The entire application has been scrutinised by the TARA Planning Sub-group over the last couple of weeks and subsequently this Objection has been submitted on the EDDC Planning portal:
21/0821/MFUL | Demolition of the existing Devoncourt building and outbuildings, construction of 81 no new residential apartments (25% affordable) and new 62 bed hotel with access via Maer Road car park, associated car parking and landscaping works |Devoncourt Hotel 16 Douglas Avenue Exmouth EX8 2EX
OBJECTION Submitted by The Avenues Residents Association (TARA), Exmouth.
- TARA, which represents over 200 members in the Avenues area, object to 21/0821/MFUL on grounds detailed below.
- We note that, despite making a pre-app enquiry of Planning West (Devoncourt Hotel 20/0006/preapp) and receiving a detailed response to Malcolm Gigg from Paul Golding, Senior Planning Officer, on 19th August 2020, ARA architecture have chosen to ignore the advice given.
- It is very disappointing to note that, despite telephone assurances that ARA welcome community consultation and would propose a date and venue, they have done nothing, contrary to Paragraphs 39 to 42 of the NPPF.
- Following our Basis for Objection, TARA submit ideas for the redevelopment of this site which we hope that the EDDC Planners and the EDDC Planning Committee will consider in line with the NPPF, Section 4 Decision Making, Paragraph 38 which advises that “local Planning Authorities should approach proposed developments in a positive and creative way”.
BASIS OF OBJECTION:
Change of use / financial viability assessment
EDLP Section 24 Employment, Economic Development, Retail & Tourism Policies E17 (Principal holiday accommodation areas) and E18 (Loss of holiday accommodation).
ExNP Policy EE1: Tourism.
1. The basis upon which the developer is seeking to gain approval for change of use makes use of data and analysis which was written in 2015 (DAS Appendix 1, Document 1). The developer therefore has not demonstrated that the current business is unviable (see the conclusions of the independent review of the FVA in the same Appendix) as its assumptions on the property market are out of date, particularly given the significant increase in staycations in the UK since COVID-19.
2. The criteria set out in Policy E17 have not been met as the company’s annual financial returns posted at Companies House show that the hotel, year-on-year, is viable. The report commissioned by EDDC planning from DVS (DAS Appendix 1, Document 2) concludes that it has not been demonstrated that the hotel in unviable and indeed with the correct management team in place and investment, poorly lacking for decades, the hotel could thrive as do others in Exmouth and around Devon.
3. The requirement of policy E18, offering the business for sale at a reasonable price for 24 months has also not been met. In the company’s own financial reports the buildings and business are valued year after year and, as of 31st December 2020, were valued at £2.3m. However, the business is for sale at £8m which is vastly inflated, unreasonable and aspirational as this figure is based on winning approval for planning and development to 81 apartments, not on the actual value of the business and its assets. This business has not sold to a quality hotel group because the price is aimed at a housing developer and not at tourism and hospitality.
Broad environmental considerations
East Devon Local Plan (EDLP) Strategy 3 Sustainable development EDLP Section 17 Climate Change & Renewable Energy (requires consideration of climate and renewable energy).
ExNP Policy GA1
1. This development plans to destroy an area of green space and mature trees rather than promoting carbon capture. Despite having large grounds suitable for ground-source heat pumps and a location suitable for solar panels, there is no reference in the proposal to renewable energy of any kind. Also, there does not seem to be any provision for renewable rainwater collection and re-use or for electric charging points for vehicles.
2. The proposal acknowledges that the primary source of heating for the apartments at least will be gas boilers. This does not recognise that this mode of energy will be banned within 4 years: “The government has announced that by 2025, all new homes will be banned from installing gas and oil boilers and will instead be heated by low-carbon alternatives. The ban is part of a UK action plan to reach carbon net zero by 2050”. The proposal neither acknowledges this nor does it suggest any suitable alternative.
Over-development of the site/general design considerations
EDLP Strategy 48: Local Distinctiveness in the Built Environment
EDLP Section 21 Design Standards Policy D1 (Design & local distinctiveness) references scale, massing, density, build line, height, privacy, overlooking, daylight in new developments.
Exmouth Neighbourhood Plan (ExNP) Policy EE1: Tourism.
The Avenues Design Statement 2017 (ADS) Recommendations 3 (replacement buildings); 4 (building lines and separation distances); 5 & 6 (maintaining a balance between the ratio of new build and green space)
1. Although the site deserves a quality hotel with leisure facilities, the replacement of a 54 bedroom resort/hotel with a 62 bedroom hotel and 81 apartments is a blatant overdevelopment of the site, as shown by the Officer’s report in 20/2362/FUL. It will result in similar site coverage of ca. 60% but contain buildings that are more than twice the height. This will negatively impact on the surrounding area. It is not in keeping with the prevailing style of the neighbourhood and the character of The Avenues and does not follow the ADS in relation to density, size and height, and sympathy with the surrounding area.
