Knowle relocation project > Pegasus planning application 16/0872/MFUL >>> Strategy 4 - Balanced Communities >>> Strategy 34 - Affordable Housing Provision Targets

There are several Policies and Strategies in the Local Plan which the current planning application falls foul of - simply because its main features are pretty much the same as the failed application back in 2013:

1: 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)"

2: Futures Forum: 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)"

3:Futures Forum: 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)"

4: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)

And there are several other such Strategies which this latest application is 'contrary to':

BALANCED COMMUNITIES AND AFFORDABLE HOUSING 

There has been considerable concern of late about the District's ageing population - and what that means for the balance of communities:
Futures Forum: “We need a more balanced community." >>> "The Sid Valley needs a ‘long-term vision’ to attract more young people and families,"
Futures Forum: East Devon's demographic time bomb >>> >>> >>> >>> >>> "the District Council has a duty to create balanced communities"

It is also a concern of the District Council - as detailed in the Local Plan:

Strategy 4 - Balanced Communities

By balanced communities we mean that in any area or neighbourhood there is a match between jobs, homes, education, and social and community facilities. Ideally these should compliment the range of ages of the resident population and have appropriate access for those with disabilities. Key components of a balanced community include:

c) Getting more age-balanced communities - many East Devon communities have an overtly aged population profile. Where this is the case we will encourage residential development that will be suited to or provide for younger people and younger families.

And that means having more affordable housing:

Strategy 34 - District Wide Affordable Housing Provision Targets: 

Affordable housing will be required on residential developments in East Devon as follows . 

Areas to which higher (50%) affordable housing targets apply: 
Outside of the areas listed above (i.e. all other parts of East Devon including all settlements not listed, coastal and rural areas and Budleigh Salterton and Sidmouth) 50% of the dwellings shall be affordable subject to viability considerations. The 50% figure applies to all areas that do not come under the 25% classification and which are permitted under Strategy 35 ‘Exceptions’ policy. Where a proposal does not meet the above targets it will be necessary to submit evidence to demonstrate why provision is not viable or otherwise appropriate. An overage clause will be sought in respect of future profits and affordable housing provision, where levels of affordable housing fall below policy targets.

Five Year Land Supply and Sub-Housing Areas

20.5 The following table indentifies key monitoring indicators

Vision/Objective/ Aspiration:

Provide affordable housing to retain younger people in our neighbourhoods and communities as well as housing others in need 

local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf

AFFORDABLE HOUSING SHOULD BE PROVIDED ON SITE

All of this is confirmed through an FOI request into correspondence with the developer before a formal planning application was submitted:
Pre Application meetings with Pegasus - a Freedom of Information request to East Devon District Council - WhatDoTheyKnow

The senior Planning Officer dealing with the application has made it clear that the applicant has certain obligations - and there is also disagreement over the classification of the proposed development:

Our conclusion based on this assessment and a Counsel opinion is that the proposed units should be classed as C3 (dwelling houses). [Rather than the C2 classification desired by the applicant. See: Building Use Classes C1 C2 C3 - Planning Consultants London and Clarification of Planning Classes with regards to C3(b) and C2 - GovYou]

Turning to the issue of affordable housing the newly adopted policy of the East Devon Local Plan (Strategy 34) sets out a target of 50% affordable housing for residential development in Sidmouth. The presumption is that such affordable housing should be provided on site. As a result we will be seeking on-site provision of affordable housing in this case. We appreciate that the provision of your mandatory well-being care and support package is likely to be unviable to a registered provider but can see no reason given the layout of the proposed units on the site why your care and support package would have to apply to all residents. The facilities could still be available to residents of the affordable units on the same basis as they will be available to the wider community. We would however accept that it would be appropriate for the affordable units to also be age restricted and we believe that there is sufficient demand in the local area to fill the affordable units. Strategy 34 does allow for an offsite contribution of equivalent value to be provided where the inability to make provision on-site can be justified through evidence from Registered Providers or for other planning reasons. We would be open to considering a case for provision to be made off-site but as detailed above the presumption is that provision should be made on-site in the first instance and so the onus would be on yourselves to demonstrate to us why this would not be possible. You should also note that Strategy 34 is predicated on ensuring that developments are viable and so in the event that you believe that our requirements are unviable we are willing to consider a suitable robust and independent viability assessment. Our usual practice is to obtain an independent appraisal of such viability information through the District Valuer. We must advise at this stage that we would expect the cost of the District Valuer to be borne by the developer.

