Following interest in the earlier post giving dates of the Public Consultation on Winslade Park, Owl will now post the draft comments from Gaeron Kayley, Chairman Save Clyst St Mary Residents’ Association for general interest.
As a group, we (Save Clyst St Mary) are not anti-development. We endeavour to transparently communicate with everyone in all parts of our village (together with the wider community) on major developmental proposals in this area, to enable them to make informed choices. We represent over 300 members of the community and our numbers continue to grow. We have successfully campaigned against inappropriate, unsustainable development in this area since 2013.
Comments on Winslade Park Development in Clyst St Mary
The major hurdle to overcome for any sizeable developmental proposals in this area is increased traffic. There is apprehension from local residents and the wider community that potential future traffic from this development will completely consume and overwhelm the capacity of the local highway network at peak times. To ensure future development does not detrimentally impact on universal accessibility to employment, retail and leisure for existing communities, visitors and commuters, guarantees to provide vital, substantial improvements to out-dated road networks and essential infrastructure must be established before or during the implementation of these major radical plans.
At present, a reduction in car-based transport in this area is restricted. There is inadequate access to bus services and no safe cycling routes via the A376 Exmouth road. The Digby and Topsham train services and the Sowton Park and Ride are also not easily accessible sustainably from the village. Therefore, it is highly likely that this proposed development will generate major increased use of cars and other vehicles. Reference to published 2011 National Statistics (the next Census figures should be published in 2021) show how people in Clyst Valley ward accessed employment; 74% drove with 5% travelling as passengers (so a total of 79% used cars or vans), only 4% used road based public transport (buses), 2% used rail, 4% cycled (2% used powered cycles) and 9% walked. Even with access to sustainable transport alternatives, it remains a fact that many people prefer the convenience of cars as a means of transport to access employment, retail and leisure. Unfortunately, public transport services can be expensive and frequently do not go where people want at the time they wish to travel.
Realistically, since these 2011 statistics, traffic has significantly increased in and around Clyst St Mary as a result of the cumulative impact of the expansion of commercial/employment (e.g. around Skypark, Hill Barton and Greendale) and new residential development. This is already having extensive, adverse effects, with traffic gridlock at peak times in Clyst St Mary on the A3052 and the A376 around the Clyst St Mary roundabout and Junction 30 of the M5 motorway.
This has lead to unacceptable and dangerous “vehicle rat-running” through existing residential areas in Clyst St Mary to avoid the congestion – so, obviously, increased vehicle use from this new major development will potentially intensify these problems.
It is questionable whether these proposals provide adequate on-site parking. Developers are only required to provide minimum car parking in their proposals to try to encourage non-car based transport. In practice this has lead to inconsiderate parking in nearby residential areas (exacerbated by commuter, rugby and holiday parking), causing many residents distress and creating dangerous highway safety issues throughout many village areas. In an effort to alleviate the serious traffic and parking issues in Clyst St Mary, the Parish Council has compiled a comprehensive traffic report for presentation to Devon County Highways.
From published evidence, (Hydrock’s Traffic Consultants’ Report in Application 16/2460/MOUT – page 2 para.1.2.3. – Document 2480191 dated 17/11/2016 on EDDC’s Planning website), it is stated that in recent years a total of 800 staff worked at Friends Provident and DEFRA and historically peak staffing figures for the entire site were around 1,500 staff. Consequently, the existing authorisation for traffic generation from 1,500 staff at Winslade Park cannot now act as permission for traffic generation from a potentially much larger workforce. In addition, there will be substantial traffic from the residential numbers, plus visitors, delivery vehicles etc to also be considered. A new rigorous traffic assessment and plan is vital to prove that the highway network can cope with such significant traffic increases.
Sustainable brownfield development and regeneration is supported. Theoretically, the concept of a ‘Wellness Community’ flourishing with living, employment and leisure provision in a stunning rural parkland environment is very appealing. However, these sizeable development proposals do seem disproportionate in a rural village location, making scaled-down proposals more appropriate for greater sustainability.
In planning terms sustainability is where economic, environmental and social aspects must be equally balanced to avoid one destroying the others. Focussing too heavily on economic growth, pressurising existing infrastructure (e.g. highways) and oversubscribed essential services (e.g. medical, health, educational and transport) can detrimentally impact on the wellbeing of existing smaller communities harming their social, cultural and environmental characteristics.
Government Planning Policy cautions against major new development in areas which are affected by flooding which could give rise to an increased flooding risk. However, these proposals have included commercial development (Zone B) beside the entrance drive and parking (Zone J) in two high risk flood zone areas. The Local Authority and the Environment Agency must ensure that future development will not increase the risk of flooding and a worsening of air and water quality and in an already fragile area.
