SVA response to final LDP June 2012
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SIDVALE ASSOCIATION’S COMMENTS ON
THE INSET MAP AND POLICIES FOR SIDMOUTH and
THE NEW EAST DEVON LOCAL PLAN 2006-2026 (the "Plan")
1.We note that the Inset Map and Policies are derived from Section 14 (Sidmouth) of the Plan plus other Sidmouth Policies from elsewhere in the document. It is helpful that you have collated all the various Policies regarding Sidmouth in one place.
2.We are commenting on both documents in this reply. The comments below are a non-exhaustive list and we reserve the right to make further representations at a later date.
3.We welcome this opportunity to comment on the Plan, and note that the provisions of the Localism Act 2011 enshrine in law the right of communities to contribute to the planning process. We welcome the statement from EDDC that: "
as a Council we need to be responsive to the views of Parish Councils, local neighbourhoods and other local area bodies and organisations
." (Plan para 5.2) and the section in the Plan which envisages involving communities in the writing of neighbourhood development plans, as provided for by the Act.
4.We are concerned that the Plan as it relates to Sidmouth does not mention the possible removal of EDDC offices from the Knowle to Honiton. We understand that EDDC will make a decision on its future later this year. If a decision to move were taken, this would clearly impact upon many elements of the Plan as it relates to Sidmouth, including the reduction of employment, provision of residential housing (since it is understood that the site is earmarked for such development), parking and green spaces. We understand the predicament that EDDC are in, in that the Plan is to be finalised before a decision is made on the Knowle, but the inclusion of housing in the Plan on both the Knowle and the Manstone Lane workshops pre-empts any decision on the Knowle and must be avoided at this stage.
5.We are particularly concerned that a number of proposed developments, including all of those flagged in the document entitled: "Evaluation of Potential Development Sites in/at The Towns of East Devon for Residential Development", which also mentions employment sites in relation to Sidmouth, would involve incursions into the Area of Outstanding Natural Beauty. We note the constraints placed upon EDDC when considering applications to build in this valuable and protected area and consider that there should be a very strong presumption against building in the AONB. We note the commitment from the Council that it will "conserve and enhance its outstanding natural environment which contributes to the economic and social wellbeing of its communities." (Plan para 3.5). We welcome this
commitment. We note, with approval, that EDDC is:
"proud of East Devon’s outstanding beautiful environment and we regard it as essential that we conserve and enhance it so that future generations can have the same high quality of life that we do."
6.As we noted in our comments on the "LDF discussion document" of 11
th August 2010, we still believe that the two halves of the District , (Eastern… more built up and an extension of the Exeter area and Western… rural, mostly AONB and the Jurassic coast), should have been treated differently for planning purposes. As we said at the time. "Because of the wide disparity, between the two areas it would then have been logical for the ground rules of the former to be different to the latter." This relates in particular for housing and employment. EDDC have chosen to ignore sensible advice on this matter, with the result that the Plan incorporates many illogicalities that are clearly evident today.
We are very concerned that, because of this "one size fits all" policy to the allocation of proposed numbers of residential dwellings and areas of employment land, EDDC has distributed District wide predictions of need, without sensibly considering the implications on each town. It would have made more sense to consider the very real implications of the large size and location of Employment Land and Dwellings on Sidmouth as has been done in the case of Budleigh Salterton, (see D6 below)
7.The Sustainability Appraisal, (SA), which forms an integral part of the Plan and is on EDDC web site, is dated 2010 and is clearly out of date. There are a number of comments in the SA, which clearly do not relate to proposals in the Plan. Examples are, (SA Preferred Policy Approach Draft CS 19, Sidmouth), Item 1. SA 250 new homes, Plan 150 new homes; SA (SA Preferred Policy Approach Draft CS 19, Sidmouth) Items 9 and 15, refer to the development being "within the town" and there is no mention of any proposed development in the AONB. The SA is a statutory part of any Plan, and it is evident that the effect on Sustainability of the proposals in the Plan have not been clearly thought out and carefully considered as they should have been.
