East Devon District Council’s Local Plan public consultation is just about to close and as part of my consideration of local sites contained within the draft Plan, I set out here my views on the Plan and various specific sites.
In approaching my opinions on each of the proposed local sites that have been put forward by landowners and/or developers for consideration to be adopted within the local Plan that emerges following this period of public and subsequent District Council consideration I recognise the need to build more homes across East Devon, particularly social housing and affordable properties.
Equally, I recognise the need to provide sites to support local businesses, be they one person firms or larger SMEs, as we need to find ways to attract and retain employment locally. Additionally, we must find ways to build our tourism offer which is something that strongly supports our local economy and provides necessary local employment.
The big conundrums that the public and the District Council have to grapple with is how many homes and employment sites do we really need, not just for the immediate future but across the life of this Local Plan and where should these be allocated? In Sidmouth and the wider Sid Valley there is clearly a need for more homes. But where should they be built is a far more vexing question. If most people were honest, they would probably say that they don’t want anything build near to them, but we all know that is both impractical and more than likely quite selfish.
There are several red lines I would like to see protected. One of these is respecting and protecting the AONB that surrounds us here in the Sid Valley, and to do this would mean severely restricting and potentially refusing to allow building to take place in the AONB. This is not NIMBYism but a genuine wish to defend our attractive and essential environment.
Another is ensuring that there is no further coalescence of the green buffer zone that exists between Sidbury and Sidford, although the granting of planning permission in 2019 by a Planning Inspector, for the business park at the site on Two Bridges Road in Sidford has moved the boundary between these two parts of the Sid Valley unnecessarily closer. I would not want to see the boundary between Sidbury and Sidford to move any closer.
Any further local development has to be linked to better and additional infrastructure and whilst this is not something that is taken into account when assessing the appropriateness of sites, it is none the less critical. To build more and more residential properties as are necessary, will inevitably place greater stain on our existing infrastructure including schools, GP surgeries, public transport, highways, as well as our mains water and sewerage systems and our other utilities.
The infrastructure issues are beyond either the responsibility or probably the influence of the District Council but it, as it develops our Local Plan must highlight these and at some point, they will all need to be addressed. If they are not then all of them will move from creaking to failing.
The following sites are ones that I have taken a particular interest in locally and which I have submitted comments as part of the public consultation around the Local Plan.
Sidbury
Sidm_34: land between Furzehill and Hillside, Sidbury EX10 0QZ.
This site has the potential to be developed for around 38 homes. In the draft Local Plan this site has been designated, by Officers, as a Second-Choice site.
This site was previously put forward by the landowner but at that point its development was on a much-reduced footprint and for fewer properties. This site now straddles the three fields that sit between Furzehill and Hillside and is not a flat site. A significant concern about this site is its road access. Two of the site’s three fields could provide road access via both Furzehill and Ebdon Lane (by Hillside). However, both these access points would not be suitable for a housing development of the proposed size. I think that accessing the site from Ebdon Lane (at the Hillside end of the site) would be incredibly difficult as it is a very narrow single-track road. Subsequent access from Ebdon Lane onto the A375 could be difficult.
Devon County Council, as the local highways authority, have indicated that its preferred access to this site would be via Furzehill but that is again a narrow road, with residents’ vehicles parked on it. Additionally, allowing vehicles for anything up to 40 homes on the site to access it via Furzehill is probably not appropriate. It would also create a potential bottleneck at the War Memorial junction.
The Landowner’s stated preference is to have a road access off of Chapel Street on the A375. This is not only a potentially dangerous spot as anyone who drives along it can recognise. It is a pinch point and has poor lines of sight, this potentially dangerous. I cannot see how this could be suitable or safe.
The site sits within the AONB with parts of its with steep slopes and below adjacent to it is the Grade II listed Furzehill Farm and would have a detrimental impact upon it.
I do not support including this site in the Local Plan.
Sidm_25: Field bordering junction of Cotford Road and Roncombe Lane, Sidbury EX10 0QN.
This agricultural site has been submitted for residential purposes to accommodate just under 40 properties. In the draft Local Plan this site has been Rejected by Officers.
The site is situated within the AONB, with landscape visibility, on the edge of Sidbury village outside of its boundary settlement. Access to the site would be either from Roncombe Lane, which is a narrow lane or from the busy A375 at a point where joining it from the site would not be appropriate and potentially dangerous.
Some or all of the site is contained within Flood Zone 3 and there is high risk flooding along roads adjacent to the site and the development of this site could add to increased storm water runoff will exacerbate downstream flooding.
I do not support including this site in the Local Plan.
Sidm_11: Burnt Oak, Sidbury.
This site has already obtained planning permission. Although given the access to the site is on a blind junction on the busy A375 I am surprised that this alone did not lead to the site being rejected when previously considered.
Sidford
Sidm_08: Land at Two Bridges Road (designated employment site), Sidford.
This site is where the business park has already been granted planning permission. Since the draft Local Plan was published the site’s owners have put the site up for sale and in doing so, they have raised the possibility of this site obtaining change of use from employment land to either residential or a mixed use of employment and residential.
I have never been convinced that this site was suitable for use as employment land but that argument was lost in 2019 when a Planning Inspector determined it was suitable. As this is no longer agricultural land is a brown field site, I am in principle supportive of its future use being subject to change of use to either residential or a mixed use of employment and residential.
I hope that whoever owns this land going forward will approach the District Council for such a change of use.