Existing ground gradients, at present, cause problems with drainage flows and frequent gully overflowing, with recurring flooding at the bottom of Winslade Park Avenue and lower village areas, especially when the flood plains are at capacity. Development on the elevated green fields increases the overall flood risk to lower areas and results in impermeable surfaces escalating that threat. It is considered that the existing drainage systems in this area are inadequate and any sizeable, additional surface and foul drainage connections are likely to cause significant problems without major improvements to the existing drainage infrastructure.
The amalgamation of two strikingly different categories of land (namely previously developed brownfield sites and agricultural green fields) on very diverse locations in this village being merged into just one planning application will be a contentious issue. Local people may welcome the sustainable re-generation of the Winslade Park office complex brownfield site but will strongly oppose residential development on the green fields in Zone A (known locally as the Plymouth Brethren site) and there will only be one planning decision by EDDC of either approval or refusal for both brownfield and green-field areas.
Unquestionably, in planning terms the weight against the green-field proposals is very significant. Strategy 7 (Development in the Countryside) of the East Devon Local Development Plan 2013-2031 applies to these green fields. It states that the countryside is defined as all those parts of the plan area that are outside the Built-up Area Boundaries and outside of site specific allocations. Development in the countryside will only be permitted where it is in accordance with a specific Local or Neighbourhood Plan policy that explicitly permits such development and where it would not harm the distinctive landscape, amenity and environmental qualities within which it is located.
The green field areas of Zone A are not included in the current East Devon Local Development Plan to 2031 which was fully adopted on 28th January 2016 or the locally-prepared Made Bishops Clyst Neighbourhood Plan which was adopted in March 2017 and finally, this land has not been included within the up-to-date Built-Up Area Boundary (BUAB) for development in Clyst St Mary within the new Villages Plan (which forms part of the Local Development Plan to 2031) and was only adopted as recently as 26th July 2018.
The public perception is that planning policies contained in such labour-intensive, costly, legal planning documents continue to be relevant and remain workable in the relatively short term since their adoption to achieve best value. Communities presume that major planning policies adopted quite recently will not now be waived, altered or amended to favour sizeable development on green-field sites, especially when protection was specifically focused on the Plymouth Brethren green field (Zone A) by its deletion from the Local Development Plan to 2031. It is high-grade agricultural land, comprising primarily a Grade 3a best and most versatile agricultural classification. As long as records have existed, the green field areas in these proposals have been farmed by locals over many generations.
This Parish’s preference in the current, locally-prepared Neighbourhood Plan was to direct development in Clyst St Mary to the vacated Winslade Park office complex brownfield site. Although an allocation for up to 150 homes currently exists in East Devon’s Local Development Plan for the previously developed brownfield areas of this office complex, this 2016 allocation does not give carte blanche to divert major residential development to green fields – brown and green field sites are at opposite ends of the planning spectrum.
Re-use of the Winslade Park employment floor-space on the brownfield site, with refurbishment of the much-valued indoor sports and leisure facilities including fitness studios, swimming pool, the introduction of cafes, bars and a range of retail outlets and services, whilst protecting the stunning green parkland, outdoor sports pitches and tennis courts is supportable in principle. However, such sizeable employment proposals, plus the 67 new homes in Zones A and D, are not sustainable. Residential development being redirected to green fields is a price too high for many residents. National and Local Planning Policy states that protection should be afforded to green fields to preserve the landscape amenities and environmental qualities of the countryside. Clyst St Mary is NOT an urban environment. The emerging Agriculture Bill 2019-2020 is a radical re-think for land management to ensure protection of healthy soil, clean air and water, green infrastructure and wildlife whilst defending against flooding to deliver quality of life and environmental benefits for communities.
The green field proposals for residential development will have an overbearing impact on many existing properties in Winslade Park Avenue and Clyst Valley Road, creating overlooking, overshadowing and increased noise and disturbance, which represents an un-neighbourly form of development, detrimentally affecting the existing residents’ rights to the enjoyment of their dwellings and gardens. This green space creates a buffer between the existing built-up areas and the open countryside.
There will be widespread encroachment on the rural landscape amenity of the area, particularly with the highly elevated site being clearly visible from many local viewpoints. The loss of green fields, clean air, water, green infrastructure and wildlife is insupportable by many people in this rural community. Planning policies seek to protect and enhance the quality, character and amenity value of the countryside. A high level of protection should be given to valued landscapes, wildlife habitats and natural resources. These residential proposals are out of character with the existing green, open rural area.
East Devon’s adopted Local Plan to 2031 sets out a strategic approach ‘to protect and maintain the local amenity quality and character of local environments, to conserve and promote wise use of land and protect and enhance the landscape character of East Devon including the protection, enhancement and management of networks of biodiversity and green infrastructure’.
Gaeron Kayley – Chairman Save Clyst St Mary Residents’ Association
