26 Feb 2013

THE KNOWLE OFFICER'S REPORT.
COMMENTS.
General.
The report acknowledges that there will be severe detrimental economic effect on Sidmouth should relocation take place.. There will be a loss of nearly 30% of the public open space at the Knowle, most of it the formal gardens, and a significant reduction in the total public recreation area within the town. It also acknowledges that the loss of car parking for the park and ride will be a disbenefit. There will be a loss of specimen trees and visual intrusion of the new buildings. Policy E3 in the current Local Plan has not been met, as there is not a surplus of Employment Land in the vicinity.
However the report states that broadly these detrimental effects are overcome by the fact that the same economic benefits will in future arise in Honiton as existsin Sidmouth and in fact will be increased by 12 workers at the Care Home, an unspecified numbers of construction jobs, and the spend of the future residents of the Development. it also finds a newly minted reason in that the development satisfies a requirement for a 5 year land supply in the District.
The report states that there will be employment and economic benefits in Honiton and East Devon as a whole from the relocation. However, as is pointed out in the Report elsewhere points out the application stands alone. Relocation is not being considered and, even if it were, we have not been told where to. Nor has any economic assessment been made of the jobs and economic benefit arising from such a move to an unidentified location.
These are serious flaws and should not permit the Application to be approved.
But nevertheless the Report finds in favour of the development.
We believe that the OP is flawed in permitting the Application for the reasons above. We believe that the OR has a preconceived aim in view; that of allowing the development whatever the rationale against it. It has precisely the same recommendation as in the first planning application, despite the fact that the economic and social effects have vastly deteriorated. It ignores the destruction of the formal gardens on incorrect evidence, it ignores the fact that Policy E3, (which allows development only if there is a surplus of Employment Land in the vicinity) has not been complied with, and ignores the fact the Habitat Regulations have not yet been satisfied.
1. EXECUTIVE SUMMARY
1.1. The statement that that only a small part of the gardens and parkland is taken is incorrect. The area of the Open space is 3.2 Ha; the area taken is 0.9 Ha. This is 28% which is not small. In fact the destruction of 0.9 Ha occurs mainly of the formal gardens. In any event such destruction of open space in an urban area is deplorable and can only be considered as vandalism.
1.2. We would point you to paragraph 2.8 of our objection, which clearly shows that (2.8.6), the figure of 21.86 Ha of Parks and Recreational grounds in Sidmouth is not correct. This is because erroneously the Open Space Study includes the Byes in this figure, which it should not as the Byes is classified as natural and semi-natural open space. The correct figure of Parkland and Recreational Space is 7.45Ha, of which then the 0.9 Ha of Knowle Parkland is a significant percentage. Open space in any town centre is a valuable asset which must not be destroyed irretrievably forever.
The Report is wrong in its assessment that the loss of Knowle Parkland would be insignificant.

1.3. The statement in the 2nd Paragraph The relocation of the Council's offices would lead to a significant loss of Employment in the town and would cause harm to local businesses is clearly very significant. The next statement that This impact is partially compensated by the proposed development and the economic benefits associated with it is clearly unfounded. The loss to the Sidmouth Economy of £3.6m per year, the £1m spent by EDDC employees, and the £0.125 spent by visitors to EDDC, (an underestimate as the OR says) is not compensated to any extent by the spend of the residents of 50 houses and of a2 Care home workers.,
1.4. The Executive Summary states that all reasonable measures are being taken to protect habitats (of European Protected species). That is not the legal test; the Derogation Tests have not been satisfied in this application. The hope that they would be met is not the test.
1.5. Page 6. the statement that the care home would provide badly needed jobs is glossing over the fact that the Care Home might provide 12 equivalent full time carers jobs, which in no way compensates for 380 EDDC professional jobs, the only reason that the Care home jobs might be wanted is the abolition of 380 EDDC jobs
1.6. the Report makes no mention of the fact that Policy E3 of the current Local Plan specifically states that any loss of Employment land MUST be based on a surplus in area. This is patently not the case.
1.7. EDDC's Notes for Guidance on objections, states that these must be expressed as Material Planning Considerations EDDC's list of these does not include wider economic benefits which the OR says overrides the loss of Parkland

2. STATUTORY CONSULTEES' RESPONSES
2.1. Natural England objects to the application as presented.
2.1.1. Natural England's response as reported in the OR clearly states that further surveys of protected species and potential roosts are required prior to determination" of the planning application.
2.1.2. NE further states that the work proposed will require licences, which will be unlikely to be granted without the further survey information recommended by EDDC's own consultants.
2.1.3. The OR proposes that it is legitimate to determine the application without all the survey information.
2.1.4. Our previous objections have set out the legal position regarding the need for further surveys prior to determination and this view appears to be supported by NE.
2.2. The Economic Development manager.
2.2.1. He confirms that any move would impact upon the economic activity and employment in the town. He also says that I am in no doubt that if the changes proposed are approved and implemented, this would have an immediate and a lasting impact on Sidmouth's economy"
2.2.2. He confirms the there are about 58 unemployed in the town; against this the projected figure of 71 job losses is a very significant increase.
2.2.3. Sidmouth employees working in EDDC number over 100. these are professional jobs in an employment area of lower status tourism jobs. IT WILL be a significant loss if these are no longer available.
3. OFFICER'S CONCLUSIONS
3.1. Loss of Employment land Page 33.
3.1.1. The Report states that it is clear that the proposed development would cause significant harm to business and employment opportunities in the town.
3.1.2. LP Policy E3 states that options for the retention of the site must be fully explored, and that there is a clear demonstration of surplus of supply of employment land in the locality THIS HAS NOT BEEN DONE other than a cursory, broad-brush cost of refurbishing the whole EDDC offices, and an examination of the costs of converting the existing old building to a hotel. . The report acknowledges that options have not been explored.
3.1.3. As there is no surplus employment land in the vicinity, Policy E£ HAS NOT BEEN SATISFIED
3.1.4. Even if wider economic benefits were to be established, there is nothing in Policy terms to support the offsetting of a loss of employment land in one specific location with economic benefits in another area of the District.
3.1.5. EDDC itself in documents such as the Report setting out justification for Employment provision in Consultation Draft Local Plan 2011 and the Sustainability Appraisal published in November 2012 has concluded that there is an identified need for 5.0 ha of employment land in the Sidmouth area, and that there are no more suitable alternative sites than a greenfield site within the AONB at Sidford. The evidence base cannot have taken into consideration the resultant loss of employment land at the Knowle should this application be granted. Consequently, to compensate for this loss, a further allocation of employment land will need to be made. Given the apparent lack of suitable brownfield sites within the built up boundary of Sidmouth, an unavoidable consequence of this proposal will be the need for further greenfield, AONB land being required for employment purposes, otherwise there will be a shortfall in employment land provision for Sidmouth over the plan period 2006-2026.
3.1.6. As such, this is a clear disbenefit of the application which does not appear to have been taken into account by the OR, and adds significant weight to the arguments for refusal of the application.