We understand that both the assessment that the scheme constitutes a C3 use and the level of affordable housing sought will come as a disappointment but we can assure you that these issues have undergone a very detailed consideration by Officers with appropriate independent legal opinion. To date we believe that we have had meaningful and constructive discussions and look forward to these continuing in respect of this issue. [And 'viability' is a very slippery commodity: Revealed: how developers exploit flawed planning system to minimise affordable housing | Cities | The Guardian and  The truth about property developers: how they are exploiting planning authorities and ruining our cities | Cities | The Guardian]

KnowleUseClassLetter.doc

The question to ask, therefore, is: 
Why, then, did the District Council chose as its preferred developer a company which specialises in building 'assisted-living apartments and wellness facilities for over 60s'?
Introduction | PegasusLife
Pegasus agreement re Knowle - a Freedom of Information request to East Devon District Council - WhatDoTheyKnow

It had other bidders as part of the tendering process, but nevertheless preferred PegasusLife:
Decision process which led to the award of the conditional contract with Pegasus re Knowle - a Freedom of Information request to East Devon District Council - WhatDoTheyKnow
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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)

The latest planning application at Knowle very much parallels the application of 2013, when the planning committee (or, DMC) rejected the plans on several grounds:

- 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)"

- Futures Forum: 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)"

- Futures Forum: 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)"

The DMC’s fourth and final reason for rejecting the planning application on 1st March 2013 also has parallels with the current application:

4 - Contrary to policy EN9 (Extension, Alteration or Change of Use of Buildings of Special Architectural and Historic Interest)

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

4. The proposed development would have a harmful impact on the setting of the listed building known as Balfour Lodge which formed one of the original gatehouses to Knowle by virtue of its close relationship and the form of development proposed. The development would therefore be contrary to policy EN9 (Extension, Alteration or Change of Use of Buildings of Special Architectural and Historic Interest) of the adopted East Devon Local Plan.

http://www.eastdevon.gov.uk/special_dev_man_010313_mins.pdf

These 2013 plans did indeed ‘have a harmful impact on the setting of the listed building known as Balfour Lodge’:

http://planningapps.eastdevon.gov.uk/Planning/StreamDocPage/obj.pdf?DocNo=1010422&PDF=true&content=obj.pdf (document 1010422 on page 164)

It is, however, clear that the current plans do not constitute any such threat, as there would be no building on the lower car park, which is opposite the Lodge – as made clear  by the developer PegasusLife.

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.’

Introduction | PegasusLife

https://planning.eastdevon.gov.uk/online-applications/applicationDetails.do?activeTab=externalDocuments&keyVal=O5ICQCGH01C00 (document 2267858)

SUMMERHOUSE IN THE GROUNDS OF KNOWLE: 2013

However, what the objection made by the DMC on 1st March 2013 to that planning application omitted was that the plans they rejected would have had ‘a harmful impact on the setting of the listed building known as’ … the Summerhouse.

Because what was a serious shortcoming at the time was the undervaluing of the site’s most vulnerable Grade II Listed Building:

Summerhouse in the Grounds of Knowle, Sidmouth Urban Didstrict Offices - Sidmouth - Devon - England | British Listed Buildings

Rather depressingly at the time of the 2013 application, the District Council did not seem to be particularly bothered with this Listed Building. It was very unclear how the planning application would affect the summerhouse:

'When you sell the Knowle, what will happen to the listed building and the grounds that are open to the public?'

