Woodbury Salterton Residents Association

The Woodbury Salterton Residents Association Committee have read the documents
supplied by the applicant and agent and wish to comment regarding the following
planning application
16/2598/MFUL
Change of use of the site to storage yard including the erection of
temporary ancillary offices, fencing, SUDS and associated works
(Retrospective application)
Land at Greendale Business Park Woodbury Salterton EX5 1EW

The above plans shows the Proposed Employment Area for Greendale Business
Park, plus the application that was approved in 09/0410/MFUL highlighted in
green. Highlighted in red shows the outline of the location for the 16/2598/MFUL
development.
It shows that the application 16/2598/MFUL overlaps to the application
09/0410/MFUL referred to within the Design and Access Statement provided by
the Applicant, which they refer to constantly as a justification. However
approximately 50% of the development is outside previously permitted
employment designated land and therefore within open countryside or
designated landscaping land that were specifically located to shield the
employment area from the open countryside and residential properties.
It should also be noted that the 09/0410/MFUL application for an extension to
Greendale Business Park Employment Area in 2009 was an Exception to the
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Woodbury Salterton Residents Association

then East Devon current plan. (It was only agreed by the LPA as exception due
to an alleged shortage of employment land for 2009 only.)
Therefore the reference to business and employment opportunities were
relevant in 2009 but are not relevant in 2017 because there are appropriate
more suitable and sustainable employment land provided throughout the district
within the new approved East Devon Local Plan.

Taken from the Design and Access Statement

Woodbury Salterton Residents Association

The Design and Access Statement states that a planning decision should to be
based on the Local Plan unless material considerations indicate otherwise.

Taken from the Design and Access Statement

The EDDC Local Plan states under E7

E7 - Extensions to Existing Employment Sites:

Outside Built-up Area Boundaries and where it is clear that a business or
employment site or estate is at or near full occupancy the Council will permit
the small scale expansion of the site in a manner that is proportionate to the
existing size and scale of site operations provided the following criteria are
met in full:
1. The local highway network is capable of accommodating the forecast
increase in traffic established by a Traffic Assessment; or where these can
be mitigated either by physical works being undertaken by the applicant or
contributions are secured towards the cost of the works.
2. There will be no detrimental impact upon any nearby residential properties.
3. No protected landscapes or historic interests or other environmental
interests are adversely affected and the existing local biodiversity and
habitats are conserved or enhanced.
In association with any development encouragement will be given for on-site
renewable energy production.
In order to ensure that land is retained for the benefit of the local economy,
permitted development rights allowing changes to alternative uses will be
withdrawn.
This policy will not apply at Hill Barton and Greendale business Parks.
Therefore this application is not compliant to current planning policy and
therefore should not be approved.

Woodbury Salterton Residents Association

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Taken from the Design and Access Statement

The Design and Access Statement 5.6 states that a number of policies are of
particular relevance to the appeal proposals. (It should be noted that this is for a
planning application and not an appeal.)
However the Refusal Notice from the previous application for the same location
15/2592/MOUT also states that a number of these policies are relevant in relation
to refusing an industrial development at this location.

Woodbury Salterton Residents Association

Taken from the refusal notice for 15/2592/MOUT

The information provided by the developer and agent for the new application
still does not provide sufficient information to overcome the deficiencies of the
new proposal (which is virtually the same as 15/2592/MOUT)

Taken from the Design and Access Statement

The Design and Access statement states the Council is at an early stage with the
Village Plan, which would provide more weight to the already agreed status in
the East Devon Local Plan regarding Greendale and Hill Barton Business Parks
who are both excluded from expansion beyond their already designated
approved employment areas.
Policy E7 state that both Hill Barton and Greendale should not be expanded
further from their existing agreed boundaries as they are both considered
located in unsustainable locations.