B.BUILT UP AREA BOUNDARY, Strategy 6
We accept the Built-Up area boundary as shown on the Inset Map, except for the area to the north of Sidford, (shown as site for 5ha of employment land), which extends into the AONB, and must be omitted. The boundary should follow the line of the gardens. The Built Up area in this location should follow the Eastern side of the A 375 and the line of the back gardens of the houses fronting on to Sid Vale Close.
C.RESIDENTIAL LAND. Strategy 26-Development at Sidmouth, (formerly DS21) and H1, (Residential Land Allocation)
1.The Plan indicates that 565 new dwellings in Sidmouth have been built since 2006, are in the process of being built or where significant inroads have been made into the planning process. (table at page 34 of the Plan). Sidmouth has therefore already seen significant residential development in the past five years. The Plan provides for 100 further new dwellings for the town, with 50 more as "windfalls."
2.We question the provision for 100 new dwellings, a figure which appears to have been "plucked out of the air", without supporting evidence to justify the figure. We consider that no further non strategic provision should be made for housing unless the need can be conclusively established. The figure of 100 new dwellings does not appear to accord with EDDC’s prediction that the working population of Sidmouth will fall by 8% over the plan period. It seems more appropriate that natural growth should be allowed through windfalls as at present.
3.We see no rationale for the allocation of 20 dwellings at Manstone, 50 at the Knowle and 30 at the East End, 100 in total apart from the fact the total happily coincides with the total allocation of 100 dwellings, and that all these are on EDDC land. Manstone and the Knowle are currently employment sites for EDDC workers; thus allocation for housing will reduce the employment within the town which EDDC proposes to promote. (Strategy 26 bullet point 2).
4.We consider that there should be a very strong presumption against building in the AONB which surrounds the town. We note the commitment from the Council that it will "conserve and enhance its outstanding natural environment which contributes to the economic and social wellbeing of its communities." (Plan para 3.5)
5.We are pleased to note the provisions of Strategy 32 of the Plan, which provides that applications for a change of use from employment or retail to residential use will only be permitted where it can be demonstrated that there is no interest from local businesses in retaining the land for its current use and would hope that these principles will be conservatively applied. We consider that, unless there are exceptional circumstances, there should be no re-allocation of employment land for residential construction, nor change of use from another category, such as has happened at Parson’s Yard and the Fortfield site with EDDC’s approval.
6.We support the Policy that any new housing development shall be within the Built-up Area Boundary. We are concerned at the inclusion of the proviso "
unless monitoring shows that there are insufficient sites gaining Planning Permission to accommodate this scale in the Plan
D.EMPLOYMENT Strategy 26 Development at Sidmouth, (Jobs) and E1 Provision of Employment Land.
1.We note that EDDC states that "We have a priority to identify and promote development on Brownfield sites first… and to protect Grade 1 and 2 farmland" However this statement does not accord with the clear contradiction in the Plan of proposing 5Ha of Employment Land in AONB and Farm Land, when there is a very good Brownfield site already in existence at Alexandria Road Estate. EDDC should explain this reasons for this.
". EDDC have an obligation to monitor the Plan after 5 years; but it will be impossible to assess "progress" of new dwellings against a mythical 15 year target, (100/15=7 per year) at any time. There will be no stage at which EDDC might judge that the target was being achieved, for instance slow build over a few years might be balanced by faster build in later years. House construction depends on a number of factors, especially economic, all of which will affect a build rate. We do not consider that monitoring will serve any useful purpose, but as it stands, the proviso weakens the stated intention to retain development within the Built-up area boundary. We therefore suggest that the proviso be removed.
7.We support the policy set out in Strategy 34 of the Plan that 50% of any new development (net gain 1 dwelling) shall be affordable housing.
2.We support EDDC’s stated aim of supporting "
modest employment…growth to meet locally generated needs
." However, we do not accept the posited creation of a new 5 hectare employment land site north of Sidford for three reasons:
2.i.Firstly the Need. We do not accept the rationale on which the 5 hectares allocation has been made, (namely that the number of new houses built plus the council’s stated policy to reduce out-commuting from Sidmouth by 50% necessitates the creation of approximately 1,300 new jobs) is a reasonable one.
2.ii.Secondly the Demand. In order for job creation, it is essential that employers wish to locate to Sidmouth. No evidence has been provided that there is such a demand from employers.
