Sunday, 29 May 2016

Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> and the rejected planning application 12/1847/MOUT of 1st March 2013 >>> >>> >>> >>> >>> Part three: "Contrary to policy D1 (Design and Local Distinctiveness)"

It can be clearly demonstrated that the same District Council policies as laid out in the Local Plan apply to both the rejected planning application at Knowle of 1st March 2013 and the planning application currently out for comment:

The third reason the Development Management Committee gave for rejecting the 2013 application can be equally applied to the latest planning application from PegasusLife:

3 - Contrary to policy D1 (Design and Local Distinctiveness)

The DMC considered that the application of 1st March 2013 would be 'harmful to the visual amenity and character of Station Road':

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

3. The proposed development as a result of its close relationship with Station Road and prominent position on the entrance to the town would be harmful to the visual amenity and character of Station Road which forms an important approach to the town through which many tourists and other visitors to the town pass. The loss of amenity and character to this area would be contrary to policy D1 (Design and Local Distinctiveness) of the adopted East Devon Local Plan


And indeed, looking at the Proposed Site Plan for the 2013 application, it was judged that these plans did pose considerable ‘impact on the visual amenity and character of Station Road’:

The question is, however, whether the current plans would also be ‘harmful to the visual amenity and character of Station Road’.

With regard to these latest plans, the developer PegasusLife make their case very clear. 
In the accompanying plans on their website they state that ‘Our site includes the EDDC buildings and parts of the grounds including the council car park. It does not include the car park near Station Road.’

However, within the context of not building directly on Station Road (which was a feature of the 2013 planning application), the developer omits mention of the height and scope of the buildings on the site as a whole - and that is considerable and unprecedented.

In fact, it has been estimated that should this go ahead, the tallest building on the Knowle site would be the second highest in the area - second only to the parish church:

Such is the height and mass of the proposed development, in the so-called ‘Dell’ taking up the car park as well as the larger ‘Plateau’ above, there would clearly be considerable ‘loss of amenity and character to this area’ – not only for Station Road, but for large parts of the town and beyond.


The building cannot be regarded separately from the grounds.

The Knowle gardens are on the Devon Local Register.

The Devon Gardens Trust has been instrumental in campaigning for the integrity of the grounds and gardens at Knowle. This is from their objection to the 2013 planning application:

The parkland of The Knowle forms part of the attractive approach to Sidmouth, providing an important contribution to the overall historic character and landscape of the town. In this respect the development proposed would have a significant detrimental effect upon the setting of the conservation area and views into and out of it. 

Letter to East Devon - Knowle - 5-11-12.pdf
Futures Forum: Knowle relocation project: "How buildings sit in their landscape"


The Knowle grounds are immediately adjacent to the East Devon Area of Outstanding Natural Beauty – and as such are afforded more protection than the planning application refers to:

Current maps indicate the close proximity of Knowle to the East Devon AONB. , as does aerial photography. EDDC’s own regulatory framework requires that proximity to AONB be taken into account:

‘The policy stipulates that development will only be permitted within or adjacent to the East Devon AONB where it conserves or enhances the landscape character of the area, respects traditional local built forms and complies with policies on development in the countryside.’ (page 130)

Futures Forum: Knowle relocation project: "How buildings sit in their landscape"
Futures Forum: Knowle: Victorian hotel and grounds ... application to English Heritage for national listing

The East Devon AONB authority also makes this clear:

The EDAP would like to be consulted on planning applications in the AONB or within close proximity to the boundary, which fall into the following categories and are thought to be potentially damaging to the AONB landscape and coastline features. Residential development: applications within settlements involving 5 or more dwellings (or, where the number of dwellings is not indicated, the site area is 0.2 hectares or greater), except where the site is specifically allocated for residential use in an approved plan. Outside settlements, applications involving a smaller number of dwellings (or a smaller site area), or the conversion of agricultural buildings, at the discretion of the planning authority.


It is clear, however, that the latest planning application will have an impact way beyond the immediate vicinity of Knowle.

In its comment so far, the Save Our Sidmouth group has highlighted ‘the height and visual intrusiveness of the buildings, and the massing’:

Visual impact of developer’s plans for Knowle raises concerns

May 18, 2016

PegasusLife have made their Planning Application for the Knowle. The reference, to be quoted in any correspondence, is 16/0872/MFUL. The return date for comments and objections at the moment is 15th June.

Save Our Sidmouth (SOS) has numerous comments on the proposal, which will be submitted to East Devon District Council (EDDC) in the near future, and published on this website, in advance of the due date, to enable you to comment if you so wish.

Foremost amongst SOS objections will be

— the excessive number of dwellings planned, (Currently 115, in contrast to 50 allocated in the Local Plan)

— insufficient parking for the residents, which will mean they are likely to use the remaining public car park

— building on the existing terraces

— use of inappropriate materials and finishes

— and, very importantly, the height and visual intrusiveness of the buildings, and the massing.

The buildings are high (e.g. building F is nearly 7m higher than the existing roof line) and will have a far greater visual impact than the present ones.

Present view of Knowle buildings as seen from across the Bickwell Valley:

An approximation with heights verified, of the west face of the Knowle Plateau using Pegasus’s drawings – as not supplied in their Townscape and Visual Impact Report. The rear buildings have been omitted here, in order to show a section of the existing Knowle building- for scale:

Visual impact of developer’s plans for Knowle, raises concerns | Save Our Sidmouth

On the other hand, the Townscape and Visual Landscape document from developers PegasusLife, part of the Planning, Design and Access Statement, is breath-taking in its blasé take on the visual impact of its proposed plans:

The Policy D1 in the adopted Local Plan makes it clear that it is a priority of the District Council to preserve the local distinctiveness of Sidmouth – and it is clear that this latest planning application does not do this.

The Local Plan has several statements to that effect:

Strategy 48 - Local Distinctiveness in the Built Environment:

Local distinctiveness and the importance of local design standards in the development process will be of critical importance to ensure that East Devon's towns and villages retain their intrinsic physical built qualities. Where towns or villages are or have been despoiled we will seek to have qualities reinstated through good design. Use of local materials and local forms and styles will be essential to this distinctiveness.

We will work with our partners and local communities to produce Design Statements to guide new development and ensure its appropriateness.

And the Policy continues with a commitment to look after the historic landscape – which echoes the concerns of the DMC in 2013 about the impression Sidmouth would give ‘tourists and other visitors’:

Historic Environment:

18.60 We regard it as essential that we conserve and enhance the historic environment of East Devon. The traditional buildings of East Devon bring pleasure to residents and visitors alike, they form a key part of the tourism appeal of the District and help define the identity of East Devon.

As for the Policy D1 itself, it is difficult to see how the current planning application cannot be rejected, as it fails to observe the key demands however many pages of Design and Access Statement there are (and there are 125 pages) - notably with regards to 'the scale, massing, density and height' of the buildings:

D1 - Design and Local Distinctiveness:

In order to ensure that new development, including the refurbishment of existing buildings to include renewable energy, is of a high quality design and locally distinctive, a formal Design and Access Statement should accompany applications setting out the design principles to be adopted should accompany proposals for new development.

Proposals should have regard to Village and Design Statements and other local policy proposals, including Neighbourhood Plans, whether adopted as Supplementary Planning Guidance or promoted through other means. Proposals will only be permitted where they:

1. Respect the key characteristics and special qualities of the area in which the development is proposed.

2. Ensure that the scale, massing, density, height, fenestration and materials of buildings relate well to their context.

3. Do not adversely affect:
a) The distinctive historic or architectural character of the area.
b) The urban form, in terms of significant street patterns, groups of buildings and open spaces.


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