Sidm_09: Land at Two Bridges Road (immediately north of the designated employment site), Sidford.
This site has previously been identified as a potential extension of the business park site next door; however, this site is not being pursued by the owners of the business park. In the draft Local Plan this site has been Rejected by Officers.
The development of this site would lead to the loss of agricultural land in the AONB. It would leave to the creeping coalescence of Sidbury and Sidford which is protected within the Sid Valley Neighbourhood Plan.
The use of this site for industrial purposes would add to the already congested roads through Sidbury and the School Street part of Sidford and this would impact negatively on these areas.
I do not support including this site in the Local Plan.
Sidm_06a: Land at Two Bridges Road (immediately west of the designated employment site), Sidford.
This site has been submitted for a potential development of around 30 homes. This site is linked to site Sidm_06b (below). This site has been designated Preferred by Officers.
The development of this site would lead to the loss of agricultural land in the AONB. It would leave to the creeping coalescence of Sidbury and Sidford which is protected within the Sid Valley Neighbourhood Plan.
The use of this site for industrial purposes would add to the already congested roads through Sidbury and the School Street part of Sidford and this would impact negatively on these areas. This site cannot be considered in isolation to the existing permitted development at site Sidm_09 and the cumulative negative impact that this additional site would have upon the local community, the road network and the local vista.
I do not support including this site in the Local Plan.
Sidm_06b: Land at Two Bridges Road (immediately west of the designated employment site), Sidford.
This site has been submitted for potential development of up to around 300 homes. This site is linked to site Sidm_06a (above). This site has been Rejected by Officers.
The development of this site would lead to the loss of agricultural land in the AONB. It would leave to the creeping coalescence of Sidbury and Sidford which is protected within the Sid Valley Neighbourhood Plan.
The use of this site for industrial purposes would add to the already congested roads through Sidbury and the School Street part of Sidford and this would impact negatively on these areas. This location would not be appropriate for permitted development that a site of this site could deliver. This site cannot be considered in isolation to the existing permitted development at site Sidm_09 and the cumulative negative impact that this additional site would have upon the local community, the road network and the local vista.
I do not support including this site in the Local Plan.
Sidm_12: Land adjoining Fortescue Road, Sidmouth.
This agricultural site of just under 5 hectares has been submitted for the residential development of around 50 homes. This site has been Rejected by Officers.
This site slopes from Fortescue Road towards the River Sid in the vicinity of the Byes which I believe is a restricted development area and the AONB forms part of this site’s boundary. Part of the site at least is within Flood Zone 3.
The site is located at the edge of Sidmouth and would encroach upon the boundary of Sidford.
I do not support including this site in the Local Plan.
Sidm_13: Land adjoining Fortescue Road, Sidmouth.
This agricultural site has been submitted for the development of just over 30 houses. This site has been Rejected by Officers.
The site is located at the edge of Sidmouth and would encroach upon the boundary of Sidford.
I do not support including this site in the Local Plan.
Sidm_14: Land adjacent to Stevens Cross Close, Sidford (east side), EX10 9Q.
This site is located adjacent to the A3052 at the edge of Sidford. This site has been Rejected by Officers.
This site is within the AONB and any development on this site would be highly visible.
I do not support including this site in the Local Plan.
Policy 36 – Coastal Change Management Areas
The coastal change management areas (CCMA) landward boundary is about 300 metres from the cliff that is parallel to Cliff Road, Sidmouth.
The CCMA landward boundary is the line to which the LPA estimate the cliff will recede in 100 years’ time however, the equivalent 100-year recession line in the Sidmouth Beach Management Plan (BMP) is about 50 metres from the cliff that is parallel to Cliff Road. There is a considerable difference in where the draft Local Plan and the BMP draw this boundary. There is a considerable difference between these two boundaries and if the Local Plan’s CCMA boundary is accepted over the BMP’s boundary this will have a significant impact upon properties located in the vicinity of the cliff.
Within the draft Local Plan this 20-year line represents the boundary of the land that the District Council “expect” will be lost to erosion in 20 years’ time.
I am unclear as to why or how the District Council can through the Local Plan and the BMP processes can identify two separate boundaries here. Given that the BMP is reaching a business case conclusion based upon the 50-metre boundary I would suggest that this is an already accepted boundary within the council and should therefore be applied within the Local Plan.
The draft Local Plan is proposing “There should be no new residential development including conversion of existing buildings within 300m of the cliff that is parallel to Cliff Road”.
I believe that is not a sound proposal for several reasons, including:
The mapping that is being used in this draft Policy is not the best available,
The policy is not flexible because there are uncertainties in the mapping and this policy does not take them into account,
The Policy does not cover the provision future coastal defence works, as being determined within the BMP business case that will change the areas at risk from erosion,
National planning guidance refers to “expected losses” (of land) in 20,50- and 100-years’ time. This draft Policy does not explain what level of exception has been adopted for the draft Local Plan and the justification for it,
It would also mean that any that property owners would not be allowed to upgrade or adapt their properties. This would have a negative impact upon property values and residents’ ability to sell their properties. The impact would not just be for property owners in Cliff Road but also the immediate surrounding area,
Apart from the planning implications, there is the question of the negative impact upon the properties in Cliff Road and the immediate surrounding area because the 100-year CCMA recession line is about 300 metres from the cliff, the 20 CCMA erosion line may well include the properties along Cliff Road. This could lead to the wider area including and beyond Cliff Road becoming a blighted area.