'There is a Grade II listed summerhouse in Knowle grounds and this will be given appropriate consideration within the planning process. It will be up to the developer to decide if they wish to retain the structure or seek to remove or relocate it and this will be part of their planning application.’ 

[EDDC: Moving and Improving site: FAQs July 2012]

This approach would certainty not endear the developers to English Heritage:

Setting of Heritage Assets | Historic England

https://content.historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/gpa3.pdf/

Moreover, the Heritage Statement put together by consultants Kensington Taylor in 2012 was rather damning of the quality of the setting of the summerhouse:

http://planning.eastdevon.gov.uk/online-applications/applicationDetails.do?
http://planningapps.eastdevon.gov.uk/Planning/lg/GFPlanningDocuments.page

With a critique of the report from the time:

The report claims that the buildings and grounds are ‘much altered’ and that ‘the setting of the listed Summerhouse is already much compromised and divorced from the original integrity of the extended grounds.’ This understanding of the setting is in much dispute, as has been made clear by the submissions from established bodies including the Devon Gardens Trust and SAVE Britain’s Heritage.

Critique of the Heritage Statement for the revised plans for the Knowle. | Save Our Sidmouth

SUMMERHOUSE IN THE GROUNDS OF KNOWLE: 2016

With regard to the latest planning application at Knowle, the developer makes it quite clear that it will not be interfering with the summerhouse:

The park, the car park near Station Road and the existing Grade II listed summerhouse will remain in public ownership.

Introduction | PegasusLife

Nevertheless, as with the Kensington Taylor report of 2012, the 2016 Heritage Statement clearly intends to diminish the value of the 'setting' of the heritage asset - thereby justifying the building on the terraces immediately above the summerhouse:

"Although there is still historic and visual linkage between the asset and the Knowle, the dgreee to which the structure is perceived as part of a Victorian garden landscape has, however, been almost entirely lost."

And yet there seems to be some hesitation as to the value of the terraces as part of the setting:

"The principal element of setting for this listed building is therefore considered to be the gardens in which is sits, whilst the wider surroundings, including the Knowle, all provide a minimal level of value to its significance."

Heritage and Archaeology Statement

Planning, Design and Access Statement

The Devon Gardens Trust, SAVE Britain's Heritage and English Heritage (now known as Historic England) would disagree:

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, actually, the terracing at Knowle, which would have been a late Victorian piece of landscaping, is in integral part of the parkland - and as such provides the 'setting' for the summerhouse.

Japanese garden design might seem a million miles away from Sidmouth, but an observer sent in this comment:

"Orientalism became popular in the 1860s onward which accounts for the increased exoticism of many gardens. The verandah arrangement connecting the interior with the lawns could be described as oriental."

Savills UK | The Knowle | Development | To Buy

"In Japan the engawa links the inside and outside, and this inbetween space is known as ma. Another key Japanese garden elements is “Shakkei” which is borrowed landscape, ie view to the sea through the trees as if an extension of the park."

East Devon Council headquarters go on sale | Western Morning News

Futures Forum: Knowle relocation project: "How buildings sit in their landscape"

The summerhouse is just behind the evergreen tree in the foreground to the right...

And the upper lawns above this will be built on under the current planning application:

Futures Forum: Knowle relocation project: "The great garden grab"

Futures Forum: Knowle relocation project: "A magnificent new development coming soon, situated in a stunning, historic landscape with extensive gardens and leisure spaces."

Futures Forum: Knowle relocation project: expropriation & eminent domain >>> "The principle that there is a public realm of common citizenship and essential public goods and space which ought not to be appropriated for private benefit."

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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'.

The national campaigning group SAVE has intervened twice over planning applications to demolish the Victorian hotel at Knowle:
> to object to the outline planning application of March 2013
Futures Forum: Knowle: SAVE Britain's Heritage
> and to object to the current application:
Futures Forum: Knowle relocation project: SAVE Britain's Heritage >>> "Loss of the Knowle and development of the park would represent a devastating blow to the history and character of Sidmouth."