3.2. Loss of Parkland and Open Space
3.2.1. The OR says that 22% of the Parkland will be lost. In fact the figure is 28%. This is a significant figure.
3.2.2. The standards laid down in the EDDC OSS report says para 5 the standards that are proposed are for MINIMUM guidance levels of provision
3.2.3. OSS states that, para 7.5.1, the starting point of any policy adopted by EDDC should be that all open space should be afforded protection unless it can be proved that it is not required. NO SUCH PROOF HAS BEEN PROVIDED.
3.2.4. Para 7.5.3 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 The vast majority of expressed local opinion is in favour of maintaining the whole of Knowle Park as an amenity open space, as has been demonstrated by significant numbers of objections to the proposal and public protests. This is echoed by the decisions of the elected representatives on STC Planning Committee.
3.2.5. Para 7.5.3 Policy R3 Sites which have nature conservation, historical or cultural value should be afforded protection, even if there is a surplus in quantity, quality or access in that area. The Knowle site qualifies for protection in all three categories
3.3. Transport Issues.
3.3.1. This report did not investigate the current traffic figures on Knowle Drive, nor the bad visibility at it's southern exit with Station road. Any increase in traffic at this point is dangerous.




Comment submitted date: Tue 05 Feb 2013

please see letter received on 1 February 2013 on the document tab of our website

Comment submitted date: Mon 19 Nov 2012

please see letter received on 16 November 2012 on the document tab of our website

Comment submitted date: Mon 24 Sep 2012

Please see letter received on 19 September 2012 on the document tab of our website

SC Copelin (Objects)

Comment submitted date: Wed 13 Feb 2013

please see letter received on 13 February 2013 on the document tab of our website

Comment submitted date: Tue 06 Nov 2012

please see letter received on 6 November 2012 on the document tab of our website

Comment submitted date: Wed 19 Sep 2012

Please see letter received on 18 September 2012 on the Document tab of our website

P Brookes (Objects)

Comment submitted date: Tue 12 Feb 2013

St Francis, Cotford Close Sidbury
Sidmouth
Devon
EX10 0SJ



25th January 2013
Dear Mrs, Herbert,

TOWN AND COUNTRY PLANNING ACT 1990
OUTLINE APPLICATION PROPOSING DEMOLITION OF E X ISTING BUILDINGS
(RETENTION OF BUILDING B) FOR CLASS D1 NON-RESIDENTIAL INSTITUTION AND PARK RANGERS STATION, RESIDENTIAL DEVELOPMENT OF UP TO 50 DWELLINGS (CLASS C3 USE) 60 BED GRADUATED CARE HOME (CLASS C2 USE) AND ACCESS (ALL MATTERS RESERVED EXCEPT ACCESS).
COUNCIL OFFICES KNOWLE SIDMOUTH EX10 8HL

I refer to your letter of 16th January, your reference HN3/12/1847/MOUT.

I would like to confirm that I wish all my previous objections and comments to be included with the contents of this letter.


My comments on your latest efforts are as follows:-

1 EXTRACT OF MARKET ASSESSMENT REPORT AND VALUATION

Only extracts from the Valuation Report prepared by the consultants Thomas Lister have been used. I'm surprised the public hasn't been allowed to see the whole report. Are you only publishing the parts which fit in with your own objectives?

These 'extracts' indicate that the report is written in a very unprofessional way in which conjecture, not facts, play a large part. Thomas Lister seem to be adopting a "back of an envelope" approach in their judgment that if the existing Knowle buildings were offered for rent or sale as office space, only 10/20 out of the existing 100 rooms would be taken up. Surely, when doing any form of market research it is necessary to obtain positive information by investigating the demand, which Thomas Lister hasn't carried out, via nationwide business agencies to ascertain the national as well as the local demand. There could well be some organisations which would be interested in such a unique location for a variety of purposes, as well as commercial offices, i.e. a conference centre, staff or educational training. These are uses which would be acceptable to the people of Sidmouth as long as our access to the gardens and parkland is assured.

It has been noted that, although this report is dated September 2012, it wasn't included in your two previous planning submissions. This has led many people to suspect that the timing of the release was deliberate as it is after the cut-off date of 14th January for the Local Plan objections.

It also appears that Planning Policy E3 of the Local Plan has not been complied with.




2. BAT MITIGATION REQUIREMENT TO INFORM DESIGN REPORT &
SUMMER, AUTUMN AND WINTER BAT REMOTE DETECTOR SURVEYS

In order to obtain a European Protected Species Licence (EPSL) from Natural England to enable you to grant Full Planning Permission to a developer, it is necessary for various additional surveys to be done. Many of these surveys have not been carried out and until such information is included with their outline planning application it will be difficult for the E.D.D.C. to give a prospective developer enough information to know that such mitigation in respect of bats is necessary and to show Natural England that they will in principle be able to issue an EPSL. This could affect the value of The Knowle hugely and also your calculations for 'cost neutrality'.


