Friday 27 May 2016

Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> and the rejected planning application 12/1847/MOUT of 1st March 2013 >>> >>> >>> >>> >>> Part two: "Contrary to to the requirements of Policy E3 (Safeguarding Employment Land and Premises)"

There is the current planning application by PegasusLife:
16/0872/MFUL | The construction of an assisted living community for older people comprising extra care units, staff accommodation and communal facilities, including a kitchen, restaurant/bar/cafe, a well-being suite comprising gym, treatment rooms and pool, a communal lounge and storage facilities; car parking for residents, visitors and staff of the assisted living community; comprehensive landscaping comprising communal and private spaces; and associated groundworks. | Council Offices Knowle Sidmouth EX10 8HL

There is the current Local Plan:
Local Plan 2013-2031 - East Devon

And there is the rejected outline planning application for Knowle of three years ago:
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

It seems that the latest planning application does not differ fundamentally from the March 2013 planning application – in that both are contrary on many levels to the District Council’s own policies as laid out in the Local Plan.

The first area where the 2013 application failed was around the lack of Parks and Recreation Grounds in Sidmouth. This has been made even more obvious through the District Council's own reappraisal – as there is even less of this type of open space than originally thought:
Futures Forum: Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> and the rejected planning application 12/1847/MOUT of 1st March 2013 >>> Part one: "Contrary to Policy RE1 (Retention of Land for Sport and Recreation)"

And there are several other areas where there has either been no fundamental change since 2013 – or things have got worse since the original planning application was rejected.

2 - Contrary to the requirements of Policy E3 (Safeguarding Employment Land and Premises)

The second area which concerned the DMC (the Development Management Cttee, or the District Council's planning committee) was the fact that the application was contrary to policies to safeguard employment land and premises:

Applications for Planning Permission and matters for determination

RESOLVED: that the application 12/1847/MOUT be refused, contrary to Officer
recommendation, for the following reasons:

2. The proposed development by virtue of the loss of a large area of current employment land and the loss of an existing park and walk facility which provides an important car parking facility used by visitors to the town and its businesses would have a significant detrimental impact on the economy of Sidmouth. 

It has not been adequately demonstrated that all options for the retention of the site for employment uses have been fully explored or that there is a surplus of employment land in the locality. 
It is therefore considered that the proposed development would be contrary to the requirements of Policy E3 (Safeguarding Employment Land and Premises) of the adopted East Devon Local Plan.



The Chamber of Commerce and Town Council have been very concerned that any reduction in staff, spending power and carparking facilities at Knowle will have a serious impact on Sidmouth’s economy:
Now EDDC obliged to revise its own Outline Planning Application for Knowle, Sidmouth, for the FOURTH time! | Save Our Sidmouth
Knowle objections top 1,745 - News - Sidmouth Herald

Interestingly, whilst the Leader of the District Council has waxed lyrical about how ‘vibrant’ Sidmouth is:

Councillor Diviani said: "Sidmouth has a vibrant town centre and its community keeps a degree of excellence in maintaining it."

View From Online - News from West Dorset, East Devon & South Somerset

… the Deputy CEO claims that the latest planning application will ‘add to the vibrancy of the town’:

Richard Cohen, Deputy Chief Executive, states that: “The Knowle site represents a rare and high quality development opportunity. The existing building stock at the Knowle is now not fit for the Council’s purpose and our decision to relocate has been driven by a desire to deliver a modern council from modern offices. 
We are open minded about future uses for the site and the Council believes that the redevelopment opportunity within a retained parkland will be an attractive development and a strong legacy adding to the vibrancy of the town”.

29 August 2014 - Prime redevelopment opportunity in the popular coastal town of Sidmouth comes to the market - East Devon

Meanwhile, the District Council claims it has ‘engaged’ with local business to ensure the 'vibrancy' of the town continues:

Stakeholder Engagement Event 26 July 2013
How will the new HQ help local businesses?
Economic vitality is a key issue for the Council and we want to have an active dialogue with local business around their needs.

Futures Forum: Knowle relocation project: Q & A pages updated today...

And yet, as outlined below, the Chamber of Commerce steadfastly rejects the notion that there has been any such 'dialogue with local businesses'.