The developer has sought to belittle the importance of this organisation. In its Heritage and Archaeology Statement, PegasusLife have this to say in the opening paragraph:

Heritage and Archaeology Statement
To be found at the documents section of the planning application (document 2267528):
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

SAVE have now sent in a formal letter of objection:

 

Throwing away our heritage? London-based SAVE vehemently objects to plans for Knowle | Save Our Sidmouth
Save Britain’s Heritage objects to Knowle PegasusLife development | East Devon Watch
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Rewilding Devon: the return of the lynx?

There is a successful 'rewilding' programme happening in Devon:
Futures Forum: On the River Otter: releasing beavers as part of the DWT's "groundbreaking project"

There are moves afoot to reintroduce another species to the wilds of Devon:
Watch: Are lynx returning to Devon's countryside? | Exeter Express and Echo

The Plymouth Herald looked a little deeper:

Wildlife watch: Big cats could return to Devon countryside

By WMNKRossiter  |  Posted: May 23, 2016

Could wild lynx like these soon roam free in the hills near you?

A wildlife trust has established a breeding programme which aims to rescue this formerly native animal of Devon from extinction and return them to "rewilded" areas.

The Wildwood Trust, which operates a visitor centre at Escot, near Ottery St Mary, is inviting visitors to see the lynx as they champion rewilding in Devon.

Peter Smith, Wildwood's founder, said: "Devon's uplands have been destroyed by a century of overgrazing and it is our aim to return the wildwood to its former condition. By changing the rules of agricultural subsidies and returning a top predator like a lynx, our uplands could blossom with wildlife and draw people from around the world to enjoy a rebirth of wildlife.

"Once we let it go" Rewilding Promo - YouTube

The charity claims that rewilding can create an ecological and tourism resurgence in the county. The trust has built a natural woodland enclosure which shows off these formerly native animals that once prowled the woodlands of Devon. They have establishing a breeding programme which aims to rescue this formerly native animal of Devon from extinction and return it to rewilded areas.

Wildwood's two lynx are young brothers, born in 2015, and were a gift from the Royal Zoological Society of Scotland. They can be seen on sunny days lounging on their giant fallen tree or in their den. On wet days, look for them in their warmest den at the side of the enclosure.

What do you think? Share your comment with other readers below

The two lynx are about to celebrate their first birthday; Theron, the spottier of the two, is Greek for hunter, a word used in Latin languages for the 'untamed' & Lorcan comes from the old Irish for 'little fierce one' .

Mr Smith said: "Rewilding has many benefits, with more jobs, and cleaner water and air. Rewilding can have a major impact on reducing flooding downstream to farms and towns. The list of benefits far outweighs the negatives and the real challenge of the rewilding movement is to allow a democratic debate for the majority of the population to reclaim public policy on how our wild lands are managed."

The trust said the lynx was not dangerous to people, with no recorded attacks on humans in the wild.

The large cat is a top predator which will change the behaviour of the sheep and deer that have grazed Britain's uplands. Animals will avoid rocky outcrops and gullies, allowing the wildwood to establish and grow, providing ecological diversity at no cost to the taxpayer.

Environmentalist George Monbiot issued a call for the rewilding of Dartmoor and Exmoor at a national parks conference in Bovey Tracy last year.

David George from the National Farmers' Union said: "The countryside that so many people enjoy is largely a product of farming and other man-made interventions. Reintroducing lynx is pie in the sky.

"You can't turn the clock back hundreds, if not thousands, of years. We don't know what would happen. Where it has been done in Spain it's in much larger areas."

Visitors to the Wildwood centre can also see other formerly native wildlife such as red squirrels, wild boar, wildcats, and even beavers on beaver watch evenings.

The park boasts features such as a maze, adventure play area and treetop drop slide.

Find out more at escot.wildwoodtrust.org or call 01404 822188.

