Interestingly, the latest applicant for planning permission to demolish the building does just this:
Heritage and Archaeology Statement
What exactly is a 'non-designated heritage asset'?
This is from the Dept of Communities:
What are non-designated heritage assets and how important are they?
Revision date: 06 03 2014
Futures Forum: Knowle: Victorian hotel and grounds ... application to English Heritage for national listing
"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."
Futures Forum: Knowle: Victorian hotel: heritage asset or not...
"It is important to note that statutory listing recognises nationally important heritage sites - but it does not follow that undesignated heritage assets do not merit protection or have no value."
Futures Forum: Knowle relocation project: SAVE Britain's Heritage >>> Historic England acknowledged that both the house and the park are of 'clear local interest' and are 'evidently highly valued by the local community'.
And the comments from mere members of the public on the planning application website are very critical of the lack of recognition of the heritage value of Knowle [for example: document 2310078]:
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
These same concerns were voiced at the time of the earlier planning application in 2013. Here is just one comment:
Ms Clare Eastland (Objects)
Comment submitted date: Fri 08 Feb 2013
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.
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
In which case, it could be strongly argued that the current application should be refused because it does not comply with a key policy in the Local Plan:
EN8 - Significance of Heritage Assets and their Setting
When considering development proposals the significance of any heritage assets and their settings, should first be established by the applicant through a proportionate but systematic assessment following East Devon District Council guidance notes for ‘Assessment of Significance’ (and the English Heritage guidance “The Setting Of Heritage Assets”), or any replacement guidance, sufficient to understand the potential impact of the proposal on the significance of the asset. This policy applies to both designated and non-designated heritage assets, including any identified on the East Devon local list.
local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf
See also:
Futures Forum: Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> and the rejected planning application 12/1847/MOUT of 1st March 2013 >>> Part four: Contrary to policy EN9 (Extension, Alteration or Change of Use of Buildings of Special Architectural and Historic Interest)
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.
.
Local planning authorities may identify non-designated heritage assets. These are buildings, monuments, sites, places, areas or landscapes identified as having a degree of significance meriting consideration in planning decisions but which are not formally designated heritage assets. In some areas, local authorities identify some non-designated heritage assets as ‘locally listed’.
A substantial majority of buildings have little or no heritage significance and thus do not constitute heritage assets. Only a minority have enough heritage interest for their significance to be a material consideration in the planning process.
Non-designated heritage assets | Planning Practice Guidance
The question, therefore, is whether the District Council considers a building to have 'enough heritage interest' or not.
This is from the District Council's Local Plan:
EN8 - Significance of Heritage Assets and their Setting
When considering development proposals the significance of any heritage assets and their settings, should first be established by the applicant through a proportionate but systematic assessment following East Devon District Council guidance notes for ‘Assessment of Significance’ (and the English Heritage guidance “The Setting Of Heritage Assets”), or any replacement guidance, sufficient to understand the potential impact of the proposal on the significance of the asset. This policy applies to both designated and non-designated heritage assets, including any identified on the East Devon local list.
local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf
And this is from the District Council's "Assessment of Significance" guidance notes:
Statement of Significance guidance notes for listed buildings
A substantial majority of buildings have little or no heritage significance and thus do not constitute heritage assets. Only a minority have enough heritage interest for their significance to be a material consideration in the planning process.
Non-designated heritage assets | Planning Practice Guidance
The question, therefore, is whether the District Council considers a building to have 'enough heritage interest' or not.
This is from the District Council's Local Plan:
EN8 - Significance of Heritage Assets and their Setting
When considering development proposals the significance of any heritage assets and their settings, should first be established by the applicant through a proportionate but systematic assessment following East Devon District Council guidance notes for ‘Assessment of Significance’ (and the English Heritage guidance “The Setting Of Heritage Assets”), or any replacement guidance, sufficient to understand the potential impact of the proposal on the significance of the asset. This policy applies to both designated and non-designated heritage assets, including any identified on the East Devon local list.
local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf
And this is from the District Council's "Assessment of Significance" guidance notes:
Statement of Significance guidance notes for listed buildings
Our guidance note for Assessment of Significance
Required to accompany applications for listed building consent and planning permission affecting heritage assets
This guidance note is designed to show you as the applicant/agent what information you should be submitting as part of your Assessment of Significance, and where to find that information.
In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.