2. It was stated by Richard Boyd, Planning Officer for the West Planning Team when offering pre-application advice in 2015 (ref applicant’s “Document 1: Comment on Pre-Application of 2015. File note”) that “the assumption is that as long as a broken form of design is used at the top of the site this can go to four storeys, progressively stepping down to two storeys as you go down through the site. Good form of design, layout and broken development would be required throughout the site.”
The plans submitted do not meet these criteria. The north block is up to 5 storeys high including the apex roof line and excavated parking to the rear. The lower block and hotel are also 4 and 5 storeys high with the apex so the proposed development does not step down to 2 storeys as you go down through the site. The design is not of “broken form” but is essentially one long block of apartments and hotel building. Moreover, the proposed hotel would look more like a motel with a view of the car park.
3. A key component of the proposal is the use of land immediately to the south of the site of the existing hotel for vehicular access to and parking to serve the proposed hotel. If the developers lease car parking facilities for the hotel from the Council they will be depriving the public of a well used facility and making it more difficult for tourists to find parking close to the beach. This is contrary to tourism policies and is further exacerbated by the staycation boom. The car park is also used as a turning point for the land train and is needed for future access to the adjoining redeveloped sports field.
Parking, traffic & highway safety
EDLP Section 26 Transportation Policies TC6 (Park & ride and park & share/change); TC7 (Adequacy
of road network & site access) and TC9 (Parking provision in new development)
1. The Maer Road car park currently serves the Land Train which effectively acts as a park and ride for Exmouth and reduces the traffic along the seafront. Reduction in capacity to benefit the proposed development will reduce the capacity for the park and ride, will reduce parking for tourism and force cars onto the surrounding neighbourhood side streets and seafront and will negatively impact other businesses for the benefit of the developer.
2. Douglas Avenue is a busy road, and the free on-street parking outside the Devoncourt is popular with beach-goers who do not want to use the car parks. Traffic flow is often reduced to one-way and there are frequent tailbacks in both directions. The diagrams for entrance and exit turns show an empty two-lane road, when, in reality, parked cars narrow the road and obstruct views of oncoming traffic. The increased number of car trips calculated in the plan entering/exiting the site will exacerbate existing traffic problems on this section of Douglas Avenue. The report by Advance Consulting Engineers Ltd in March 2021 estimates that traffic flow during Peak Hours (0800-0900 & 1700-1800) measured as combined trips will increase from ca. 36 to ca. 92 – an increase of 156%. It should be noted that the report makes no allowance at all for commercial deliveries to the apartments yet home deliveries are a well known area of growth in the retail economy and one which has expanded significantly due to Covid-19. NB On-street parking outside the Devoncourt also has the positive benefit of slowing traffic down as it approaches the junction of Douglas Avenue/Maer Road especially traffic travelling downhill from the east.
3. The proposed 81 residential dwellings will access the development by a single point onto Douglas Ave at a very busy and dangerous point on the road. This will result in a considerable increase in traffic travelling past the Academy for the Deaf and via the Douglas Ave / Maer Road junction, adding to that generated from the new sports fields and the proposed new dwellings on the site of the former Rolle College playing fields, on the site adjacent to the Academy as well as from Plumb Park which is still under construction.
4. The Transport Statement provided, whilst having some helpful information, also disingenuously argues that by using part of EDDC’s Maer Road Car Park for the proposed hotel that the estimated volume of traffic using the hotel would not impact Douglas Avenue. This is clearly wrong as arriving traffic is directed to Maer Road from Douglas Avenue and departing traffic from Maer Road is directed to Douglas Avenue.
5. The Transport Statement makes no allowance at all for the volume of delivery traffic that would need to access the proposed apartments. Covid-19 has brought about a major and possibly permanent change in where people work and how they shop. The explosion in online shopping has fuelled a secondary explosion in home deliveries: none of this is allowed for in the Statement or the proposal.
6. TARA believes that the scale of this proposed development, which clearly is classed as “Major”, should require a full Transport Assessment rather than a mere Statement, as per the Government website.
7. Additional pedestrian traffic will be generated from the 62 bedroom hotel onto Maer Road and heading predominantly to Maer common and Exmouth beach. There should be provision for a marked pedestrian crossing on to Maer Road and on to the seafront.
8. In accordance with current research into the mental and physical effects of traffic noise and pollution, the additional volumes of traffic that will be generated will worsen both. A recent public consultation by TARA (June-July 2021) into the local living environment resulted in over 350 responses. Well over 70% of respondees complained about existing levels of traffic and the resultant noise and pollution from exhausts along Douglas Avenue. The WHO recognises that “safe” levels of Nitrogen Dioxide resulting from traffic need to be revised
significantly downwards. Recent research published in the International Journal of Environmental Research and Public Health shows that traffic noise has a negative impact upon mental health with effects upon depression, anxiety, cognitive decline, and dementia.
9. On the basis of 8. Above, it might be questioned whether permitting such a large scale development that will generate huge volumes of noise, pollution, and traffic during demolition and construction, and which will then be followed with on-going and substantially higher levels of noise & traffic pollution contravenes the human rights of the local community.
