Tuesday 31 May 2016

Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> Strategy 3 - Sustainable Development

When it comes to planning decisions, any application must comply with the tenets of 'sustainable development'.

When it comes to the planning decisions over Knowle, the idea of 'sustainability' his has been a central point for the District Council:

Richard Cohen, Deputy Chief Executive presented his report on options to address the Council’s future accommodation requirements. Since the Development Management Committee (1 March 2013) had refused the application for alternative use of the Knowle site, work had continued on the viability analysis of various options:
 Remaining at the Knowle in a reconfigured form
 Honiton options
 Relocation to Cranbrook
 Other sites in the district
The viability analysis identified that remaining at the Knowle site was not a sustainable option as the ‘outdated’ offices were not fit for purpose and costly to run.

However, such statements have to be seen within the context of what the Local Plan says on the subject of 'sustainable development':

East Devon Local Plan 2013 to 2031

Strategy 3 - Sustainable Development:
The objective of ensuring sustainable development is central to our thinking. We interpret sustainable development in East Devon to mean that the following issues and their interrelationships are taken fully into account when considering development: a) Conserving and Enhancing the Environment - which includes ensuring development is undertaken in a way that minimises harm and enhances biodiversity and the quality and character of the landscape. This includes reducing the risk of flooding by incorporating measures such as sustainable drainage systems. Developers should maximise the proportion of their developments that take place on previously developed land b) Prudent natural resource use - which includes minimising fossil fuel use therefore reducing carbon dioxide emissions. It also includes minimising resource consumption, reusing materials and recycling. Renewable energy development will be encouraged

17 Climate Change and Renewable Energy
Climate Change and Low Carbon Development
17.1 The best available evidence shows that we are seeing and can expect to see future changes in the global climate as a consequence of past and ongoing greenhouse gas emissions. These changes are predicted to escalate in the future and it is therefore essential that in East Devon we prepare for greater frequency of extreme weather events, and plan for greater energy efficiency and generation of energy from renewable sources. There can also be economic benefits to be gained. This chapter of the plan addresses these themes.
Transition to a Low Carbon Economy
17.2 The Climate Change Act (2008)68 has put in place legally binding targets for the UK to achieve an 80% reduction in greenhouse gas emissions by 2050 with reductions of 34% by 2020, against a 1990 baseline. Emissions from buildings account for approximately half of all emissions nationally. There is little scope to force existing buildings to become more energy efficient, other than by offering incentives to upgrade and making renewable technologies a requirement of applications for refurbishment or extension, but all new development will be required to be “low carbon”.
17.5 In addressing climate change and energy security the planning process can not only mitigate against the risks but can help to turn them into opportunities for local businesses, giving East Devon a competitive advantage and helping it to prosper in the future. The implementation of planning policy at a local level is crucial to deliver the radical reductions in energy demand and greenhouse gas emissions required to support the national transition to a Low Carbon Economy. The scope of policy can cover the appropriate location and layout of new development, and provide active support for energy efficiency improvements to existing buildings and the delivery of renewable and low-carbon energy infrastructure.
17.6 All development proposals must be planned over the lifetime of the development to ensure that the maximum potential for reducing carbon emissions and minimising the risks posed by climate change are achieved. Developers must be mindful of the carbon emission standards which will be required for later stages of the build programme as decisions taken at the outset can compromise the viability of emissions reduction in latter phases. In some parts of the District it will be possible to generate energy locally at a scale which could serve the local area, for instance through a Combined Heat and Power scheme. New development should include infrastructure to enable it to be connected to such CHP schemes, whether they already exist or may be provided in the future. Where low carbon technologies are not installed new buildings should be designed for easy installation and/or adaptation at a later date.
17.12 Proposals for well designed, sustainable buildings will be supported unless it would cause harm to a heritage asset or its setting or existing mature trees, and this would not be outweighed by the proposal’s wider social, economic and environmental benefits. This will also apply in the case of refurbishment of existing development, for example regarding the fitting of external insulation to properties with solid walls. Where conflict arises, for instance by the reduction of the effectiveness of photovoltaic cells due to overshadowing by mature trees or the impact of cells on the appearance of an historic building, the trees or historic building will usually take precedence and alternative forms of technology should be considered. Similarly, in planning for the lifetime of a building or development future conflicts should be considered, for instance the impact that tree planting to the south of buildings will have on the effectiveness of solar capture in the long term.