On a more general note, when I have attended recent E.D.D.C. Public meetings I have been disappointed by the arrogance & discourtesy shown to the public and to dissenting Councillors, by certain individuals, which amounts to a lack of democracy. I do hope that the Planning Meeting on 1st March will be conducted in a rather more professional atmosphere.

Finally I would like to complain about the length of time which you have given us to submit in our comments, i.e. by 1st February, only 14 or 15 days, which many residents will find inadequate, particularly those (and there are quite a high percentage) who are not on the internet and might have difficulty getting to your offices to see the reports you list.


Yours sincerely,




Peter Brookes


Mrs A. Herbert,
For Head of Economy,
E.D.D.C.,
Knowle,
Sidmouth.
EX10 8HL.

Comment submitted date: Tue 18 Sep 2012

Please see letter received on 13 September 2012 on the Document tab of our website

S Mathews (Objects)

Comment submitted date: Fri 08 Feb 2013

please see letter received on the document tab of our website

Comment submitted date: Wed 07 Nov 2012

I am writing to you concerning the modified proposals with the above reference that were published by your letter dated 18 October 2012.

I have to say that although EDDC have added a number of documents that were incorrectly omitted in the earlier version of this proposal, they do not, in my view, make any addition of a substantive nature to the accuracy of an actual proposal, and, therefore, do not in any way address the scope of my concerns expressed in my previous letter to EDDC on the subject. That was listed as received on your web site so I do not intend to reproduce it here.

I again make the point that the document setting out the economic justification for the proposal is flawed as to application of its methodology, its approach to analysis, lacking demonstrable sources to key factors used in the development of the focus of those analyses and using unproved assertions as if they were demonstrable fact. In short, in my view, the document is inadequate and not fit for the stated purpose. Since the entire project rests on that document, the project cannot be sustained until such time as a robust and verifiable paper that can be generally accepted has been produced and published for review.

The actual details of the proposals are reserved (except for access) so it is not possible to come to any conclusion as to the appearance, suitability, positioning or character of what may be finally developed.

However, the current disposal of the parkland and associated agricultural use areas of the overall plot are such as to provide a very specific ambience to the plot in general - that of being a major area of parkland, not overlooked and relatively well screened from surrounding buildings (whether EDDC or otherwise). Although there may be extensive car parking areas, these are relatively discreetly hidden from view by the natural shape of the land.

The parkland is not 'a recreational area' such as is provided for at the Ham, nor the connector land characterised at The Byes, and it would be more than just a technical error to attempt to pass it off as such. The defining characteristic of the parkland will be significantly harmed by the imposition of high density high rise housing units where there are none today. These will have the effect of hemming in the parkland with comparatively high rise buildings that are inappropriate in nature and appearance, and converting the appearance from a grand estate to a town square, such as Ladbroke square in Central London.

The proposed building suggested to be on existing outline footprints will remove the current screening of shrubs and medium height bushes, significantly altering the appearance and reducing the enjoyment of the current parkland. The change from low level car parking to high level buildings at the Northern end will also have the same effect. Existing buildings are only screened from the view of the pedestrian by the combination of low, medium and high level bushes and trees that counteract the steep slope of the land. Without that screen the building(s) will dominate the landscape and view, converting the appearance from parkland to a housing estate.

For these, and my previous reasons set out in writing, I object to the proposed development.

Comment submitted date: Tue 25 Sep 2012

Please see letter received on 19 September 2012 on the document tab of our website

Mrs Jacqueline Green (Objects)

Comment submitted date: Fri 08 Feb 2013

please see letter received on 7 February 2013 on the document tab of our website

Comment submitted date: Thu 07 Feb 2013

KNOWLE PUBLIC CONSULTATION Comment on OPA: 12/1847/MOUT
Jacqueline Green , 7th February 2013
My additional comments, on the latest revised Outline Planning Application for the Knowle, are as follows: (a copy, in pdf file, has been sent earlier today to Mrs Anna Herbert, as it includes essential photographic evidence referred to here, which is excluded on this online site).

I strongly support all the objections put forward by SOS in their representation.
I wish to make 5 points further to my earlier representation, which still stands.
1.The relocation of EDDC HQ to Honiton would increase travel distances for most of the population. This does not fit with EDDC¿s vision for more sustainable, low carbon policies. The argument that new offices would be more central, is based on opinion, not fact as the chart below (based on 2011 census figures) shows:
  Mileages Between Towns

EDDC @ Mileage advantage by population (2011) EDDC @ Mileage advantage by population (2011)
Town Sidmouth (mileage) Honiton (mileage)
Axminster
  15.7
  n/a 10.1 6,828
Exmouth
  10.9 35,939 18.5
  n/a
(inc Budleigh Salterton)
 
Honiton
  9.9
  n/a
  0
  11,623
 
Ottery St Mary
  6.6
  n/a
  5.8
  8,820
Seaton
  10.1 7,332 11.2 n/a
Sidmouth
  0 13,930 9.9 n/a
POPULATION BENEFITING FROM LOCATION OF EDDC IN:
  Sidmouth 57,201 Honiton 27,271

further to travel
data:
  see Town Profiles
 
www.devon.gov.uk


2.The destruction of Knowle, which this OPA entails, ignores the site¿s heritage value to future generations. The photographic evidence below (2 photos), endorses the representations by official bodies including SAVE Britains¿ Heritage, Devon Gardens Trust and the Victorian Gardens Society.