2.iii.Thirdly the Location. We take issue with the proposed location of the new site.
To enlarge upon each of these points:
3.i.EDDC has proceeded on the assumption that each of the new dwellings built since 2006,
( Plan, table page 34),
creates a need for 1 new job. Apart from the inaccuracy of this figure, (Roger Tym’s report puts it at 0.81 taking East Devon as a whole), the area-wide figure measure needs some adjustment in Sidmouth’s case to take into account the large number of retirees who occupy any new dwellings and who will not require a job.
3.ii.Furthermore there is no evidence that for each of the 238 dwellings that have already been built and occupied there is still one person looking for work, indeed the percentage of unemployed people in Sidmouth is very low.
3.iii.The relative health of the employment market in Sidmouth is shown by the fact that it is a net in-commuting town, -326 net inwards from EDDC ‘s own figures.
(Report setting out Justification for Employment Provision in the Draft Local Plan Table 1)
It has an exceptionally high retained employment rate of 67%, which is the highest for any small town in England. The principal employers in Sidmouth are the Hotel, Leisure and Retail businesses, most of whom are active in the employment market. The Plan argues that there is a need to up-skill the type of work available; we would not disagree, but an arbitrary increase in employment land available will not attract new high tech employment to the town; this is supposed to be the preserve of EDDC proposals in the West End.
3.iv.EDDC has a policy that 50% of all current out-commuters, (782), should be provided with a job in Sidmouth,
( Report Setting out Justification for Employment Land 2011. table 1) Whilst we support measures to reduce the level of commuting, we believe that the target of halving the number of out commuters is unrealistic in Sidmouth’s case. Sidmouth already has a much higher percentage (67%), of retained workers that any other of the seven towns, whose average is just over 50% (ibid)
. To achieve this level of employment in the town, approximately 84% of Sidmouth workers would have to work in the town itself, an extremely high figure. There will always be a significant number of people, who by virtue of their business sector experience, or specialisation, will be drawn to work in Exeter or further afield. The out-commuters travel because they seek work that Sidmouth is not able to offer, such as at the University or Met office, in the larger hospitals or professional firms. Sidmouth has a very high percentage of University graduates (37% of the working population) and it is inevitable that many of these will seek highly specialised employment which is likely to centre around Exeter, the regional hub.
4.i.EDDC’s rationale for requiring the additional employment land is based on an employer need for Sidmouth based jobs which EDDC has not demonstrated to exist There is no evidence that provision of office space, (B1) on the fringes of the town, would attract 1300 jobs in the next 15 years,
(Ibid, table 1),
indeed EDDC has provided no evidence that there is any business demand for such space at all. The only evidence available is that of a
Sidmouth employer who has expressed an interest in moving from a central town site to the site shown on the Plan.
4.ii.In order for a site of 5 hectares to be justified, a major new employer, or more realistically several major employers would have to move to the town.
4.iii.There is no evidence that this demand exists, and we would question whether such demand can be created given: (a) given the comparatively poor access to Sidmouth; (b) its distance from the two main transport arteries the A30 and M5, as well as the absence of a rail link; and (c) the opportunities being promoted by EDDC elsewhere.
4.iv.We note that the 2007 Atkins report highlighted several areas in East Devon for employment land development, but since the Atkins consultants considered that good transport links were essential to any new development area, Sidmouth was not one of them.
4.v.Estate Agents in the town have confirmed that they have had no enquiries for land purchase for new businesses in the recent past, and the Tyms report highlighted the comparatively long average time taken to re-let commercial units in East Devon, which implies a lack of demand.
4.vi.Furthermore, we note that there are considerable developments being built or planned elsewhere, particularly in West End and around Honiton and question whether a development in Sidmouth would appeal favourably to tenants in comparison to these alternative locations. We also note that EDDC has made a commitment that: "
Care will be taken to avoid over provision where this might inhibit successful market delivery and local wealth creation."
4.vii.EDDC has not, so far as we are aware, carried out research into the need for a new site and its stated approach to identifying sites for potential employment land development is to await approaches from local landowners offering their sites for development.
4.viii.We believe that there is a small requirement for SME start up units. But these can be quite easily be provided on existing sites in the town and would not require a 5 hectare B1 use class site.
