THE SOUTH HAMS SOCIETY - Planning applications

Stokenham - Field at SX783424, south east of Mill Farm, Frogmore - retrospective application for mobile field shelter, hardstanding and new hedging (SHDC application 53/0038/12/F)

The Society wrote as follows to SHDC on 31/1/12:

The South Hams Society has considered this application carefully and has visited the site. It objects to the field shelter and to the hardstanding on the grounds of the harm that would be caused to the landscape of the South Devon AONB, in contravention of adopted policies.

It is not clear from the application whether approval has already been given to change of use of the field from agricultural to equestrian. If not it presumably must be sought, and the Society would object to that on the same grounds.

County Structure Policy CO3 reads: In designated Areas of Outstanding Natural Beauty, the conservation and enhancement of their natural beauty will be given priority over other considerations. Within these areas, development will only be provided for where it would support their conservation or enhancement or would foster their social and economic well-being provided that such development is compatible with their conservation. Particular care will also be taken to ensure that any development proposed adjacent to such areas does not damage their natural beauty.

This development would not support the conservation or enhancement of the AONB. Nor would it foster its social or economic well-being. No such claim is even made.

Having read the design and access statement, we suspect that the policies which oppose this sort of development may not have been explained to the applicant. The problem is much less to do with the close views of the site (from the lane for instance) than with the long views of the landscape into and within the AONB. From the houses in the west end of Chillington and at Oddicombe, from gateways in the lane running south from Sherford Cross and from various points on the A379 the land at and adjoining the application site clearly looks unnatural, at odds with the rural landscape, and unattractive. The attached photograph, which shows both the application site and the adjoining one, and was taken from the A379, shows this. This is not a problem that could possibly be overcome with landscaping conditions.

Furthermore, CO3 makes no distinction between what can and what cannot be seen from public viewpoints. This is understandable: we can have no idea what land north of the A379 will be open to the public in even twenty years' time, let alone for the infinite period for which the AONB is intended. If the protection is to be meaningful it has to apply to the totality.

It is not the applicant's fault that, here and at other places south of Chillington, so much of the landscape has already been damaged by change to equestrian use that each new instance attracts particular attention. That, however, is no reason for allowing such change to continue.

Adopted LDF Core Strategy Policy CS9 echoes CO3. Other policies which appear to apply are County Structure Policy CO1 – the proposals are not sympathetic to Devon's landscape character and quality; and Local Plan Policy SHDC3 – the proposals do not fall into any of the categories for development permitted in the countryside.

DP2 opposes unsympathetic intrusion into the wider landscape.

DP15 and DP18 would appear to oppose the proposed change out of agriculture and the erection of the buildings. These proposals would not support the essential needs of agriculture (rather the reverse) or of the local community. They would not make use of existing buildings, be well related to an existing farmstead or group of buildings , or be complementary to any agricultural operations.

Adopted policies are overwhelmingly against this application. The Society asks the council to refuse it and to require the reinstatement of the land to agricultural use.

Yours faithfully,

John Graham
Secretary

Copied to: Stokenham Parish Council

Robin Toogood, South Devon AONB Manager

Malborough - Field at SX726398, north of A381 Malborough to Salcombe road (SHDC application 33/3087/11/F)

The Society wrote as follows to SHDC on 15/1/12:

We are sorry that we have once again to point out that this development, already refused under application 33/1313/11 and the subject of two applications before that, is entirely unsuitable for its location. In doing so, we make no apology for reminding the council of matters that have come up in the predecessor applications.

Policies

In refusing application 1313/11 the council gave as Reason 1 that the building, due to its prominent location, size, roof materials and associated earthworks, was considered to have a detrimental impact on the character and appearance of the AONB, the Coastal Preservation Area and countryside as a whole. It was therefore contrary to county structure plan policies C01, C03 and C05 and to SHDC policies CS9, DP1, DP2 and DP15.

Luscombe Maye's agricultural appraisal addresses Policies CS9, DP2 and DP15. It also harks back to the original agricultural determination under 0246/10. It quotes some of the provisions of CS9 and DP2 but provides no arguments or evidence that the proposal conforms with either. In fact, the building is there for all to see and it is very clear to any onlooker that it is in serious conflict with both policies.