Furthermore, despite the display of promise from the District Council's political leadership, not only did the DMC reject the 2013 planning application on the grounds that it would have an adverse effect on the local economy, but these objections still stand today – namely, that 'It has not been adequately demonstrated that all options for the retention of the site for employment uses have been fully explored or that there is a surplus of employment land in the locality'.


At Cabinet on 4th June 2014, a report was presented promising a 'review' of how much business space there was across the District - all within the context of the relocation project:


- As part of the redevelopment of the Council’s Heathpark site, the East Devon Business Centre will be vacated. In preparation for this, Cabinet agreed in April to review its approach to the provision of business space and support across the district. EDDC currently provides business units across the district comprising office and workshop space in a variety of locations.

The chosen company, Carter Jonas, will begin their work shortly, gathering evidence over the next few months and report back their findings and recommendations by September 2014 at the latest.

And more from this packed-full agenda! A reference to the East Devon Business Forum! | East Devon Watch

The Deputy CEO made reference to this review to the Overview and Scrutiny Cttee on 16th October 2014 - again within the context of the District Council's relocation project:

> Business space review – a study has been commissioned using external contractors, to provide information to help inform a case for the future of serviced business spaces in the district, and the Council’s role in that provision.

Futures Forum: Knowle relocation project: analysis of the Deputy CEO's 'Office Relocation Update'

And that was it: no 'review' has been published since...

As for other 'evidence' from the District Council:


Much has been made of a study especially commissioned into the economic impact on Sidmouth should the District Council relocate. 
In the context of this study, the DMC concluded on 1st March that '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'.

The Economic Development Manager concurred, saying in the Economic Impact Study of January 2013 from consultants Peter Brett, 'that if the changes proposed are approved and implemented this would have an immediate and lasting impact upon Sidmouth’s economy.'

Nevertheless, the political leadership jumped on several of the findings from the Brett report to justify relocation and the impending planning application:

Knowle move ‘will cost Sidmouth 71 jobs over decade’
10:45 18 January 2013

An updated independent assessment of the economic impact of East Devon District Council’s proposals to relocate its main offices has been released for public consultation.

It comes as the council confirms its Outline Planning Application for Knowle will be determined by councillors on Friday 01 March.

For two weeks from today (Friday, January 18) a freshly revised Economic Impact Assessment by Peter Brett Associates will be available to view online at http://planning.eastdevon.gov.uk/ as part of the supporting documents for the council’s Outline Planning Application to redevelop the Knowle site. During this time people will be able to comment on the Assessment, which sets out how the proposals might affect the local economy, especially in Sidmouth.

The council is inviting comment on it as part of the consultation on its Outline Planning Application for Knowle, which is expected to be determined by councillors on the Development Management Committee on Friday 01 March. It is also writing to everyone who has previously commented on the application, inviting them to review the updated and final Economic Impact Assessment and let the council know if it affects their previous comments on the planning application.

The document is just one of 29 pieces of evidence relating to the proposals, drawn up as the council does its homework on the possibility of moving. No decision on whether to move has been taken by the council, and an eventual decision will depend on many things, including the financial viability which is currently being assessed. The council has said it will only move if it is ‘self funding’ and does not cost local taxpayers money. It is considering the possibility partly because the cost of Knowle is spiralling, with urgent repairs alone estimated to cost more than £1M of taxpayers’ money if an alternative isn’t found.

Importantly the document can only provide an informed estimate of issues such as job losses, as predicting these trends over 10 years is not an exact science and depends on lots of different factors. It does however help inform the overall worst-case estimate of the impact of the move.*

The final Economic Impact Assessment includes a number of changes following Peter Brett Associates’ careful review of the data to satisfy the stringent requirements of the council’s planning arm. There is more information provided to help clarify and illustrate the statistics to ensure that the data is as consistent and robust as it can be given the predictive nature of the worst-case estimates. The most notable revision is that job losses in Sidmouth over a ten year period are predicted to be 71. This has changed from a previous estimate of 59, although the report notes that many of these are likely to occur through natural change over the decade as Sidmouth residents find other work or choose to retire.