5.i.Strategy 31 of the Plan states: "
As part of any proposal for development of employment land evidence will be taken into account of the suitability of existing available and unused or
underused employments (sic) sites and the ability of these to meet the needs for proposed development."
It is gratifying to see therefore that EDDC accepts, (para 14.4) in the Local Plan, that they would support any initiative to provide a safer access to the estate from the B 3176.
5.iv.Whilst we acknowledge that poor access limits the use of the site, it is clear that the site has the potential to provide space for large numbers of employees, before destroying AONB land in a wholly unjustified proposal.
5.v.The recently adopted NPPF continues the previous policy of preservation of AONB land from earlier planning Guidance."
Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and AONBs which have the highest status of protection in relation to landscape and scenic beauty". ( Core Planning Principles 115).
No attempt has been made by EDDC to examine the impact of allowing Employment Land on the AONB, through Traffic effects, Environmental effects, or any other measure which would try to assess the impact of building in such a sensitive area. EDDC have NOT demonstrated to any extent the need to permit building in AONB land, which they are required to do when contemplating it.
5.vi.The Local Plan does not in itself consider the attributes of the proposed site in AONB land, but an assessment is included in the document entitled:
"Evaluation of Potential Development Sites in/at The Towns of East Devon for Residential
Rather than making a strategic allocation of a suitable site for development, EDDC have adhered strictly to a policy of proposing sites that have been nominated by landowners; in this case sites at Sidford and at the Sidford Garden Centre, both in AONB land. In the latter case a recent Planning Inquiry determined that further development could not take place there because of the effect on AONB land. This equally applies to the Sidford site.
5.vii.We would also note, in relation to the Sidford site, that there would be considerable problems with access, since all site traffic would have to pass through either Sidford or Sidbury. The A375 narrows considerably through both villages and this already creates a bottleneck which would only be exacerbated if additional commercial traffic (some of it possibly HGV traffic) were to use the road.
6.Sidmouth is allocated 5 Ha non strategic employment land out of a total of 12 Ha in East Devon. Budleigh Salterton is allocated 3 Ha in the same document, but there is no Employment land shown as being provided as "
In light of this statement, we would expect any provision for Sidmouth to consider first the existing employment land sites and how their potential can be maximised. We consider that by maximising the potential of the Alexandria Road site any immediate need for further development of employment land would be abrogated. We note that the initial development of employment land posited in the Plan envisages that only 3 hectares will be developed in the next 5 years, with a further 2 hectares to be developed at a later stage.
5.ii.The Alexandria Road Site has been used for many years by a variety of firms. In the past it provided employment for over 200 people working for Devon Caravan Conversions, as well as jobs provided by other firms. It has spare capacity of about 0.6 Ha (as acknowledged in the EDDC report). This would, if used, provide employment for a further 96 people using the criteria in the EDDC report.
5.iii.The Roger Tym Report on Employment sites only looked at the existing Alexandria Road site, and concluded that, although there is capacity, this is hindered by the poor access.
Budleigh has a relatively low need and given the environmental constraints of the town and lack of evidence for demand, it is not proposed that allocations are made." Table 3 of the Report Setting Out Justification of Employment Provision,
Thus Sidmouth, a very similar town to Budleigh, with a similar profile, is being treated very differently.
E.Town Centre. The Knowle. East End, Strategy 26 Development of Sidmouth; E9 Town Centre.
1.i.The Plan states that the policy is to "
enhance the environment and promote business opportunities in the town.
" This is to be commended.
1.ii.We are perplexed to see therefore that there is no mention of EDDC’s intention to relocate to Honiton and vacate their HQ in the centre of Sidmouth.
1.iii.Any such move would have serious consequences for the town and we fail to understand why an analysis of these consequences and its detrimental effects have not been discussed or even mentioned.
1.iv.EDDC’s intended relocation from the Knowle will in itself reduce the number of jobs and employment land in the town, should it come to pass, with 100+ Sidmouth jobs being relocated to
Honiton. This in turn will increase out-commuting from Sidmouth (contrary to the aim of reducing out-commuting by 50%).