3.The ecosystems which safeguard a flourishing community, have not been recognised in this OPA. Knowle parkland is part of Sidmouth¿s Green Corridor (see addendum to the representation by Graham Cooper). Nor has the ¿natural capital¿, on which our local economy is based ( HRH Prince Charles explains this new understanding of 21st Century economics in his foreword to ¿What has Nature ever Done for Us? How Money Really Does Grow On Trees¿, the new book by Tony Jupiter). The recently launched Civic Arboretum, of which Knowle parkland is an important part, is another unique attraction for East Devon to be proud of, and an educational resource not to be discarded. ¿Old Monty¿ (see below)can only be properly understood, ecologically and historically, in the current appropriate setting.

The Knowle parkland has the thickest Monterey Pine in the whole of the UK. In 2009, it¿s vital statistics were: height 120 ft. girth 20ft 4 ins (source: waymarking.com.) . The same source gives this description:
Monterey Pine, although now rare in its native California, is one of the world¿s most valuable pines and is the most widely commercially planted one especially in New Zealand, Australia, Chile, Spain and South Africa. This is due to its rapid growth (up to six feet per year) and adaptability to poor soils.
Monterey pine is also used extensively in landscaping as a windbreak to prevent erosion, and to quickly provide variety and contrast with its attractive foliage. In their native habitat along the Pacific coast, Monterey pines are famous for their wind-swept, picturesque shape. On very hot days the pine cones can burst open emitting a loud snapping sound.
The old & wrinkly gnarled tree situated in this Sidmouth park has its place in record books as having the biggest diameter of its kind in the UK. Some of the large branches are now so heavy that cables have been attached to prevent them from breaking.
4.There is no publicly available evidence that alternative options for the former hotel, have been seriously explored and properly costed. Retrofit of existing buildings is the most efficient way of reducing carbon emissions (see representation from Derek Chant of Sid Valley Energy Action Group). The Department Of Energy and Climate Change have recently chosen this option for their own ageing HQ building. Converting the old hotel into flats again, (with one or two bedrooms?) might fit local needs better than this speculative OPA option. Retrofit of the present newer Knowle offices is likely to be a cost effective way for EDDC to manage their expected downsize.





5.Only an informed decision on this OPA 12/1847/MOUT will be the right one for everyone in East Devon. The value of the link between past, present and future will doubtless be taken into consideration. My representation therefore ends with the view of someone who has knowledge of ¿the whole of the Knowle¿ .

An  interview with John Govier in the Sidmouth Herald 21st September, 2012. (Reproduced with his permission)
The last living member of Sidmouth Urban District Council says development must be resisted
 THE last living member of the former Sidmouth Urban District Council has issued a plea for developers to keep their hands off the Knowle ¿ telling the Herald: ¿It¿s part of our heritage¿.
John Govier is also one of the few remaining founders of East Devon District Council (EDDC) and has reminisced on how the headquarters were bought for just £65,000 ¿ and a covenant was placed on the land.
Sidmothian Mr Govier, 72, who served the town as a councillor for around 20 years, has also branded refurbishment figures for the Knowle as a ¿hype¿ and ¿softening up¿ process for the ratepayers as EDDC looks to relocate to Honiton.  
¿The Knowle site is unique in Sidmouth and any attempt to develop it should be firmly resisted,¿ he said.
In a three-part special beginning in today¿s Herald, Mr Govier recalls his memories of local government and how they relate to hot topics today.  
Here he explores the Knowle since the war and its future.
¿The Knowle Hotel continued after the war as a British Rail hotel. Situated near the railway station, it occupied an unparalleled view down the Sid Valley to the sea and has some of the most beautiful, mature parkland grounds in Sidmouth ¿ and still has,¿ said Mr Govier.
¿The Knowle Hotel itself in those days had a certain grace and style about it. It had one of the best ballroom dance floors in the west of England, and was popular with both holidaymakers and locals. I, personally, can recall many a happy Boxing Night and New Year¿s Eve spent at the Knowle Hotel.
¿It was sold with the Beeching railway axe and the Knowle Hotel Co acquired it and ran it very successfully until it was purchased by Sidmouth Urban District Council (SUDC) in 1971.
¿The SUDC council offices were then at Norton Garth, next to the putting green.
¿The deal was virtually done overnight and Norton Garth was sold for about £22,000 and the Knowle Hotel purchased for £65,000, as I recall.
¿Very few councillors at the time knew what was going on and when it came before the SUDC it was a fait accompli.
¿Sidmouth UDC was aware that changes were coming to local government and that the Radcliffe Maud report was adopted and that local authorities, urban district, rural district etc would be amalgamated forming district councils. What our precise area would be, we did not know then.
¿Ted Pinney (former SUDC leader) had in mind the Knowle becoming the headquarters for the future East Devon District Council (EDDC). This, we know, is what happened ¿ but Sidmouth had lost the first of its major hotels, and a good one!
¿A good step or a bad step, I don¿t know, but at least Knowle was safe from developers and its unique grounds would be cared for. I recollect that we put a covenant on the grounds.
¿The Knowle building was far too big for the SUDC¿s needs and so roughly half the building was turned into council flats.
¿So EDDC duly came about in 1974. After a while more office space was needed and EDDC bought the Brinkburn Hotel (opposite the Manor Pavilion), turned the Brinkburn into flats and moved the Knowle flat tenants to the Brinkburn.
¿Sidmouth is fairly central in East Devon and its acquisition by EDDC from SUDC has probably saved ratepayers thousands, if not millions, of pounds over the years, and, as we all know, the capital cost of building new council offices would run into millions after they acquired it for nothing. And why build new council offices now? What guarantees are there that the EDDC will still be there in 10 years.
¿To be absolutely blunt, the seemingly undemocratic way that the EDDC is being run at the moment, I don¿t see many ratepayers, especially in Sidmouth, losing any sleep if EDDC were to be succeeded by a better council.
¿How I wish we still had SUDC ¿ we could look after ourselves and be masters of our own destiny again ¿ and we understood Sidmouth and made it what it is.
¿My verdict on the proposals for Knowle is as follows:
1. Firstly, the future of any successful local government lies in doing things in a democratic way; and that the elected members are seen to be running the councils ¿ not the officers ¿ and the Knowle is a typical case in point;
2. The Knowle site is unique in Sidmouth and any attempt to develop any of it should be firmly resisted;
3. Should the EDDC depart from Knowle, then it is vital that the car parks are retained for public use ¿ Sidmouth is desperate for more car parking;
4. The parkland and many exotic trees in Knowle must be retained and cared for - it is part of Sidmouth¿s heritage, and our own councillors must protect our heritage; it is their duty to do that.
¿The figures coming out of Knowle at the moment for ¿refurbishment¿ are a hype, and I see them no more than a ¿softening up¿ process for the ratepayers. Are they saying that every door needs replacing? If Knowle was in private hands now, and run by businessmen, it would be a different matter. In business you do things when you can afford them ¿ but, of course, with councils they are not spending their own money, because it is all of us, the ratepayers, who foot the bills.¿

