Futures Forum: Knowle: the Byes and when a 'meadow' is a 'park'...
The main issue being that the consultants Bennett Leisure & Planning (Belap) who produced the District Council's Open Space Study
www.eastdevon.gov.uk/lp-openspacestudyfinalreport.pdf
would not acknowledge that there were 'problems' with the methodology used to determine how bits of Open Space are categorised...
Queries last November to Belap such as this:
I have
been studying this report which EDDC have now incorporated into their Planning
process and have a couple of queries about it which I hope you can resolve as
they do not impinge on client confidentiality and are in the public
domain.
1. You
identify 14 types of open space but the charts of ha/1000 population on pages 33
and 85 do not show findings for the Natural and Semi-natural Open Space
category. Can you explain please?
2. The
map on page 31 seems to show The Byes in Sidmouth (the riverside walk owned by
the National Trust) as Natural greenspace but its 13.81ha are listed in Appendix
C as Parks and Recreation Grounds. Can you explain this too
please?
Thank
you for your response.
You
state that "The Byes
is classified as Park and Recreation Ground (13.81 hectares.)" presumably
because it is so listed in your Appendix C. But can I ask how this
classification was arrived at? Did anyone walk the Byes or was it perhaps done
from a map?. Can I please ask you to revisit your definition of Parks and
Recreation Grounds and then tell me where I can find in The Byes any indication
of formal planning, or any lawns or any flower beds? But they are an exact fit
to your definition of Natural and Semi-natural Open Space.
This is
a crucial issue because the Applicant in a current Outline Planning Application
makes much of Sidmouth's apparent surplus of Parks & Recn Grounds based on a
Planning Support Statement which used your East Devon Open Space Study.
In response to your latest query: The Byes was visited during the audit. It is indeed a mixture of park and natural space, it does have features of both typologies, but is very much used as a park, with formally laid out paths and cycleways and managed amenity grassland. It has very heavy use, and it is important that the standard of maintenance is high. It also acts as a green corridor. In the assessment it is required to decide the typology a site best fits in with – of course not every site fits neatly in a classification. For this site, we decided that because of the heavy use and high levels of maintenance required it would fit better in the parks and recreation grounds category. This is an important point, as this typology attracts a higher level of funding and management than natural space which is crucial for this site.
and:
Thank
you for your email. I have discussed with senior officers and the Chief
Executive who has advised me that the best thing to do would be for you to make
a representation on the New Local Plan which is currently out for consultation.
You can do this online by clicking on a RefPoint (looks like ®6.12)
in the Plan itself (which can be found here)
and following the instructions. If you prefer you can also make a representation
by filling in the representation form attached or by writing to East Devon
District Council Offices, Knowle, Sidmouth, EX10 8HL, or emailing localplan@eastdevon.gov.uk.
By
making a representation at this stage, your views will be taken into account by
the inspector at our examination next summer.
It is then that the piece set out at
Futures Forum: Knowle: the Byes and when a 'meadow' is a 'park'...
was put together and the National Trust directly contacted.
... at the same time the Vision Group had presented its objections to the planning application for Knowle:
Vision Group for Sidmouth - Objection to Planning Application
Not only has the Open Space Study had a direct baring on these plans to develop Knowle, but it has been integrated into the District Council's draft Local Plan:
East Devon Open Space Standards ® 6.191
18.10 An Open Space Study has been completed which comprises identification and mapping of open spaces; audits of quantity, quality, and accessibility; Geographic Information Systems analysis to establish current levels of provision and identify needs. Public consultation has helped to establish community aspirations and requirements for open space and has created local standards for both urban and rural areas.
www.eastdevon.gov.uk/publicationdraftnewlocalplan.pdf
An objection to the Local Plan was presented by the Vision Group in January:
Objection to proposals for development of the Council offices site for housing in respect of the resultant loss of public open space and parkland.
SUPPORT, WITH RESERVATIONS
PUBLIC OPEN SPACE: RELOCATION
FROM KNOWLE
The declared support for the preservation of Public Open
Space in the draft Local Plan is to be welcomed.