Demolishing a building is not 'sustainable development' as far as the Local Plan is concerned.

Indeed, working to improve the energy efficiency of the building should be a priority:

In 2008, a Display Energy Certificate was issued giving Knowle the “more energy efficient” band C.
This was accompanied by an Advisory Report from the Energy Assessor, who set out several recommendations such as more insulation, more double-glazing and a comprehensive heating strategy.
Futures Forum: Knowle relocation project: "How efficiently is this building being used?"
Indeed, the District Council has made commitments to the band C rating:
"Working towards an ideal energy certificate level for each property, rather than just reporting what level it had; to aspire to making improvements that brought each property to a minimum of level C"
Central government itself is keen to promote this certification:
Improving the energy efficiency of our buildings                 
In 2012, another such Certificate was produced [and this can be seen on the website of Savills which is marketing Knowle] – but it showed no improvement.
The question arises, therefore, as to why the vast majority of the Energy Assessor’s efficiencies have not been considered and modern sustainable technologies introduced?

Fundamentally, 'sustainable development' is about minimising carbon emissions and reuse/recycling/reduce - which means renovation rather than demolition of buildings:

Asset renovation 22 May 2014
In these tough financial times, why build new schools, council offices and other public buildings when you can renovate existing ones at a lower cost? 
AN EXCITING new product to transform existing public sector buildings so they are high quality, attractive and efficient – but delivered at a lower cost than new build projects – is being launched by Scape.


Rather than demolishing the buildings at Knowle to finance the proposed relocation to Honiton, Robin Fuller in his open letter [to the Herald] of 3rd September (‘EDDC, flats, Councillors ’) suggests ‘A TRULY GREEN ALTERNATIVE TO EDDC’S PROPOSAL’
1) Modernise the 1975 building at Knowle through the sale of the Honiton Heathpark site; the District Council has publicly stated that it needs half of the current 9200 square metres of floorspace and that the current building is ‘not fit for purpose’; halving energy use together with state-of the-art ecodesign would result in a truly ‘green’ office-space.
2) Sell the 1880/90s Knowle Hotel and caretaker’s lodge with outline planning permission to convert them into flats, which in turn would raise considerable sums for the District Council; this could well produce the 50 dwellings proposed in the draft LP and avoid the stated aim of building on greenfield land; the substantial gardens and parkland would not be eaten into; and the park-and-walk facility would continue to serve visitors.
Knowle – a positive and cost-effective way forward
I outline a proposal which offers a truly green alternative to EDDC’s plans to demolish perfectly sound buildings at Knowle and destroy public parks and gardens, trees in the arboretum and wildlife habitats, all in order to fund the provision of up to date offices.

Refurbishment v redevelopment or new build:
A précis and interpretation for Knowle

Nigel Addy and Peter McCallum of Davis Langdon, an AECOM company, discuss creating and adding value through refurbishment. Interestingly, Davis Langdon were consultants to EDDC on refurbishment costs, but they were only asked to examine full refurbishment of all of Knowle, old and modern, despite the fact that this would have refurbished nearly double the floorspace required. A précis of their article follows.
“So why is there so much excitement surrounding the refurbishment of existing offices?” ask Addy and McCullum. There are many pros and cons for developers depending on size and age of the building and what is required as an outcome. For a developer in our current financial times, there is the need for quick turn around and realisation of an asset, which is not necessarily the same motivator for a business owner wanting to make choices over relocation or refurbishment. Given that the article is written for developers who wish to make money, one should be able to assume that most advantages would also apply to EDDC.
Knowle: On that basis the refurbishment costs for the 2,725 m² of modern offices at Knowle would be £2.8million (at Central London prices, 2012).
So, in summary, Class A refurbishment of the modern offices at Knowle might cost just £2.8million, perhaps £3.7million and, at an extreme, £5.1million with substantial structural changes.
The chamber plus associated offices are not included in this improvement. Clearly, there would be the need bring the chamber rooms into whatever new heating system were installed in the modern offices, and possibly to add air conditioning; also to improve insulation.
Overall, these figures still indicate that refurbishment costs could be met by sale of the remainder of the old Knowle for conversion to flats. Equally, office-refurbishment and a new building extension might be funded by sale of the entire old Knowle, probably for complete redevelopment as luxury flats.
It is not reasonable to dismiss the option of refurbishment and extension without subjecting that option to the level of analysis that has been applied to ‘moving and improving’. To the contrary, any open-minded approach would have started with the refurbishment option applied to only those parts of Knowle which EDDC would themselves occupy; and it would only have explored moving as an option if refurbishment were shown by a full and fair analysis to be impossible.

