2013 VGS Futures Forum – comment on District Council Local Plan

This was sent yesterday on behalf of the Vision Group’s Futures Forum to localplan@eastdevon.gov.uk:

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