This declaration has been undermined, however, by
documentation supporting the Outline Planning Application12/1847/MOUT - Council
Offices Knowle Sidmouth EX10 8HL. At point 3.32 on page 28/30 of the Planning
Support Statement document 1034474, consultants Bell Cornwell state:
The current open space requirement as set out in the East
Devon Open Space Study 2011 sets out the standard of 1ha/1000 population for
parks and recreation grounds. Sidmouth currently has 21.26ha... which equates to an exeedance
of the standards by 7.33ha a significant amount more than the town actually
needs. As a consequence utilisation of a small area of the parkland [at Knowle]
will not make a significant impact on the provision of open space parks and
recreation within the town and consequently would not be contrary to Policy RC1
http://planningapps.eastdevon.gov.uk/Planning/lg/dialog.page?Param=lg.Planning&org.apache.shale.dialog.DIALOG_NAME=gfplanningsearch&SDescription=12/1847/MOUT&viewdocs=true
Furthermore, the District Councils Development Management
Committee of 4th December 2012 also concluded that Sidmouth has an excess of
open space parks and recreation ground: P103 Loss of Open Space: Aside from the
loss of the parkland potentially impacting on the historic significance of the
gardens the proposal would lead to a loss of open space that could impact on
the amenities available to the residents of the town.
Policy RC1 of the adopted East Devon Local Plan seeks to
retain land for sport and recreation unless either equivalent alternative
provision is to be made, facilities can best be retained and enhanced through
the development or there is an excess of open space in the area. The Planning
Support Statement submitted with the application argues that even with the loss
of open space resulting from this development there will be adequate open space
provision in Sidmouth. This is based on a recent open space study that was
carried out on behalf of the Council and was adopted by the Council earlier
this year. The study sets a standard in urban areas of 1ha of parks and
recreation grounds per 1000 head of population. For Sidmouth this amounts to a
need of 13.93ha of parks and recreation grounds. Sidmouth actually has 21.26ha.
This is 7.33ha in excess of the adopted standard for urban areas in East Devon.
The proposed development involves the loss of approximately 0.8ha of park and
recreation ground (if the depot site is excluded as this is not considered to
currently form part of the recreation ground). On this basis the proposal is
considered to comply with the requirements of Policy RC3 of the adopted Local
Plan.
Conclusion: The loss of jobs within Sidmouth is a
significant issue that weighs against this application particularly in the
current economic climate. This cannot however be separated from the wider
economic benefits of this development for the district as a whole. The loss of
parkland and gardens although clearly of great importance to the local
community and as such its partial loss is regrettable, the facts of the matter
are that the loss is not significant in terms of open space provision in the
town or considered to be so significant in terms of any historic significance
that the parkland had in the past and may still be considered by some quarters
to have today to justify the refusal of this application on this ground alone.
http://eastdevon.gov.uk/combined_dmc_agenda_041212.pdf
(pages 103 and 113)
Designations of these different types of open space are set
out on pages 17 and 25 of the District Councils Open Space Study:
Whilst in the Open Spaces Study there has been scrupulous
care given to delineation and nomenclature, it appears that the methodology of
the consultants Bell Cornwell is unsound. By including Natural Green Space and
other 'Wild/Semi-Wild Areas' together with 'Parks and Recreation Grounds', Bell
Cornwell has considerably overstated the amount of 'Parks and Recreation
Grounds' within the Sidmouth Boundary. In particular, Bell Cornwell and the
District Council have in fact attempted to classify all the public open space
in the area generically known as The Byes in Sidmouth as simply Parks and
Recreation Grounds, rather than a mixture of Natural & Semi-Natural Green
Space and Parks and Recreation Grounds which has had the effect of exaggerating
the amount of parkland in Sidmouth. There has been a separation of different
types of outdoor sport facilities in The Byes but no recognition of the variety
of different types of open space to be found in The Byes. The result has been
to give the same overall outline delineation to the whole of The Byes as if all
13.81ha of that public open space were homogeneous.
In reality, there are large areas of The Byes which should
be differentiated: Gilchrist and Margaret’s Meadows, included in the northerly
section of The Byes, were originally donated by local people and have been
owned and managed by the Sid Vale Association for some years: they are tended
as wild-flower areas, with considerable woodland and pond sections. These
meadows are very popular, but the SVA takes care to give them a semi-natural
feel, with occasional sheep-grazing and once-yearly mowing: The Byes where the
SVA currently hold 18 acres of trees and meadows, on the banks of the River Sid
And as such these are clearly Natural & Semi-Natural
Green Space and not Parks and Recreation Grounds.