End of additional comments on EDDC¿s revised OPA12/1847/MOUT
Jacqueline Green
Sidmouth 7th February, 2013

Comment submitted date: Fri 16 Nov 2012

Please add to my previously registered comments (Planning Application 12/1847/MOUT) the following comments objecting to the amended Plans.

I strongly object to the amended Plans as they contravene National Planning Policy guidance and law.They do not meet requirements for Environmental Impact Assessment Regulations 2011, nor Conservation of Habitats and Species Regulations 2012.

Moreover, the Plans are based on Heritage and Traffic statements which are incomplete (See Sid vale Association Objection, Sections 3 and 5).

The ill-conceived and publicly uncosted relocation to Honiton risks a huge bill for taxpayers. The cost and reasoning are dubious.
The price for Sidmouth in loss of office jobs, heritage (buildings and historic trees), public green space, and essential discreet car parking, is too high.

Ms Clare Eastland (Objects)

Comment submitted date: Fri 08 Feb 2013

EDDC Planning Application 12/1847/MOUT
I wish to object to the revised plans for the Knowle.
Please add to my previously registered comments (Planning Application 12/1847/MOUT) the following comments objecting to the amended Plans.
The following are the main points I wish to make on the revised plans.
The original and revised plan for redevelopment of The Knowle should be rejected in its entirety.

The most recent plans do nothing to alleviate concerns raised in response to previous plans. EDDC show no duty of care or concern for the town of Sidmouth, nor any understanding of the importance of tourism and the environment and individuality of the town as its main attraction. The new plans are even more detrimental to the local environment in terms of height and impact. The amendment includes an increased number of housing units and destruction of further trees and so exacerbates the harm caused. The changes will 'save' 2 of the wonderful tress only and include further restriction of public access to the parkland.
A full ecological survey of the site has not been presented. The amended Plans as they contravene National Planning Policy guidance and law. They do not meet requirements for Environmental Impact Assessment Regulations 2011, nor Conservation of Habitats and Species Regulations 2012.
The Plans are based on Heritage and Traffic statements which are incomplete (See Sid vale Association Objection, Sections 3 and 5).

Additionally:
1) EDDC do not provide enough evidence to show that this move should be made.
2) The cost comparison figures seem very dubious. EDDC must have an on-going maintenance budget which would be needed wherever the offices were situated, but this has not been taken into account.
3) There has been no Environmental Impact Assessment. The loss of park and gardens shows lack of compliance with UK and EU wildlife legislation.
4) The Knowle and its parkland are not allocated for housing in EDDC's adopted Local Plan nor in the new draft local plan. It is designated as recreation land under policies RE1/RE4. This application is contrary to EDDC adopted Local Plan. There is no justification for the significant departure from policy.
5) As there are no solid grounds or evidence to approve a major departure from policy, the plan should not be brought forward for determination until after the Local Plan Examination in Public next spring. If the application is brought forward earlier than this it should be refused as it undermines the adopted Local Plan.

Ownership
Knowle was bought for the people of Sidmouth by the Town Council - EDDC took that over - the whole site rightly belongs to the people of Sidmouth in perpetuity, NOT EDDC, and should not be sold off.

Cost
1. The sale of land could not be made at a worse time, while land values are at their lowest, large numbers of the existing housing stock on the market plus the developments still being erected.
2. EDDC has not explored other options for achieving their wish to reduce operating costs.
3. The uncosted relocation to Honiton risks a huge bill for taxpayers.
4. The price for Sidmouth in loss of office jobs, heritage (buildings and historic trees), public green space, and essential discreet car parking, is too high.
5. If EDDC believe it to be beneficial cost wise to relocate to Honiton then the whole of the EDDC taxpayers should be expected to fund the move rather than one small town in the district.
6. The huge cost of this application so far could have updated the present building and preserved the parkland.
7. As the planning applicant is using public funds, this should be counted in the decision making. We would like to know who is benefitting from this plan?
8. EDDC should publish its full commercial assessment of the office relocation proposal for scrutiny by community charge payers. Unless this is done the only conclusion that can be drawn is that this development and relocation proposal is driven solely by profit motives and should therefore be considered as such and determined by an independent third party rather than by EDDC itself.


Sustainability
1. In government policy sustainability is key to development, and yet the plans for relocation are far more costly in terms of carbon emissions and will take far longer to offset. Refurbishment is socially and economically more viable than building new premises and that it would take 50 years before the carbon used in constructing a new building is repaid by subsequent carbon saving in its use. With this in mind how can the Council justify any move?
2. 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 or rent out the historic Knowle buildings to contribute further to the provision of renewable energy installation, probably leaving a balance of funds for other projects. These steps could be taken with minimum environmental damage and no impact on greenfield land or ecology whatsoever.