Read the view of hill farmer Robin Milton here. 

Are you ready to see lynx and wolves on Dartmoor and Exmoor?

Britain's uplands like Dartmoor and Exmoor should be returned to the wild for the benefit of human wellbeing, an Exeter conference has been told. Letting trees...

Anton Coaker: George's rewilding idea is garbage - let's move on

George Monbiot? I've been waiting for the dust to settle, before having my tuppence-worth. And remember, it's my family, my local community, and my extended...

Sheep are the 'white plague' of Dartmoor says activist

Dartmoor has been ruined by sheep, a meeting of national parks chiefs has been told.Writer and environmental activist George Monbiot called for the "rewild...

Wildlife watch: Big cats could return to Devon countryside | Plymouth Herald

See also:
Futures Forum: On the River Otter: beavers and rewilding Devon ............... and "trying to repair the monstrous damage we have inflicted on nature in Britain"
Futures Forum: Rewilding Britain >>> " a bio-engineered pastiche", or >>> "a feat of natural renewal"?
Futures Forum: On the River Otter: "The rewilding movement has been in the spotlight since the discovery last year of England’s first wild beaver population"
Futures Forum: Sharing Our Lives with Wolves: on BBC's Shared Planet
Futures Forum: James Lovelock and Science on 'Start the Week'
Futures Forum: New habitats, old habitats
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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:

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)"

Futures Forum: 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)"

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

combined-special-dmc-agenda-010313.pdf
combined-dmc-agenda-020413.pdf

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’:

http://planningapps.eastdevon.gov.uk/Planning/StreamDocPage/obj.pdf?DocNo=1010422&PDF=true&content=obj.pdf (document 1010422 on page 164)

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.’

http://www.theknowleconsultation.co.uk/

https://planning.eastdevon.gov.uk/online-applications/applicationDetails.do?activeTab=externalDocuments&keyVal=O5ICQCGH01C00 (document 2267858)

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:

Futures Forum: Knowle relocation project >>> a far more imposing development than assumed? Part Three

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.

HOW DOES THE KNOWLE SIT IN ITS LANDSCAPE?

The building cannot be regarded separately from the grounds.

The Knowle gardens are on the Devon Local Register.

The Knowle | Devon Gardens Trust

EDDC reject Knowle Planning Application | Devon Gardens Trust

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"

PROXIMITY TO EAST DEVON AREA OF OUTSTANDING NATURAL BEAUTY

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)

eastdevon.gov.uk/media/1167579/combined-dmc-agenda-120612.pdf
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.

http://www.eastdevonaonb.org.uk/uploads/documents/conserve/Policy%20and%20Planning/planning%20protocol_revised_Jun14v1.pdf

VISUAL IMPACT

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:

http://planningapps.eastdevon.gov.uk/Planning/StreamDocPage/obj.pdf?DocNo=2267755&PDF=true&content=obj.pdf

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.

http://eastdevon.gov.uk/media/1515081/local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf

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Quarrying in East Devon > inspector demands proposed quarry at Straitgate to be reduced in size

An inspector has been looking at the County minerals plan - including the Straitgate Quarry:

Futures Forum: Quarrying in East Devon > inspector to consider objections

The piece in the Express & Echo gives a very good summary of the Inspector's findings:

Devon Minerals Plan hearing recommends nearly 200 changes

By Exeter Express and Echo | Posted: May 28, 2016 By Anita Merritt

Nearly 200 modifications have been made to controversial plans which will set out the future of quarrying and mining in Devon following examination hearings this week.

The revised Devon Minerals Plan will result in further public consultation between August 1 to September 23, before being given Devon County Council committee approval.

There are 199 modifications altogether, though many are minor issues of clarity, updating and correcting errors.