The actual area in hectares, including Livonia Field as
noted on the official National Trust map, is 7.41ha. Sid Meadow and the
Community Orchard, forming part of the southerly section of The Byes, are owned
by the National Trust and were integrated into The Byes four years ago, having
offered grazing for many years. The National Trust’s own map shows it to be a
considerable segment approximating 2.25ha. The East Devon National Trust has
written expressing its dismay:
You make a very valid point about the National Trust's
meadow land adjacent to the Byes. This is indeed managed as natural grassland. All
the land has been declared inalienable under the National Trust Act and as such
the Trust has a statutory duty under the National Trust Acts to promote the
conservation of places of historic interest and natural beauty and ensure their
permanent protection. We would support the correct re-designation of this
meadow. We note your comment that this would have an impact on the amount of
Parks and recreational land in Sidmouth as defined in the study.(e-mail sent 7
January 2013)
If all these meadows are classified as natural or
semi-natural space, which they clearly are, this would then reduce the claimed
amount of parks & recreation grounds by over half. This means 9.66 hectares
less than the 21.26 ha referred to by the Planning Support Statement supporting
the Outline Planning Application. It brings the amount of Parks and Recreation
Grounds in Sidmouth to a revised total of 11.6ha less than the Planning Support
Statement says Sidmouth actually needs, (according to the District Councils own
calculations of requirements per head of population).This particular
Representation may be considered irrelevant with regard to the draft Local
Plan; indeed, these points have been submitted as a separate objection to the
Outline Planning Application 12/1847/MOUT. However, advice has been received
from a District Planning Policy Officer that these points should be made in the
form of a Representation to the Inspector:
Thank you for your email. I have discussed with senior
officers and the Chief Executive who has advised me that the best thing to do
would be for you to make a representation on the New Local Plan which is
currently out for consultation. You can do this online by clicking on a
RefPoint (looks like 6.12) in the Plan itself (which can be found here) and
following the instructions. If you prefer you can also make a representation by
filling in the representation form attached or by writing to East Devon
District Council Offices, Knowle, Sidmouth, EX10 8HL, or emailing localplan@eastdevon.gov.uk. By
making a representation at this stage, your views will be taken into account by
the inspector at our examination next summer. For information, RefPoints which
may be of use are 6.192 on page 127 (Strategy 43 Open Space Standards), 6.133
on page 89 (Strategy 26 Sidmouth), or 6.295 on page 177 (Policy H1 Residential
Land Allocations specifically The Knowle).(e-mail sent 20th December 2012)
(See RefPoint 6.289: H1 - Residential Land Allocation;
RefPoint 6.295: Sidmouth f) Current Council Offices, Knowle 50 homes =
EMPLOYMENT AND HOUSING LAND: RELOCATION FROM KNOWLE
The main focus by campaigners, however, has been the application (Outline Planning Application) to develop Knowle [12/1847/MOUT] and how the Open Spaces Study has been applied, as this letter to a District Council Officer indicates:
Thank
you for responding on behalf of the CEO.
However as I stated quite clearly in my
email this is not an objection
related to the emergent local plan. The Open Space Study was adopted by the
Development Management Committee at their June 2012 meeting as evidence in
current planning
applications and eventually as policy when the emergent local
plan is finalised and adopted.
My objection related to a misrepresentation of
this OSS by statements made in the Planning Support Statement specifically
related to OPA 12/1847/MOUT. It is therefore not a matter at this stage for the
local plan but, as you have mentioned, it does indeed "have implications for
the current application for the redevelopment of the Knowle" and it needs
resolution before that OPA can credibly be determined while such
misrepresentation remains unresolved. The "appropriate forum" is therefore the
planning department and the "appropriate time" is
now!
I
repeat my request that this is registered as an objection to
12/1847/MOUT.
The Outline Planning Application was rejected by the Development Management Committee on 1st March 2013:
www.eastdevon.gov.uk/special_dev_man_010313_mins.pdf
But it was not until 3rd June that the Minutes of this meeting were clarified to reflect the 'benchmark' used by the authors of the Open Space Study:
Minutes of
a special meeting of the Development Management Committee
1 March
2013
*56
Applications for Planning Permission and matters for determination
The Byes
had been classified as parkland by an experienced independent consultant and was
consistent with classifications across the country. It was recognised that any
loss of open space was unfortunate however calculations showed that Sidmouth
had more park land than the adopted national standards.
(As
agreed at the Development Management Committee meeting held on 7 May 2013 a
note is placed on these minutes to clarify that the benchmark used in the assessment
of Sidmouth’s park land was based on local standards used by Consultants in the
Open Space Study, rather than adopted national standards as was stated at the
meeting and recorded in the minutes.)
However, the work is not over, as campaigners seek definite clarification:
I can now pursue the issue of getting The Byes properly classified...
I have asked a District Council Officer for a meeting and sent him my paper. I have since got
maps showing the exact areas of SVA land and 1997 Newsletters when the land was
transferred to them saying that it will be managed as a nature reserve.
I will pursue next week as the issue
could arise during the upcoming Local Plan process...
To be continued...
..
.
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