These statements will form part of the justification for the proposal and should demonstrate that consideration has been given to the protection of the heritage asset and/or its setting. The purpose of the Statement is to identify the important characteristics/significance of the existing heritage asset and to explain how the proposals would affect these and justify why this is necessary or desirable. If appropriate the Statement can be incorporated as part of a Design and Access Statement as long as it is clearly identified within the overall document. A complete Statement must include:
- Statement of significance of the heritage asset
- Details of the proposal
- Analysis of the impact of the proposal on the significance (including a statement of need & statement of impact)
The term ‘Heritage Assets’ includes 'Designated Assets' such as Listed Buildings, Conservation Areas, Scheduled Ancient Monuments, Historic Parks, Gardens and Battlefields, as well as 'Non-designated Heritage Assets’ for example, sites and buildings of historic interest as determined by the Local Authority. In East Devon, such non-designated assets would include buildings on the Local List, and other non-listed houses, public houses, barns, and other farm buildings, amongst others.
The Assessment of Significance will need to contain a description of the significance of the heritage assets affected by the proposal, and the contribution of their setting to that significance.
It is important to note that Applications submitted without such Assessment of Significance will not be validated.
Statement of Significance guidance notes for listed buildings - East Devon
The applicant has provided this Assessment of Significance: the first paragraph has been copied above and demonstrates how the applicant has sought to justify demolition through belittling the heritage value of the Victorian hotel at Knowle:
Heritage and Archaeology Statement
However, national and regional heritage bodies would disagree:
“The alterations that have occurred both to the gardens and the house mean that neither meets the criteria for designation in a national context, though they are evidently highly-valued by the local community.”
Required to accompany applications for listed building consent and planning permission affecting heritage assets
This guidance note is designed to show you as the applicant/agent what information you should be submitting as part of your Assessment of Significance, and where to find that information.
In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance. As a minimum the relevant historic environment record should have been consulted and the heritage assets assessed using appropriate expertise where necessary. Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.
These statements will form part of the justification for the proposal and should demonstrate that consideration has been given to the protection of the heritage asset and/or its setting. The purpose of the Statement is to identify the important characteristics/significance of the existing heritage asset and to explain how the proposals would affect these and justify why this is necessary or desirable. If appropriate the Statement can be incorporated as part of a Design and Access Statement as long as it is clearly identified within the overall document. A complete Statement must include:
- Statement of significance of the heritage asset
- Details of the proposal
- Analysis of the impact of the proposal on the significance (including a statement of need & statement of impact)
The term ‘Heritage Assets’ includes 'Designated Assets' such as Listed Buildings, Conservation Areas, Scheduled Ancient Monuments, Historic Parks, Gardens and Battlefields, as well as 'Non-designated Heritage Assets’ for example, sites and buildings of historic interest as determined by the Local Authority. In East Devon, such non-designated assets would include buildings on the Local List, and other non-listed houses, public houses, barns, and other farm buildings, amongst others.
The Assessment of Significance will need to contain a description of the significance of the heritage assets affected by the proposal, and the contribution of their setting to that significance.
It is important to note that Applications submitted without such Assessment of Significance will not be validated.
Statement of Significance guidance notes for listed buildings - East Devon
The applicant has provided this Assessment of Significance: the first paragraph has been copied above and demonstrates how the applicant has sought to justify demolition through belittling the heritage value of the Victorian hotel at Knowle:
Heritage and Archaeology Statement
However, national and regional heritage bodies would disagree:
“The alterations that have occurred both to the gardens and the house mean that neither meets the criteria for designation in a national context, though they are evidently highly-valued by the local community.”
Futures Forum: Knowle: Victorian hotel and grounds ... application to English Heritage for national listing
"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."
Futures Forum: Knowle: Victorian hotel: heritage asset or not...
"It is important to note that statutory listing recognises nationally important heritage sites - but it does not follow that undesignated heritage assets do not merit protection or have no value."
Futures Forum: Knowle relocation project: SAVE Britain's Heritage >>> Historic England acknowledged that both the house and the park are of 'clear local interest' and are 'evidently highly valued by the local community'.
And the comments from mere members of the public on the planning application website are very critical of the lack of recognition of the heritage value of Knowle [for example: document 2310078]:
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
These same concerns were voiced at the time of the earlier planning application in 2013. Here is just one comment:
Ms Clare Eastland (Objects)
Comment submitted date: Fri 08 Feb 2013
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.
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
In which case, it could be strongly argued that the current application should be refused because it does not comply with a key policy in the Local Plan:
EN8 - Significance of Heritage Assets and their Setting
When considering development proposals the significance of any heritage assets and their settings, should first be established by the applicant through a proportionate but systematic assessment following East Devon District Council guidance notes for ‘Assessment of Significance’ (and the English Heritage guidance “The Setting Of Heritage Assets”), or any replacement guidance, sufficient to understand the potential impact of the proposal on the significance of the asset. This policy applies to both designated and non-designated heritage assets, including any identified on the East Devon local list.
local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf
See also:
Futures Forum: Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> and the rejected planning application 12/1847/MOUT of 1st March 2013 >>> Part four: Contrary to policy EN9 (Extension, Alteration or Change of Use of Buildings of Special Architectural and Historic Interest)
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