This application may appear on the face of it to be a Sidmouth issue.  However, the proposed loss of public open space and the implications for other major schemes waiting in the wings across the district should this application be approved, are significant. 

This is a unique application which has been submitted by EDDC and will be determined by EDDC.

I believe that it is in every EDDC councillor’s interest to carefully examine this application and the implications of its approval.

1. Planning policy
The Knowle and its parkland are not allocated for housing in EDDC’s adopted Local Plan.  It is designated as recreation land under policies RE1/RE4.

So this application is contrary to EDDC’s adopted Local Plan.

So if the application is contrary to policies both within the adopted Local Plan, what is the justification for the significant departure from policy?

Given the huge sums of money that EDDC has spent defending its adopted Local Plan against around half a dozen public inquiry appeals, it is baffling that councillors and officers would advocate seriously undermining the success they have had so far in defending the Local Plan, by submitting and approving a major application contrary to strategic planning policy.

I would point out the following dangers of this approach:

• If approved, it would be the first housing application approved under the new draft Local Plan policy, prior to the Examination in Public.  Given the myriad of major premature planning applications submitted in my ward alone – Ottery St Mary Rural – that have been refused on the grounds that they are contrary to the adopted Local Plan, developers across the district would have grounds to argue for approval of their own schemes.

• a huge amount of public money has been spent on defending appeals at public inquiry, several lasting for almost a week with teams of barristers and planning consultants.

• an approval of this application could mean that tens of thousands of pounds of public money has been wasted. 

• An approval would also mean that the planning inspector decisions, which so far, have supported EDDC’s position, will have been undermined, with significant implications for past and future decisions.

2. Justification
A major departure from strategic policy needs to be justified.  The justification supplied, which is that the Knowle is too expensive to refurbish so it is necessary to move, should not be used as a justification. 

The application is scheduled to be determined at the Development Management Committee meeting on 20 November. However, it is clearly not so urgent to move from the Knowle that a determination cannot wait until the draft Local Plan has been adopted next year. 

3. Employment land
The planning support information document states that employment land should not be protected long-term, according to the NPPF.  But in the adopted Local Plan the Knowle is allocated for recreation not employment.  Alexandria Industrial Estate is allocated for employment uses.

But this issue is an absolutely key issue for Sidmouth because by re-allocating Knowle for housing with the loss of over 300 jobs at Sidmouth the case for the highly unpopular proposed 12 acres of employment land at Sidford becomes implicitly stronger, despite that there being no evidence of its need according to independent evidence.

4. Public open space
The parkland associated with the Knowle is demonstrably special to the community, many of the trees are specimen trees, it has public access and for decades people have used the gardens for strolling through, walking their dogs and enjoying the beauty and peace. 

This council argues that it owns the building and parkland so therefore, has the right to sell it. 

But I would argue that it was taxpayers’ money that bought the Knowle and it is taxpayers’ money that maintains it.  Therefore taxpayers should decide what becomes of it. 

The taxpayers have spoken loudly and clearly.  They do not wish the parkland at Knowle to be built on.

Building on special public open space is another major departure from policy, given the current designation in the Local Plan of recreation and also the implications of other parks and gardens across the district.

5. Sale of the Knowle
It is impossible to divorce the issue of the sale of the Knowle from the issue of developing it.  Because this planning application is submitted solely as a result of a desire to move to Honiton to a brand new building.

I find it unacceptable that this application is being forced through at this stage, which (if approved) is bound to undermine the Local Plan at a critical stage, when there is a huge pressure from developers.

6. Conclusions
There must be solid grounds and evidence to approve a major departure from policy but there are no such grounds in this instance.

Even if there were solid grounds for approval, why is EDDC risking its adopted Local Plan with this application? 

Given that the application is already submitted I would urge that it is not brought forward for determination until after the Local Plan Examination in Public next spring. 

This approach would mitigate the risk this council is taking in undermining its own strategic planning policies.

If the application is brought forward earlier than this it should be refused to avoid undermining the adopted Local Plan.

The parkland is demonstrably special to the community.  It was bought, and is maintained, with taxpayer’s money.  Any approval to build over it is likely to weaken policies to protect open space across the district.