Futures Forum of the
Vision Group for Sidmouth
Response to minor
changes to the draft Local Plan
6th October 2013
Planning Policy,
East Devon District
Council,
Knowle,
Sidmouth, EX1O 8HL
Dear Sirs,
The Vision Group for
Sidmouth, as part of the Transition Town movement Welcome | Transition Network, believes
that strategic planning should have sustainability at its heart.
It is to be welcomed,
therefore, that the District Council has actively adopted these ideas in
general policy terms Futures
Forum: Sustainable Development: and East Devon and as laid out it its
Sustainability Appraisal East Devon District
Council - Sustainability Appraisal and Habitat Regulations – although it is
still not clear exactly how its ‘objectives’ have been measured, for example, that there should be ‘no increase
in flooding’ at Sidford.
Nevertheless, it is also
to be welcomed that the District Council has actively sought to engage with the
VGS on planning issues Futures
Forum: Development for Sustainability: Futures Forum meeting.
There are specifically
two areas of the latest draft Local Plan East Devon District Council -
Proposed Post-Publication Changes which the Futures Forum of the VGS would
like to address, in the light of its own ‘consultations’.
SIDFORD
EMPLOYMENT LAND: USE
The District Council
will be aware of the tendency for A1/A2 land-use to be granted in East Devon over
time, following B1/B2 approvals Futures
Forum: What is the difference between a 'business park'... and a 'retail park'?,
Futures
Forum: What is the difference between a 'business park'... and a 'retail
park'... Part Two – which might explain the ‘minor’ change to “Strategy
26 - Development at Sidmouth: ® 6.133” to include ‘retail’ as a matter
of course at the proposed employment land site at Sidford.
However, if the District
Council were serious in its contention that ‘There is little doubt that town
centres are under increasing pressure from the competition coming from
out-of-town trading’ http://www.eastdevon.gov.uk/vhstc_taff_report_270912.pdf,
then this ‘minor’ change
should not be included.
The VGS therefore
proposes that
‘2.
Jobs - provision of up to 5 hectares of additional employment land, with a particular
onus on B1 space with uses (with any retail “ancillary to primary use of each
unit”).
should be rewritten as
‘2. Jobs - provision of
up to 5 hectares of additional employment land, with only B1/B2/B8 space
permitted, to the exclusion of any retail.’
SIDFORD
EMPLOYMENT LAND: FLOODING
Whilst the initial
proposals for development of employment land at Sidford refer to ‘sustainable
development’ and that ‘The proposals for
the site fully address on and off-site flood risk and make full provision for
these in accordance with current planning policy (NPPF and local policy) and
the current requirements of the Environment Agency’ www.eastdevon.gov.uk/1967-fordscontextlogic-josephmarchant-6_133efloodriskassessment.pdf
– and whilst the District Council describes the site as Flood Zone 2 in
its Local Plan documentation http://maps2.eastdevon.gov.uk/mapping/localplan/,
the Halcrow Group rates most of the site as Flood Zone 3B http://www.eastdevon.gov.uk/plg_sframainreport01.pdf
which the Environment Agency itself clearly warns about Environment
Agency - Watch our short animation of surface water flooding. (See ‘Sustainable
development’ at Sidford Fields? | Save Our Sidmouth, EAFloodmapSidford.)
The VGS therefore
proposes that
‘Jobs
- provision of up to 5 hectares of additional employment land, with a
particular onus on B1 space with uses (with any retail “ancillary to primary
use of each unit”).
should be rewritten as:
‘2. Jobs - provision of
up to 5 hectares of additional employment land, with only B1/B2/B8 space
permitted, to the exclusion of any retail,’
and:
‘but
only as a remote contingency – following the 5 year review of the Local Plan
and only once exceptional need has been demonstrated and serious drawbacks
overcome, namely the threat to the viability of Sidmouth’s economy, its high
street and current employment sites – and the threat of flooding on a floodplain
within an AONB.’
KNOWLE:
It is to be welcomed
that the latest draft Local Plan states ‘The
site allocated at the Current Council Office at Knowle has been amended to show
a smaller area that reflects current development expectations.’
This also reflects the
statements from the District Council Leader following the decision by the DMC
in March to reject proposals for development at Knowle Parts
of Knowle spared in Local Plan changes - News - Sidmouth Herald.
However, the proposals
for the site at Knowle “Current
Council Offices, Knowle — 50 homes ® 6.295” clearly extend the
original Zone C into the gardens to the south, beyond the building’s current
footprint [the lawns down to a boundary below the flower beds and just
short of the Gothic folly].
In particular:
> These lawns are shown
in District Council maps to be within the recreational area Futures
Forum: Local Plan: maps in focus.
> In the refusal by the DMC of planning application 12/1847/MOUT, it was stated that the construction of dwellings should not be allowed on "an area of open space..." and that it would be "contrary to policy RE1":’Furthermore the Local Planning Authority is not satisfied that the open space is surplus to requirements and the development is therefore considered to be contrary to Policy RE1 (Retention of Land for Sport and Recreation) of the adopted East Devon Local Plan and the guidance of paragraph 74 of the National Planning Policy Framework.’ http://www.eastdevon.gov.uk/special_dev_man_010313_mins.pdf
> In the refusal by the DMC of planning application 12/1847/MOUT, it was stated that the construction of dwellings should not be allowed on "an area of open space..." and that it would be "contrary to policy RE1":’Furthermore the Local Planning Authority is not satisfied that the open space is surplus to requirements and the development is therefore considered to be contrary to Policy RE1 (Retention of Land for Sport and Recreation) of the adopted East Devon Local Plan and the guidance of paragraph 74 of the National Planning Policy Framework.’ http://www.eastdevon.gov.uk/special_dev_man_010313_mins.pdf
> The Planning
Committee of Sidmouth Town Council responded similarly in February: SUPPORT development in Zone C subject to
development being restricted to the footprint of the existing office buildings
and subject to sympathetic and appropriate design in keeping with the character
of the area and adjacent properties. Advisory notes: The existing access to
Knowle drive from the western edge of ‘zone C’ should be closed off with all
access to zones C being from the main driveway to avoid the creation of a
through road. All current and proposed Public Rights of Way throughout the
site should be maintained.
The VGS therefore
proposes that:
There should be no
extension beyond the current footprint of the buildings at Knowle.
and:
The proposals to
refurbish and renovate the current buildings should be actively considered by
the District Council – following the principles of development for
sustainability Futures
Forum: "A truly green alternative to EDDC's proposal", Futures
Forum: Knowle: refurbishment vs redevelopment.
The Futures Forum of the
Vision Group for Sidmouth would support the other paragraphs in the draft Local
Plan relating to Sidmouth and would like to thank you for this opportunity to
comment.
Yours faithfully,
Jeremy Woodward
on behalf of the Futures
Forum
Vision Group for
Sidmouth
See also: Futures Forum: District Council - Submission of the new Local Plan........... deadline Monday 7th October..... pro forma letter from SOS
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