1.v.The removal of the EDDC offices from the Knowle would have a knock on effect on other businesses in the town, particularly in the retail and food sectors, since EDDC employees who currently take advantage of Sidmouth town centre would not do so if the offices are moved to Honiton.
1.vi.The proposed conversion of the land at the Knowle to residential use directly contravenes EDDC’s own policies set out in the Plan (
contravening Section 24.5, Loss of Employment sites, and Policy E3 Safeguarding Employment Land and Premises)
which lays down strict guidelines for change of use of employment land.
1.vii.The reuse of the Knowle for up to 50 dwellings has been proposed in the Plan, so it would appear that EDDC is minded to approve the change of use, without any evidence that it has considered any employment land options or attempted to secure the future of the Knowle as employment land as required by Strategy 32.
1.viii.At the Knowle, EDDC’s own Strategy 34 dictates moreover that 50% of any such housing would have to be affordable. It is not clear how this objective is to be delivered.
1.ix.The draft town plan shows these 50 dwellings being partially situated on the current car parking area; thus depriving the town of the useful "Park and Walk" facility which it currently enjoys.
1.x.Further, any wholesale development of the Knowle, and the loss of the green space which it currently occupies, flies in the face of EDDC’s stated commitment to "increase expectations for green space and recreational space within towns." (Plan para 3.4)
We re-iterate that the Sidmouth plan MUST take into account EDDC intentions, so that the effect on the town centre, public open space, the employment and commercial implications on the town, and the traffic and environmental issues can be clearly assessed.
East End (14.3 Main LP page 83)
2.i.We are very disappointed at the lack of any outline proposals for the East End, and expect that EDDC will provide a stronger commitment to regeneration there than the current statement which merely says in 14.3, "Conserving and enhancing the built environment and historic qualities of the town centre and Seafront, (sic), …".
2.ii.Sidmouth needs a definite plan to achieve the outcomes of Para 14.3 bullet point 6, and a commitment to providing one would be welcomed in this plan
2.iii.The 30 dwellings at the East end are shown as being in a "mixed use" redevelopment. Clearly if there is to be any regeneration at the East End of the Esplanade, then in the probable absence of any public funding, a developer would have to provide these, and would expect returns through housing provision. In this event, clearly he would want to maximise his financial returns, which would mean high cost dwellings have to be provided. But this militates against the real need of the town, which is affordable housing for key workers.
F.Park and Ride. Strategy 26 Development of Sidmouth; Infrastructure.
1.The Local Plan (The Vision) page 82 and 14.3 bullet point 8, and Strategy 26, mention "Park and Ride", (and Park and Change) provision.
2.Sidmouth already has a "Park and Walk" facility at weekends, using the EDDC car park. This is well used in the prime tourist months, and we support its continued provision. This land is shown as being used for new housing in the Plan, which implies that in the event of EDDC moving this would pre-empt its use as "Park and Ride/Change" facility. If EDDC do not relocate then equally there is no possibility of using this land as a "Park and Ride/Change" except at Weekends. In any case the closeness of the current Park and Walk to the town centre precludes it as anything other than the current use.
3.The report makes use of two terms; "Park and Ride" and "Park and Change". The former is presumably for tourists and residents who would be encouraged to park their cars to ride into town on a bus, the latter would be provided presumably to enable travellers inside and outside Sidmouth to park their cars to travel to Exeter and similar towns on buses.
4.EDDC has undertaken no analysis of the need or effects of these, and they are merely badly thought out and ill defined aspirations
5.We believe that neither a "Park and Ride" or a "Park and Change" facility are physically viable or needed in the town.
5.i.Park and Ride. Very few residents would use it as they would not drive out of town to come in again by bus. Some tourists might use it but there is no evidence that there is a lack of parking in the town that is a disincentive to them, or that its provision would decrease congestion in the streets.
5.ii.Park and Change. Residents who want to travel to Exeter by bus can and already do so by regular services which depart from the centre of town, and various stops along the exit road.
5.iii.Equally as importantly, there would be no location for it except in AONB land.
6.Apart from the vague aspirations in the Plan, there are no definitive proposals for provision, which would require the acquisition of a considerable amount of land in AONB. We believe that the Plan must review these aspirations, which
MUST NOT BE in the AONB.
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