The appraisal claims that DP15 "allows for development in the countryside that supports agricultural interests". The actual wording is "meets the essential needs of agriculture". Even if it is accepted that the use of the field is the growing of hay, it is clear that the hay is for equine consumption (Mr Roberts' submission of 22 June 2011) and we question whether that comes under any of the categories defined as agriculture in Section 336 of the Town and Country Planning Act 1990. And even if it were accepted that it does, the appraisal offers no evidence that there is an essential need for a building in that field - this is apparently only one of the fields that the applicant uses and the hay and the machinery could be stored anywhere, including an industrial estate. The argument for a need that is so essential that the AONB should be violated is very weak indeed.

If the agricultural determination of 2010 is a factor in the council's decision we ask that it give a full account of 0246/10.

County structure plan policies C01, C03 and C05 and SHDC policy DP1 are not mentioned in the appraisal. We believe that they are just as opposed to this application as they were to 1313/11.

Appearance

At the time of writing the council's website shows no submissions from the AONB Unit or the council's landscape officer in respect of the current application - no doubt they will be published before any decision is made. Their comments on the predecessor applications are however on record:

a. The AONB unit objected to 1313/11 - "The barn occupies a prominent open site where it is conspicuous from the roadside layby above and from the minor roads opposite. Because of its isolated position away from any existing farmstead or feature it appears incongruous in the wider landscape....The size of the structure and the associated earthworks make a prominent scar on the the hillside." There is also adverse comment on the new stone track which was not covered in that application or the current one.

b. The council's landscape officer objected to application 0323/11 - "The building bears no relationship to any existing farmstead, road pattern or building pattern in the area and sits intrusively on the middle to upper slopes. It draws the eye from a number of directions from the Estuary and the roads north and paths within the vicinity and is in an inappropriate and visually intrusive location".

We see nothing in the new application that makes the appearance of the building any more acceptable than the one refused under 1313/11. The plans are the same. Tree planting is mentioned but it is not clear how it would make the building more acceptable. Even if the planting were to be completely successful it would not conceal the fibre cement roof, the land form would have been changed and the site would not look like cultivated land. The actual appearance of the building from the surrounding lanes is very much worse than the photograph submitted with the application suggests.

The use of the land

In their agricultural appraisal Luscombe Maye say that the applicants purchased the land in 2009 "with the intention of establishing a hay/haylage business". Two years later, in June 2011, Mr Derek Roberts, who we understand is employed by SHDC as a consultant on agricultural operations, visited the site and spoke to the applicants in relation to application 1313/11. He reported that "The land is used for the keeping of four horses which Mr Favis and Ms Freeman own. These are two riding horses, one retired horse and one youngster which is being brought on for riding. The horses are kept only for pleasure purposes and Ms Freeman competes in showjumping." He goes on to say that hay and haylage from this and other pieces of land are cut and sold, but he makes it clear that the primary use of the land is for keeping horses. He expressed the view that the size of the building was not justified by operations that were genuinely agricultural.

In October 2011, following a site meeting at which Luscombe Maye stated that the applicants' intention was to produce hay rather than keep horses, he reported again. Writing with reference to application 1313/11, though that had long since been decided, he largely withdrew the views he had expressed only four months earlier, though he still had doubts about the size of the building. One is bound to ask how Mr Roberts, as a professional consultant, had so misunderstood the operation that he was retained by the council to assess. If the council wishes to approve the current application we believe it should first conduct its own inquiries into the nature and viability of the applicants' hay-making business. They should include an examination of the applicants' accounts and business plan.

Earlier in 2011 the council's landscape officer, reporting for application 0323/11, wrote that "it is very clear on site that this is not being used for agricultural purposes and is being used solely for horse related uses".

On 10 January this year there were still horse jumps in the field.

Conclusion

While the Society has every sympathy with the applicants, who have undoubtedly been misled on the planning laws, it strongly objects to this application. It is taking the case seriously because it is becoming very concerned about piecemeal overbuilding of the AONB. These repeated attempts to get round the rules, including a change to a different agent, risk making a mockery of the adopted planning policies.

We ask that the application be refused and that the notice issued with the decision on 1313/11 be enforced.

Yours faithfully,

John Graham
Secretary
The Church House
Woodleigh TQ7 4DG

Brixham - Hillhead Farm, Hillhead - Installation of 11kw wind turbine on 15m mast (20m tall to tip of blade) (SHDC application 10/2824/F)

The Society e-mailed SHDC as follows on 5/1/12:

The documentation on the web site for this application in the AONB is inadequate.