The modifications include:

• Amending the vision and the spatial strategy policy to a more concise form;

• Widening mineral consultation areas for ball clay and china clay;

• Clarifying the tonnage of sand and gravel potentially available at Straitgate Farm;

• Greater detail on the means of access to the West of Penslade Cross site to avoid lorries passing nearby houses;

• Increased commitment to use of secondary and recycled aggregates

Examination hearings to consider objections over the Devon Minerals Plan were held over four days at Exeter’s County Hall, and concluded on Friday.

The plan underwent consultation last autumn, and proposes sites to achieve the supply of minerals to 2033.

It includes building a 100-acre quarry near homes in Uffculme.

Mid Devon residents expressed there anger that they had not been consulted for three years while the proposals were being drawn up, while those in East Devon, where another quarry is proposed at Straightgate, near Ottery St Mary, have successfully campaigned for the size of the potential quarry to be reduced in size.

The proposal for Penslade Cross in Uffculme would see 40 hectares – almost 100 acres – of agricultural land, lost to a sand and gravel operation. The land contains an estimated eight million tonnes of aggregate which would be used in the building trade.

Residents have also voiced concerns over a huge increase in lorry movements around junction 27 of the M5, and noise and dust pollution.

The examination hearings this week were conducted by government inspector Andrew Freeman. The aim was to establish the soundness of the minerals plan.

The emerging Devon Minerals Plan will eventually replace the existing Minerals Local Plan of 2004, and it is likely to be adopted by the end of the year. The plan aims to maintain the supply of the wide range of mineral resources produced in Devon, while minimising adverse effects on Devon’s communities and environment.

Devon County Council have said that while some of the resources have adequate reserves to last beyond the next 18 years, it is necessary for the plan to propose some new areas for working to ensure supply.

A Devon County Council spokesman said: "We are satisfied with the outcomes of the examination hearings which have enabled all parties to have their say on each part of the minerals plan. The modifications that have arisen from these discussions do not significantly alter the proposals within the plan, and largely address matters of detail and clarity."

Devon Minerals Plan hearing recommends nearly 200 changes | Exeter Express and Echo

Here is the piece from the EDW blog:

DEVON MINERALS PLAN: INSPECTOR RECOMMENDS MORE THAN 200 CHANGES

28 May 2016

It appears from the press release (link below) that the recommendation is that Straitgate Quarry should be reduced in size but the Inspector raised many issues about access and alternative sites to which he did not receive adequate answers.

Much centred on lack of consultation, and the amended report must now go out to public consultation again from August 1 to September 23,
http://www.exeterexpressandecho.co.uk/Devon-Minerals-Plan-hearing-recommends-nearly-200/story-29331545-detail/story.html

Report from the Straitgate Quarry Action Group here:
http://straitgateactiongroup.blogspot.co.uk/

Devon Minerals Plan: inspector recommends more than 200 changes | East Devon Watch

And here is the piece from the campaigning Straitgate Quarry Action Group - which suggests that we are no further forward:

What happened at the Examination?

The Examination of the Devon Minerals plan was adjourned today, after four days of hearings. An eight week consultation on modifications will begin in August; the Inspector will consider responses and produce his report by the end of October.

DCC and Aggregate Industries faced a number of difficult questions from the Inspector in relation to Straitgate. The Inspector learnt that despite Straitgate being one of DCC's Preferred Areas for future sand and gravel quarrying, despite the site being championed by the Council since 2012, despite consultations, discussions, reports and planning applications - we still don’t know how the site will be accessed or how the material will be processed. Fundamental unanswered questions. A Preferred Area is meant to be:

areas of known resources where planning permission might reasonably be anticipated

The draft Devon Minerals Plan puts forward two such areas. Even on the first day of the Hearing, in relation to over-provision of resource, the Inspector said:

I suppose the question is, do you need two Preferred Areas?