The report also highlights the likely impact on Sidmouth’s 500+ local businesses as relatively small, noting most of the businesses as small but adaptable to change. Of those businesses interviewed for the study, over three quarters saw no need to change their business operations or plans because of the proposals.
Cllr Andrew Moulding, Deputy Leader of East Devon District Council said: “This independent and impartial report is a piece of the larger picture which will help inform the decisions the council makes going forward. It has been prepared with great care, responding to feedback from our planners and members of the public who challenged certain aspects of the draft and making sure we have a robust, well evidenced document to consider.

“There is unquestionably a negative but relatively limited impact on Sidmouth’s economy, and this information must be balanced with the potential benefits of moving. With Knowle in its current state doing nothing is not an option, because it places a huge burden on all East Devon taxpayers, even for just the essential repairs.”

Russell Porter from Peter Brett Associates added: “We have been pleased to prepare this document for the council and hope that it helps them reach an informed decision. While no report of this nature can predict the future with 100% accuracy, it should give a good estimate about the local impacts of the proposal. It will be a matter for the council to decide how this balances with other impacts and benefits of moving, including how the proposal affects taxpayers and other parts of the district.”

Knowle move ‘will cost Sidmouth 71 jobs over decade’ - News - Sidmouth Herald

The Sid Vale Association in its analysis of the Study had a very different take to the Deputy Leader – seriously questioning the soundness of the report:

Economic Impact Assessment – Peter Brett Associates Aug 2012

4.8 A detailed critique of the Economic Impact Assessment is appended to this document at Appendix 1. In summary, The EconIA is seriously flawed. 

The adverse economic impacts are far greater than has been assessed. The critique concludes that:

·         Impacts on employment in Sidmouth have been significantly underestimated. It is calculated that 69 jobs will be lost overall, rather than the 3 suggested by PBA.

·         Impacts on spending in Sidmouth are similarly significantly underestimated. EDDC spending of £3.6m per annum has been discounted from the Assessment.

·         Consultation of the public and stakeholders has been inadequate.

·         The business questionnaire which was used to build the economic assessment is not fit for purpose.

Sid Vale Association - SVA Objections to proposed Knowle redevelopment

The Vision Group's analysis was equally critical of the Economic Impact Assessment:


1) The commuting costs for District Council employees (Page 11: Para 2.2.5) will in fact be considerable. This contradicts a central platform of the District Council’s calculations with regard to Housing and Employment land in the draft Local Plan.

2) The term ‘resilience’ has now become vacuous (Page 13: Para 2.3.3), just as ‘sustainability’ has lost all meaning. And yet the Report’s dismissal of the impact of loss of local contracts on small businesses (Page 14: Para 3.2.6) and the inaccuracies with regard to the expenditure of Sidmouthians (Page 18: Para 3.2.19, 21) indicate that there is little understanding of how a local economy can maintain its ‘resilience’, especially in these difficult times.

3) There are serious errors in the mathematics contained in this Assessment. For example, the understanding of ‘outlier’ in statistical terms is not correct (Page 17: Para 3.2.18) and has led to distortions in the collection and analysis of data.

4) The failure of District Officers to take the issue of the park-and-walk facility seriously persists in this Assessment (Page 19: Para 3.2.24; Page 20: Para 3.2.24; Page 26: Para 4.2.3; Page 31: Para 4.3.6).

5) There are serious flaws in the calculations with regard to ‘employment creation’ (Page 21: Para 3.3.5, 7; Page 24: Para 3.4.2).

6) The drafting of the questionnaire to local businesses was so poor (Page 26: Para 4.2.3; Page 28: Para 4.2.9; Page 30: Para 4.3.2, 3, 6, 8, 9) that the information gathered and subsequent analysis cannot be taken seriously.

Vision Group for Sidmouth - VGS submission to Knowle planning application sept12


At the end of the day, though, the District Council argues that there will be a 'loss' of jobs anyway, as they will be introducing their 'Work Smart' initiative:

The Corporate Organisational Development Manager is investigating the potential for staff to work in more mobile and flexible ways. 
Work Smart is the council’s name for its home, mobile and flexible working arrangements for staff which will be developed through the Council’s management team and subject to consultation with staff and fit with operational requirements. 
It will involve more staff working away from the office or dividing their time between the office and another location. 
In doing so EDDC hopes to have a more flexible workforce and service delivery available and accessible to customers around the district. 
More desks can be shared, storage space reduced, communal and shared space more effectively provided and less traditional office space overall will be required. 
Initial staff survey work, Member requirements and office layout planning has resulted in an office size projection that involves a mix of communal space, meeting space, reception area, 250 desks and Council specific space such as the Council Chamber itself. This leads to an overall total floor space of 3,352m2.