The Visual Impact Statement was not supplied with the original application and added by request of the planning officer. It now contains photographs which were taken under lighting conditions such that the impact of the turbine cannot be adequately judged. This should be remedied before any decision is made.

There is a lack of information about other issues on the web site as well:

the 'summary of acoustic measurements' title page appears to originate from another report of an installation in Galway, Ireland,
the report jumps to page 6 after the title page,
the acoustic report mentioned in page 6 of the document is not present,
the wind speed data is acoustic data, etc.

It is difficult to judge whether the documents supplied with the application are inadequate or if the loading of the application documents to the website has not been done correctly.

Perhaps the Christmas spirit has intervened with the website operation.

This application should not have been registered without an adequate Visual Impact Statement and the Society believes it should be refused in its present state.

John Chalmers
South Hams Society
9 Croft Road
SalcombeTQ8 8DZ

Salcombe - Puffins, Fortescue Road - Resubmission of householder application 41/2216/11/F for alterations and extension to dwelling (SHDC application 41/3233/11/F)

The Society e-mailed SHDC as follows on 5/1/12:

There are no drawings for this application apart from the Site Allocation Plan although they are referred to in the Design and Access Statement.

John Chalmers
South Hams Society
9 Croft Road
SalcombeTQ8 8DZ

Stokenham - Golden Meadow, Widewell - Householder application for alterations and extension to dwelling (SHDC application 53/3245/11/F)

The Society e-mailed SHDC as follows on 5/1/12:

There are no adequate drawings for this application which involves substantial extensions and alterations for a house within the AONB and Undeveloped Coast. Those at the end of the Design and Access Statement are too small to be useful and do not show the changes over the existing house.

The Society believes that although these proposals are derived from an earlier application to rebuild there still is a requirement for comprehensive drawings for the current application which should not have been registered without them.

John Chalmers
South Hams Society
9 Croft Road
SalcombeTQ8 8DZ

Malborough - Seaways, Malborough, Kingsbridge, TQ7 3DN - Householder application for alterations to external elements and minor alterations to internal layout (SHDC application 33/3258/11/F)

The Society e-mailed SHDC as follows on 5/1/12:

This application 'seeks to change the external appearance of the property' and to make 'alterations to the fenestration' but provides no drawings to show what is intended.

The Society believes that these are required before registration and a decision can be made.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

North Huish - Newpark Stables-retrospective application for the change of use of land to equestrian use and the erection of stable,quad bikeandstoragebuildings (SHDC application 38/2989/11/CU)

The Society wrote as follows to SHDC on 4/1/12:

The South Hams Society has considered this application carefully and has visited the site. (The application gives a grid reference of 271404 56737. We would place it near 271800 56200.) It objects to the existing buildings, the proposed buildings and the change of use, on the grounds of the harm that would be caused to the landscape of the South Devon AONB, in contravention of adopted policies.

These developments would not support the conservation or enhancement of the AONB. Nor would they foster its social or economic well-being. In fact no such claim is even made.

It is implied in the last paragraph of the Design and Access Statement that the development would be relatively out of sight. CO3 makes no distinction between what can and what cannot be seen from public viewpoints. This is understandable: we can have no idea what land will be open to the public in even twenty years' time, let alone for the infinite period for which the AONB is intended. If the protection is to be meaningful it has to apply to the totality and we should as far as possible avoid making exceptions, not least because they inevitably create precedents.

In fact the site is high on a forward slope and is very widely visible, particularly from Diptford and the hills behind it. The land in this part of the AONB is very attractive and remains relatively unspoiled, with open fields and very few buildings. The stables, railings and hard-standing already on the site are at odds with the hedges and pasture fields which fill most long views into the AONB. This is not a problem that could be overcome with landscaping conditions.

Adopted LDF Core Strategy Policy CS9 echoes CO3. Other policies which appear to apply are County Structure Policy CO1 - the proposals are not sympathetic to Devon's landscape character and quality; and Local Plan Policy SHDC3 - the proposals do not fall into any of the categories for development permitted in the countryside

DP2 opposes unsympathetic intrusion into the wider landscape.

The parish council's concern that the stables might be used for commercial purposes seems very reasonable.

Adopted policies are overwhelmingly against this application. The Society asks the council to refuse it and to require the reinstatement of the land to agricultural use.