Woodbury Salterton Residents Association

Taken from the Design and Access Statement

It is a pity that the landscaping proposals for the various applications in 2009
where not adhered to as a substantial area of this site was planted with young
trees, as shown by the following landscaping approved scheme in 2009 for the
planning application 09/1195/MOUT

Woodbury Salterton Residents Association

Taken from the Design and Access Statement

It is not surprising that there is no evidence of nesting birds and the site is
unsuitable for foraging bats dormice, badgers, reptiles and amphibians as the
survey was carried out after the development and all vegetation removed.
Taken from the Ecological Appraisal attached to this application 2.3 states
The site consists of around 1.122Ha of brownfield land that included
part of a former plantation woodland at the northern end of the
area. The whole area within which development is proposed is now
a brownfield site, with a very low ecological value
Taken from the Ecological Appraisal Addendum Report dated April 2016 1.6
states
There is a continuous and joined up line of four plantations of
broadleaved trees and shrubs to the east and north of the various
compounds in which industrial units are being, or will be,
constructed. It has been necessary to remove a small number of
trees from the western edge of the southernmost plantation, to
enable the construction of the attenuation pond
Following this report a Tree Preservation Order was implemented to protect the
remaining woodland from further destruction but it is understood further work has
been carried out following the serving of the Tree Order.

Woodbury Salterton Residents Association

Taken from the design and Access Statement

The proposed attenuation pond and discharge system are specifically related to
both the recent planning applications 16/2598/MFUL and 16/2597/FUL. Therefore
both these planning applications need to be considered together in relation to
Flood Risk and Foul Drainage. Failure to approve 16/2597/FUL will result in the
drainage strategy for this application to fail.
Taken from the Comments submitted by DCC Flood Risk Management Team
Section 3.2 of the Flood Risk Assessment and Drainage Strategy
(Report Ref. 4094, Rev. V04, and dated June 2016) states that
Compound 33A will be finished with rolled stone to enable the
surface water runoff to freely drain into the underlying strata.
However, the applicant has not submitted any information in order
to demonstrate that the geology in this location is conducive to
infiltration, and as such, this area must be treated as impermeable
when sizing the proposed surface water drainage management
system.
Furthermore, section 5.9 of the aforementioned document refers to a
climate change uplift value of 30%
for the proposed surface water drainage management system.
However, following the publication of the
Flood Risk Assessments: Climate Change Allowances document
(dated 19th February 2016) by central
government, the applicant will be required to use a climate change
uplift value of 40% when sizing the
proposed surface water drainage management system for this
development.
The applicant must also note that where infiltration is not used, long
term storage must be provided to store the additional volume of
runoff caused by any increases in impermeable area, which is in
addition to the attenuation storage required to address the
greenfield runoff rates. Long term storage should therefore be
included within the surface water drainage management plan to
ensure that each element is
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Woodbury Salterton Residents Association

appropriately sized, and this should discharge at a rate not
exceeding 2 litres/second/hectare.
The applicant must also submit information regarding the adoption
and maintenance of the proposed
surface water drainage management system in order to
demonstrate that all components will remain fully
operational throughout the lifetime of the development.
The Attenuation and flood prevention measures are specifically designed for
both applications and the consulted Flood Authority has identified a serious
miscalculation with the proposed drainage strategy.
Therefore the Application should be refused on possible Flood Risk, as the
outflow is proposed to enter the Grindle brook upstream of the Business Park.

Taken from the Design and Access Statement

As shown earlier the previous application 09/0410/MFUL was for a smaller area
and the landscaping to the site proposed in 2009 has now been substantially
removed and therefore the landscape is significantly different.

Taken from the design and Access Statement

All planning applications need to be considered on their own merits. Significant

changes have taken place with new planning regulations a new approved local
plan and the provision of substantial employment land at Cranbrook and the
West End of the district.
Conclusion
Due to the above reasons the Woodbury Salterton Residents Association cannot
support this retrospective application.
WSRA Chairman David Rose Hollywell Woodbury Salterton Exeter