Effects on amenity (neighbours and community)
EDLP Section 21 Design Standards policy D1 (Design & local distinctiveness) references scale,
massing, density, build line, height, privacy, overlooking, daylight in new developments.
1. The west section of both the north and south blocks directly overlook living rooms, bedrooms and dining rooms of all of the adjacent properties. Further, all mature trees which would offer some screening are to be removed from this area. From all levels and viewpoints this will directly and negatively impact those households. They would be overlooked giving loss of privacy by the excessive height of the proposed buildings. With the proposed apartments having balconies and outdoor space there would also be a negative impact of noise outdoor at high level and overlooking into directly adjacent private spaces.
2. ARA were responsible for the design of the Ocean Quest apartments on Douglas Avenue. A visit to the garden of The Coach House, Kingsdon Hall will provide a salutary example of the impacts upon neighbours of poor placement of new buildings on a site.
Loss of existing health facilities
ExNP policy CF1 (Health & well-being facilities)
1. This policy states that “…Any development proposal which leads to a reduction in current health and wellbeing facilities will not be supported unless mitigated by improved or increased capacity for the delivery of health and wellbeing services through the development proposal.” The proposal will result in the loss of the gym, spa, indoor and outdoor swimming pools and tennis court at the Devoncourt Hotel, all of which are open to and used by the general public, which would not be replaced under the proposal. These biodiverse gardens will be lost to tarmacadam and concrete.
2. The illuminated grounds of the Devoncourt at Christmas are an Exmouth institution and this, too, would be lost to the public.
EDLP Strategy 34 District Wide Affordable Provision Targets
1. This proposal should be providing 25% on-site affordable housing. Based on the 81 residential apartments this equates to 20.25 units for affordable housing with 70% for rent (14 units) and 30% (6 units) for an affordable route into home ownership such as shared ownership. The 0.25 would result in a commuted sum of £11,559.
2. It is noted that an EDDC response to a pre-application enquiry by the developers estimates the number of units at only 15 (10 rental, 5 affordable purchase). The basis for this calculation is not known.
3. The same EDDC communication states that the 25% provision should be both on site and in separate blocks to the private apartments as experience shows that combining affordable and private accommodation within the same building is unsatisfactory.
4. There is insufficient detail provided with this application on the provision of affordable housing. The Heads of Terms states that 25% on-site affordable housing will be agreed with EDDC. There is no affordable housing statement or plan which identifies the proposed affordable units.
5. Based upon previous experience it is felt to be highly likely that, as soon as development commences the affordable housing units on site will be found to be economically unviable and the developer will seek to renege on the Heads of Terms. Under no circumstances should EDDC permit this to happen as there is a dearth of such housing in the Exmouth area.
Statement of Community Involvement
1. The applicants’ own submission simply states that “Further to liaising with the owners and developers of the site, we have been advised that they will be happy to meet with the Community to discuss the proposed new development. The feedback from the community can, if possible, be incorporated into the proposals to ensure the application takes on board the comments and items raised.” ie there has been no community involvement prior to the submission of the application.
2. TARA contacted ARA on September 23rd to discuss this and to request a public meeting. ARA said that “they welcomed public consultation and that a response suggesting a time and a date for such a meeting would be given to TARA by September 30th. No such response has been received and it appears as though ARA are deliberately ignoring public consultation.
ALTERNATIVE APPROACH TO RE-DEVELOPING THE SITE:
- TARA recognises the need for, and support, the provision of high quality hotel accommodation on this site that will contribute to making Exmouth a year-round destination. This is as suggested in the Exmouth Masterplan but so far failed by the construction only of the Premier Inn budget hotel. Another budget hotel is not what is needed.
- The site has an excellent position on the edge of the Maer Local Nature Reserve, the Heritage Coast, and the East Devon AONB. A new hotel, built on the existing site and retaining the views over the area, the sea and the South Devon coast, and which provided Eco-friendly access and offered Wellness facilities within the building and the extensive and biodiverse grounds, would be seen as a major asset to both the town and the local community.
- Such a proposal would result in a lower environmental impact during re-development and on-going operation of the hotel and would recognise the Climate Emergency through use of alternative energy sources, provision of e-charging points for all vehicles, and rainwater harvesting.
- As suggested by Paul Golding in his pre-app response of 19th August 2020, a hotel could be designed – see final bullet point below – in a manner sympathetic both to the character of the Avenues and also to the immediate neighbours. Neighbours would be impacted to a much lesser extent if the hotel stepped down towards the rear and followed the natural decline of the grounds.
- The type of modern tourist hotel that should be considered could be modelled on the Saunton Sands Hotel, owned by Brend Hotels. This hotel has been extensively re-modelled and offers a mixture of single, double, and family rooms plus some holiday apartments. It offers Wellness facilities but has also linked with local watersports businesses so that hotel guests can make use of their facilities and equipment and receive coaching. The top floor of the hotel is given over to guests so that they can relax after treatments and other activities: it offers extensive views of the coast.
TARA, October 7th, 2021