Economic impact
1. Economic Impact Assessment Report appears to use figures supplied by Save Our Sidmouth/Sidmouth Chamber of Commerce so can be accepted as accurate. However, too many of the best paid jobs in Sidmouth will be lost.
2. Tourism value - the Knowle is at a strategic gateway to the town - visitors will have a view of houses and a care home rather than the unique parkland with wonderful old trees which helps to set the scene for arrival into Sidmouth.
3. The loss of parkland and spoiling of a town labeled the 'Jewel in the Crown' for East Devon tourism on the UNESCO heritage coast has an economic impact.
4. The loss of park and ride has an adverse economic impact on the town.

The building
1. The Knowle is a significant and prominently-placed local landmark, in and overlooking a public park. Although altered due to change of use, the building has retained its external character created in the 1890s, which reinterpreted features such as the veranda from the older cottage on the site. Internally, the building retains features such as a Delft tiled fireplace and Pugin wallpaper.
2. A conservation area review of Sidmouth produced in recent years states that the area north west of the existing conservation area up to The Knowle should be assessed for potential inclusion in the designation. It points out that the first Sidmouth building noted in the original conservation area appraisal is Knowle Cottage, the earlier building on the site from which the surviving 1890s building was developed. This clearly acknowledges its significant place in the historical development of the town.
3. Given the status of The Knowle as a local landmark retaining many features of interest, the building should be considered a non-designated heritage asset. According to clause 135 of the NPPF,
"In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgment will be required having regard to the scale of any harm or loss and the significance of the heritage asset."
4. The heritage statement attached to the application does not provide any assessment of the significance of the main building and of the loss that would result from its demolition, focusing instead almost entirely on the listed summerhouse. The lack of information means that a balanced judgment cannot be made about the loss of the non-designated heritage asset.
5. The original Knowle hotel building, at least, should not be demolished, but be offered for sale or rent.
6. If EDDC are determined to move to Honiton, then mixed use of current buildings area only - offices or hotel use, crafts, art gallery - all would add to tourism - better use than residential which puts pressure on facilities such as medical. Parkland should revert to ownership by Sidmouth - e.g. by Sid vale Association.

Parkland
1. Our understanding was that the parkland and gardens had been acquired as a local green space for the enjoyment of the residents of Sidmouth. EDDC now claim they are unable to find any documentation to prove this to be true. Please see this link http://www.eastdevon.gov.uk/lp-repsf.pdf which supports residents' views that the Knowle was acquired for, and has been treated as, a public open space since 1973. Over the years it has been used by walkers, dog walkers, picnickers, young families, as well as a venue during Folk Festival week. It is a well known and much loved landmark for tourists/resident alike.. It has a fine selection of trees and buildings. To lose this valuable open space in town will disadvantage disabled people unable to access the footpaths in the surrounding hills.
2. Sidmouth does not meet even the MINIMUM requirements for recreational land for its population size. 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 any alternative areas. It must therefore be rejected by the EDDC Planning Committee.
3. The Parkland at least should revert to ownership by Sidmouth - e.g. by Sid vale Association.
4. A Devon Open Space report includes acknowledgement that the parks and open spaces of the Knowle are noted as special and placed alongside Killerton and Connaught Gardens as recreational areas to be enhanced and cherished. These plans contradict and eradicate this recognition.
5. The current application is gross over development of the parkland. The original footprint of the current buildings should be adhered to, not including the temporary structures which should have already been removed as planning for them has expired. I believe EDDC are already in breach of the terms of an earlier planning application in that permission to have temporary structures on site has now lapsed and yet these temporary buildings remain. Thus including these buildings as part of the current footprint is misleading.
6. There is no justification for losing more natural open space in the town and no justification for change of use of the land from employment land to residential land.
7. The Arena provides a natural theatre and could provide excellent concert space through the summer which would be a tremendous boost for locals and tourism.
8. Public rights of way are being lost. Recently EDDC tried to claim as their own private land with notices warning of no rights of way.
9. Installing flights of steps in the park which would effectively deny access not only to wheelchair- and pushchair-users but also to the frail and infirm. This beautiful parkland, like any other, should be accessible for all to enjoy.
10. The Zone C proposals require removal of trees which should have preservation orders in place, and will see the disappearance of footpaths crossing scenic open space. As the area around the Knowle has already been designated for use by the public of Sidmouth (1973),how can the council justify any change in its status?
11. The provision has now been increased to 26 houses, not the original 19 and is a gross overprovision. This will also see more trees felled and will again cause irreversible damage Zone C now has provision for 26 3 storey houses, instead of 19. This is a gross overprovision in a residential area.
12. 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.

Trees
1. The Knowle landscape and parkland trees form the core of the world's first community Arboretum and bring to the District benefits which have not been properly assessed.
2. The recommendation from Natural England for a full ecological and environment survey to be commissioned has not taken place. The arboricultural survey has not provided information on wildlife use of the trees. There is no reference to landscape considerations in an urban setting.
3. Trees contribute to carbon sequestration, carbon storage and removal of atmospheric pollution. This information is not available for our District. Neither have trees been surveyed for their role in flood prevention and erosion control, factors which will be crucial to the success of development plans.
4. The Council must obtain the relevant survey reports to enable the restoration of Knowle parkland and gardens to fulfil its role in a vibrant and economically robust Sid Valley. Only then can responsible development of the building be considered.

Wildlife
1. The additional information regarding the welfare of the resident bat population will still be insufficient to satisfy Natural England and enable the required licence to be issued. Hopefully any independent Planning scrutiny will reject the proposal on this basis and any developer be dissuaded. I do not see the disruption of the local wildlife as an acceptable price to pay under any circumstances
2. The Bat survey only concerned the Knowle building NOT surrounding parkland Lesser horseshoe roots in attic of high conservation significance - no other known roots this size in Devon LH bats very sensitive to disturbance and lighting, vegetation removal and even pruning 10 trees scheduled for removal will be important for bats. ( also hedges) - more surveys required.
3. Wildlife Consultants recommend 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.
4. Devon Wildlife Consultants recommend which should be obligatory to avoid contravening UK and EU wildlife legislation.. the mature woodland and vegetation should be retained and enhanced in order to retain the historic nature of the site in order to provide foraging for bats, badgers and other mammals, invertebrates and birds; this is not planned.