And three and a bit thousand square metres is of course the area the 1980s building and Chamber at Knowle comprises - but that's another chapter:
Futures Forum: "A truly green alternative to EDDC's proposal"
Futures Forum: Knowle: refurbishment vs redevelopment
Futures Forum: Knowle plans: 1970s building
Costs of relocating EDDC HQ vs refurbishing Knowle - a Freedom of Information request to East Devon District Council - WhatDoTheyKnow

Meanwhile, other local authorities have been doing similar things - but without feeling the need to move to another town to do them:
SIDMOUTH: Council exchange contracts with Pegasus Life for Knowle

And, besides, there is the new industrial park to compensate for any losses:
Pegasus Sidmouth: Milton Keynes without the roundabouts | East Devon Watch
Vision Group for Sidmouth - Objection to Planning Application
Futures Forum: Knowle relocation project: connected to the draft Local Plan ... connected to employment ... local business ... retail parks vs the high street ... proposed Sidford employment land ... building on floodplains ... tourism ...

Otherwise, things stand pretty much the same with regard to the requirements of Policy E3 (Safeguarding Employment
Land and Premises) today as they did on 1st March 2013.


In the adopted Local Plan

Policy E3 has disappeared - and has been replaced by Strategy 32:

Strategy 32 - Resisting Loss of Employment, Retail and Community Sites and Buildings:

In order to ensure that local communities remain vibrant and viable and are able to meet the needs of residents we will resist the loss of employment, retail and community uses. This will include facilities such as buildings and spaces used by or for job generating uses and community and social gathering purposes, such as pubs, shops and Post Offices.

Permission will not be granted for the change of use of current or allocated employment land and premises or social or community facilities, where it would harm social or community gathering and/or business and employment opportunities in the area, unless: 
1. Continued use (or new use on a specifically allocated site) would significantly harm the quality of a locality whether through traffic, amenity, environmental or other associated problems; or 
2. The new use would safeguard a listed building where current uses are detrimental to it and where it would otherwise not be afforded protection; or 
3. Options for retention of the site or premises for its current or similar use have been fully explored without success for at least 12 months (and up to 2 years depending on market conditions) and there is a clear demonstration of surplus supply of land or provision in a locality; or 
4. The proposed use would result in the provision or restoration of retail (Class A1) facilities in a settlement otherwise bereft of shops. Such facilities should be commensurate with the needs of the settlement


Again, we have that desirable commodity 'vibrant communities'...

And the remaining question is whether the DMC, when it is called to consider this planning application, will consider exception number 3 above, that: 
- 'Options for retention of the site or premises for its current or similar use have been fully explored without success' (As the District Council claims that it has assessed the viability of 'repairs'/'renovations'.)
- 'and there is a clear demonstration of surplus supply of land or provision in a locality' (And note the use of 'and' rather than 'or': the District Council's flawed Economic Impact Assessment says there is enough employment land elsewhere - see above. 

Finally, though, the successful lobbying of the now-disbanded East Devon Business Forum resulted in the District Council insisting that there is not enough employment land in the District:
Futures Forum: A history of the East Devon Business Forum, part nine ....... "The local development framework would enable businesses to progress land allocation. It was agreed that the strategy should reflect the Forum’s views."
Futures Forum: The current state of employment land sites in the Sid Valley
Futures Forum: A history of the East Devon Business Forum, part three....... "Members of the Business Forum often underestimated its influence on policy at EDDC; an example was for the need for more employment land in the District."
Futures Forum: A history of the East Devon Business Forum, part two....... "It mostly represents a number of businesss that councillors and ex-councillors are involved in and those where councillors and ex-councillors own where land which was permitted to be changed from agricultural land to industrial land."
Futures Forum: The East Devon Business Forum, housing numbers and greenfield sites
Futures Forum: Lobbying: East Devon Business Forum


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