On the second day, questions started on Straitgate. On access, AI confirmed that it had no rights over the northern part of the site, leaving the only possible access on the southern side. The Inspector read out to AI what the company had previously said in its planning application to quarry Straitgate:

The southern option, onto the B3174, was dismissed early in the process on highway safety grounds. It would have been too close to existing accesses, including the access to Straitgate Farmhouse, and the vertical alignment of the highway at this point would compromise visibility. 5.44

Despite having had six months to sort this out, AI said it was still 're-assessing' this option; the option where the recent safety audit indicated that HGVs could only turn left - not right, where they would need to go; the option where only this week a DCC Highways Officer said "nothing has been resolved nor even tentatively agreed".

The Inspector moved on to processing. Having first ruled out Whiteball in Somerset, the Inspector read out to AI what the company had previously said in its planning application to quarry Straitgate:

It has been demonstrated that processing at Rockbeare is not physically possible due to a lack of silt space and clean water storage, insufficient stocking and processing area and the presence of great crested newts in existing ponds. 8.37

The Inspector wanted to know if AI had ruled out Rockbeare. AI wouldn't go that far, but did confirm that 'a detailed assessment had ruled it out as a viable option'. So, if not Rockbeare, what about Blackhill?

The Inspector read out to AI the objection from Natural England in response to the recent Blackhill/ Houndaller application; an application to process a fraction of the amount of nitrate-rich soils that would come from Straitgate:

At the current time, Natural England does not concur with the applicants view that the importation of the proposed material will not have an adverse effect on the East Devon Pebblebed Heaths SSSI/SAC for the following reasons... The unit of the East Devon Pebblebed Heaths adjacent to Blackhill Quarry contains sensitive wetland habitats including areas of M14 - Schoenus nigricans-Narthecium ossifragum mire which is dependent on low nutrient status. This habitat is more sensitive than any other wetland habitats and is very sensitive to any nutrient change...

AI said it was working on a response. DCC said it was not putting Blackhill forward as a processing site in the Minerals Plan, relying on the phrase:

Proposals for the off-site processing of extracted materials should be located outside of the AONB unless exceptional circumstances can be demonstrated.

Which is all well and good, but where does DCC think the material will be processed?

The Inspector also raised questions on the risk of birdstrike, soil storage, B3180, hydrogeology, ancient woodland, archaeology, hedgerows and dormice, heritage, visual impact on AONB, flooding and tourism.

A further question addressed the amount of resource, and this issue was also considered at the hearing today. Earlier on in the proceedings, it was made clear that AI had dropped the 460,000 tonnes of overburden from its plans; an issue we had raised last year.

On the remaining resource, only last month DCC had advised:

Given that Aggregate Industries has stated the quantity by which their original resource figure would be reduced by compliance with the requirements of Table C.4 of the Plan, I consider that it would improve clarity of the Plan if the currently-modified reference to "Up to 1.2 million tonnes" be replaced by "Approximately 0.9 million tonnes".

This was in line with the EA's position:

In addition, although it was our understanding that the minerals development at Straitgate would entail above max water table working, we note that the operator is now proposing an operation that does not conform to the requirements of this policy or the mitigation proposed in Appendix C.

DCC has now backtracked on its statement, relying on the number in AI’s hastily produced resource statement, which "assumes a working base that coincides with… the maximum recorded winter water table" - not 1m above it - and the Council persists with the notion that Straitgate could provide "Up to 1.2 million tonnes"; a ridiculous show of faith when you consider how many times AI has revised that number. The dry working scheme sanctioned by the EA - see post below - could only produce 900,000 tonnes, according to AI’s own Regulation 22 response, and this point was made to the Inspector.

To safeguard private water supplies, the Inspector recommended more consistent wording in the main body of the Plan to reflect the wording in Appendix C.4:

The development of this site will only involve dry working, above the maximum winter (wet) level of groundwater with an unsaturated zone of at least 1m maintained across the site.

In summary, the Inspector was left not knowing how processing of any material from Straitgate would take place nor how access to the site might be safely achieved; a ludicrous situation for a Preferred Area; a ludicrous situation when you consider how long DCC and AI have had to prepare for this.

Straitgate Action Group: What happened at the Examination?

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