Traffic and parking facilities
1. The access road to/from the site is the smallest narrowest road to/from the A3052 and is already a major cause of congestion.The one day traffic survey is in itself flawed and overtly light-weight. Whilst coaches and cars frequently try to squeeze past each other on the road into Sidmouth adjacent to this land,


I also wish to object to the reaction of the EDDC to legitimate expressions of concern from the local population. The arrogance shown in denigrating the people's opinion plus the attempts to minimise the number of people involved in the protest on November 3rd is scandalous. Public access to information has also been denied.

EDDC and its representatives frequently refer to the views it chooses to dismiss as the views of the elderly population. Discounting the views of the objectors on the grounds of age is illegal.

The plans completely go against the spirit of the Localism Act 2012. 4000 residents marching in protest against the plans in 2012.The Statement of Community Involvement is dated 23rd August. It is clearly out of date; there has been much public involvement since that time. The document should reflect these issues.
East Devon District's deciding on its own application is not following natural justice - as it is both applicant and judge
"As this application contravenes planning policy, guidance and law and fails to satisfy the requirements of the Environmental Impact Assessment Regulations 2011 and the Conservation of Habitats and Species Regulations 2012, outline planning permission should be refused."

Proper process should be followed, with accurate accounting of such things as the amount of recreation land in Sidmouth. The Knowle and its parkland was given to the people of Sidmouth, not to EDDC. If this development goes ahead it will be robbery by EDDC. This is a disgraceful proposal given the position of Sidmouth within the UNESCO world heritage coastal area.
Yours sincerely,
Clare Eastland
29 Sidford High St
Sidford,
Sidmouth,
Devon EX190 9SN

Comment submitted date: Thu 15 Nov 2012

Attention Mrs A Herbert,
EDDC Planning Application 12/1847/MOUT
I wish to object to the revised plans for the Knowle.
I wish my previous objections and comments made to the earlier application to stand.
The following are the main points I wish to make on the revised plans.
1. The Knowle has bats and other wildlife and there needs to be a protected species survey. Habitats such as the Knowle are becoming increasingly rare in Sidmouth and elsewhere.
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. The alternative would be to leave the parkland undeveloped as Sidmouth Town Council suggests.
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
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 the vicinity, where a proposal involves the loss of Employment Land. This has not been established. The provision of more houses and unsightly concrete will impact on the wildlife biodiversity and attractiveness of the whole area and is therefore likely to reduce the number of visitors coming to the area and have an adverse effect on tourism and tourism-related employment.
4. Para 2.27 asserts that the proposal does not envisage the loss of employment of Council staff. Para 3.10 acknowledges the loss of 55 jobs in the Sidmouth area. Also the loss of tourism jobs ¿ see above.
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 of 0.89ha 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. The criteria have not been met. EDDC have calculated the provision of recreational land incorrectly as the byes are NOT parks but natural and semi-natural open space. In fact Sidmouth does not meet even the MINIMUM requirements for its population size, and we should also take into account the requirements of visitors and tourists and the need to keep Sidmouth looking attractive in order to attract tourists.

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, with 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 asserts 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 any 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. This is likely to have an adverse impact on trade and therefore on employment in the town.
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. Cars would still have to go to and from any such facility and it is doubtful whether people would bother to use this as it is quite a way out of town.

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.
I do not think any additional buildings should be built at Knowle. It should remain as recreational land, with the redevelopment of the Knowle house to house EDDC and any other suitable businesses. This would be the most sustainable long term solution.
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. Views will be affected as far away as Sidford Hill and Soldiers Hill ¿ I can see the Knowle trees from my house on Sidford High St.
3. The Knowle house is in itself a part of Sidmouth¿s heritage and should be maintained and redeveloped.

Proper process should be followed, with accurate accounting of such things as the amount of recreation land in Sidmouth. The Knowle and its parkland was given to the people of Sidmouth, not to EDDC. If this development goes ahead it will be robbery by EDDC. This is a disgraceful proposal given the position of Sidmouth within the UNESCO world heritage coastal area.
Yours sincerely,
Clare Eastland
29 Sidford High St
Sidford,
Sidmouth,
Devon EX190 9SN

Mr G Cooper (Objects)

Comment submitted date: Fri 08 Feb 2013

please see email received on 7 February 2013 on the document tab of our website

Comment submitted date: Thu 15 Nov 2012

EDDC Planning Application 12/1847/MOUT

Dear Mrs A Herbert,

As you are aware the Knowle Park was designated a green wedge of open recreational space for the health and wellbeing of the residents and visitors to the resort.

Although as a single application it must be refused, each zone in turn fails to satisfy basic planning criteria.
Zone A The "grasscrete" car park is open public space and not brown field. The w/e car parks should be retained for the use of visitors to the town.
Zone B The large care home proposal is surplus to requirement and is not part of the N.E.W. Devon Clinical Commissioning Group's capital programme. Such facilities are already available at the mothballed Stowford Lodge which stands idle and the under-used Green Close.
Zone C This is a gross overprovision in a residential area and the houses cover the existing south upper lawn, a designated "recreational area" There has also been no application for a change of use nor has the loss of employment land in the town with an alternative supply been provided.
Zone D The depot is a temporary installation and the land is designated green space see EDDC planning application. 08/0850/FUL
Zone E There is a great loss of "recreational land" particularly on the west side of the town, where other such green open space land is non-existent.