Here is an excellent summary of the issues from the Save Our Sidmouth chair:

SOS dismisses “emotional, vague and unsubstantiated views” in Cllr Tom Wright’s letter.
January 22, 2015 by sidmouthsid
This letter has been sent to the Exmouth Journal, countering a Conservative councillor’s letter about relocation, which was published in that newspaper last week:
A response to Councillor Tom Wright’s letter is essential. He demonstrates EDDC councillors’ continuing inability to understand basic issues and he hopes that bland statements and unsubstantiated opinions can overcome the obvious shortcomings of EDDC’s proposed move from the Knowle. Let’s help him to understand those issues.
The facts are:
• EDDC chose Sidmouth for its HQ after the 1973 local government re-organisation. Modern and EDDC-approved extensions were built in the 70s and 80s.
• After a major review in 2001/2002 EDDC confirmed that it should remain at the Knowle because:
o It was central for the district, easily accessible by public transport from all the remaining towns and that considerable sums had already been spent in shutting outlying offices and depots.
o The Knowle allowed any necessary expansion.
o Refurbishment of nearly £4 million was implemented. The then-Conservative leader said that the building should never again be allowed to fall into disrepair but soon, regular planned maintenance ceased.
• An estimate in 2014 by EDDC’s advisers on Relocation suggested that some £1.5 million, to remedy defects, would enable the building “to be occupied for the next five years”. These repairs resulted from “the failure to carry out maintenance in previous years”, (their words).
• EDDC maintains it only needs an area marginally larger than the existing “new” Knowle buildings but no really detailed investigation has been undertaken to and extend the “new” building and sell older parts.
• The Skypark option collapsed when EDDC discovered that they lacked sufficient money to fund it and that they had overlooked statutory regulations on tendering.
• £750,000 has already been allocated and mainly spent on relocation fees despite the desperate need to fund other services.
• EDDC sums for the move do not make sense. The costs of the new Honiton building and the refurbished Exmouth building, plus other essential spend, will total more than £15m- in these times of austerity.
• EDDC plans to borrow £5.5m over 20 years for the move and claims that energy cost savings will make the move “cost neutral”. Informed commentators have ridiculed these energy saving estimates which are five times higher than government’s own predictions.
• Only a few chosen councillors know the financial breakdown for the Knowle sale, the costs of new and refurbished offices and all the other associated costs, yet other councillors continue to vote it through.
EDDC is secretive, responds tardily to FOI requests and even objected to the Information Commissioner’s ruling to release some reports prepared by their consultants. £7,500 has been spent on a barrister to appeal against this ruling.
The relocation, a Conservative-supported vanity project, is opposed by many councillors, including the Independent Claire Wright, the prospective Parliamentary candidate for East Devon who has long-since been an outspoken critic. Even the current Conservative MP, Hugo Swire urges EDDC to delay the relocation exercise because of uncertainties on the future of Local Government and the loss of 250 jobs to Honiton.
Any move, a disaster for which we would all pay over 20 years, cannot be justified by emotional, vague and unsubstantiated views.
Richard Thurlow
Chair, Save Our Sidmouth

SOS dismisses “emotional, vague and unsubstantiated views” in Cllr Tom Wright’s letter. | Save Our Sidmouth.

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