There is no evidence or demand for the extra homes and the above proposal represents opportunism on behalf of a selfish small number of councillors who have lost all sense of their public responsibilities and civic propriety. We trust the inspector will take note of the considerable opposition within the district to this extremely unpopular proposal.

Comment submitted date: Wed 19 Sep 2012

Please see letter received on 18 September 2012 on the Doument tab of our website

Mr R Day (Objects)

Comment submitted date: Fri 08 Feb 2013

Dear Mrs Herbert

Kindly add the following to our previous letters of objection and we wish any previous objections and comments made to the earlier application to stand:

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 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 the 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 the 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 of 0.89ha 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, with 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 asserts 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 any one time) will have a great effect since there are only 329 long stay car parking 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 story houses are shown in a straight line some 13m 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.



From: ROBERT AND MARGARET DAY
4 RIDGEWAY CLOSE, SIDBURY, EX10 0SN


NB; KINDLY ENSURE THAT THE ABOVE ADDITIONAL REPRESENTATIONS ARE ADDED TO BOTH OF OUR PREVIOUS INDIVIDUAL RESPONSES TO THIS APPLICATION.


Comment submitted date: Wed 19 Sep 2012

Please see letter received on 17 September 2012 on the Document tab of our website

Mr Adrian Davey (Objects)

Comment submitted date: Thu 07 Feb 2013

To just say that The Knowle is no longer "fit for purpose" is inadequate without explanation, alternative scenarios and costings.

The application should be returned until this is properly addressed.

Mr Anthony (Tony) Green (Objects)

Comment submitted date: Wed 06 Feb 2013

The Response of Tony Green to OPA 12/1847/MOUT
I remain strongly opposed to this shameful outline planning application which contemptuously ignores the wishes of large numbers of Sidmouth residents to maintain the Knowle parkland and gardens as an important local amenity.
This application is being rushed through purely to achieve the ¿Council ambition¿ to relocate to Honiton. The specious arguments advanced to justify this move are entirely irrelevant as planning considerations.
My objections to this application are:
1. The inevitable destruction and degradation of the gardens and parkland by the construction proposed contravenes Policy E2 (4.29) of the adopted Local Plan which protects Land of Local Amenity Interest Within and on the Edge of a Settlement.

2. Knowle park and gardens are designated as recreation land in the adopted Local Plan. The proposed development would seriously reduce the scope for local people to continue to use this land as they have done for many years for sport and recreation. This contravenes Policy RE 1 of the adopted Local Plan which specifies
The Retention of Land for Sport and Recreation.

3. Development of the scale proposed would damage this area¿s character as a flourishing wildlife habitat close to a town centre in contravention to adopted Local Plan Policy EN6 which gives protection to Wildlife Habitats and Features.

4. The application assumes a change of land use from employment to residential, and would result in the loss of over 300 well-paid jobs in Sidmouth. There is currently no compensation for this massive loss. This contravenes Policy EN3 of the adopted Local Plan which calls for the Safeguarding of Employment Land and Premises.


5. The loss of an extensive year-round park and walk at Knowle will have a serious negative impact on the limited availability of parking in the town, and could well affect the vitality of town centre commerce.

6. I have lost all confidence in the ability of council officers and consultants to produce a reliable Economic Assessment.

Tony Green, Sidmouth resident,
23 Cotlands EX10 8SP

Comment submitted date: Thu 08 Nov 2012

In addition to my previously expressed objections to the first application which still apply , I object to the revised application on the grounds that it contravenes provisions of the National Planning Policy Framework (NPPF), 2012.
The proposed destruction of the Knowle parkland and gardens which have been open to the public for decades is contrary to:
a) article 74 of the NPPF which states that existing public open space should not be built upon.
b) article 75 of the NPPF which states that planning policy should protect public rights of way and access.
c|) article 76 of the NPPF which states that local communities should have the right to decide on local green space provision. This precipitate application, were it approved, would pre-empt this important right.

Tony Green
23 Cotlands
EX10 8SP

Comment submitted date: Tue 18 Sep 2012

I am strongly opposed to this shameful outline planning application which contemptuously ignores the wishes of Sidmouth people to maintain Knowle parkland and gardens as an important local amenity.
It is reprehensible that this application is being rushed through before the adoption of the draft Local Plan. It is so fatally flawed that were it submitted by any outside developer it would be dismissed without question for the following reasons:
1. The inevitable destruction and degradation of the gardens and parkland by the construction proposed contravenes Policy E2 (4.29) of the adopted Local Plan which protects Land of Local Amenity Interest Within and on the Edge of a Settlement.
2. Knowle park and gardens are designated as recreation land in the adopted Local Plan. The proposed development would seriously reduce the scope for local people to continue to use this land as they have done for many years for sport and recreation. This contravenes Policy RE 1 of the adopted Local Plan which specifies The Retention of Land for Sport and Recreation.
3. Development of the scale proposed would damage this area¿s character as a flourishing wildlife habitat close to a town centre in contravention to adopted Local Plan Policy EN6 which gives protection to Wildlife Habitats and Features.
4. The proposal to funnel traffic from the development into the narrow, residential, Knowle Drive which issues either in a notorious ¿pinch point¿ in Station Road or at a blind junction in Broadway contravenes adopted Local Plan Policy TA7 which requires Adequacy of Road Network and Site Access in any new development.
5. The application assumes a change of land use from employment to residential, and would result in the loss of approximately 300 well-paid jobs in Sidmouth. There is currently no compensation for this massive loss. This contravenes Policy EN3 of the adopted Local Plan which calls for the Safeguarding of Employment Land and Premises.
Finally, a possible consequence of the success of this application would be a fatal undermining of the Adopted Local Plan which could lead to the revisiting of many planning appeals which have been dismissed by reference to it.

Tony Green,
Sidmouth resident,
23 Cotlands EX10 8SP


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