Yours faithfully,

John Graham
Secretary
The Church House
Woodleigh TQ7 4DG

Chivelstone - Chivelstone Barton, Chivelstone, Kingsbridge, TQ7 2LY Installation of 15kw wind turbine on 20m mast with 6m blades (SHDC application 10/2824/11/F)

The Society e-mailed the following representation on 7/12/11:

The South Hams Society has considered this application carefully and is familiar with the site. The Society has weighed the benefits and costs both public and private, to the farming community and the public at large. It is very aware that over the ages it is farming that has created the South Hams landscape and that in addition to the subsidies provided, farming must continue to be a viable activity. Farming methods change and this must also be taken into account. However the Society has come to conclusion that in this case the costs to the environment outweigh the benefits.

In arriving at this conclusion the Society has determined that there are significant defects in the documents presented with the application. In particular the benefits of the turbine are grossly over estimated and the damage to the environment and the setting of the Church of St Sylvester greatly under estimated. The details of these distortions are given below.

The application claims unrealistic load factors for the turbine - 64% of the nominal capacity. In general wind turbine load factors are between 20% and 30% and in this setting with wind speeds of only 7 metres a second the likelehood is that the load factor will be in the low 20s. The benefits to the applicant and the saving of carbon emissions are therefore about one third of that claimed.

The Design and Access statement contains a rudimentary Landscape and Visual Impact Assessment carried out by the turbine contractor with 6 photomontages of the turbine at various points around it. These display considerable inconsistencies. Photomontage No. 6 from Chivelstone near the Church of St. Sylvester shows the mast as being smaller and less dominant than that from Wilton, position 4, which is 2.5 times further away, and from position 5, Chivelstone Cross, which is 1.5 times further away. The actual effect at Chivelstone must be nearer to photomontage 1 taken beside the access lane to the barn which is only slightly nearer. The application therefore minimise the impact on St Sylvester's church. An accurate visual assessment must be a requirement for such a prominent development in the AONB.

These defects are sufficiently marked for the Society to consider that this application should be rejected on these grounds alone.

If however the application is to be considered the Society objects on the following grounds.

1. A number of smaller 5 kWh turbines have been approved in the South Devon AONB. Because of their small size they are often hidden by mature trees. This turbine is considerably larger tall - 26 metres to the tip of the blades - and sited on a prominent plateau bare of trees above the 100 metre contour. It is in the AONB and Undeveloped Coast and can be seen from many viewpoints both at short and long distances. It could not be more visible and have a more damaging impact on the protected landscape.

The application therefore contravenes to very significant extent policies designed to protect the landscape including Devon Structure Plan Policies CO3 and CO5 protecting the AONB and coastal development and South Hams District Council Policy CS9 in the Core Strategy and Policy DP2 in the Development Policies DPD.

2. The application contravenes Policy CS 9 also by damaging the setting of St Sylvester's a Grade 2* building.

3. The turbine is sited in a sensitive area for birds as shown in the RSPB report 'Mapped and written guidance in relation to birds and onshore wind energy development in England', 2009s.

4. There is considerable local opposition - 54 letters objecting as against 16 supporting it.

There are other issues which while not strictly being material planning issues have been considered by the Society.

5. If approved, this application would set an example which would be used as an argument for many further applications which the District Council would find hard to resist. The whole of the South Hams could rapidly become covered in turbines thus effectively comprehensively damaging the whole countryside including the AONB, the Undeveloped Coast and Areas of Great Landscape Value.

5. There is no evidence that the applicant has considered other methods of generating renewable energy which have less impact on the landscape some of which are highly suitable for use on farms such as Biomass and Anaerobic Digestion.

6. There is no comment on this application by the AONB Unit despite it being of great significance to the future of the area because of the example it creates for further development.

The Society urges the District Council to reject this planning application

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

Galmpton- Field at SX 693 399, Burton Farm, Galmpton, Kingsbridge, TQ7 3EY - Erection of 2no. 11 kw wind turbines on free standing 18m masts (SHDC application 46/2662/11/F)

The Society e-mailed the following representation on 17/11/11:

The South Hams Society has considered this application carefully and is familiar with the site. The Society has weighed the benefits and costs both public and private, to the farming community and the public at large. It is very aware that over the ages it is farming that has created the South Hams landscape and farming must be a viable activity in addition to the subsidies provided. Farming methods change and this must be taken into account. However the Society has come to conclusion that in this case the costs to the environment outweigh the benefits.

The Society therefore objects to this application on the following grounds.

1. The turbines are sited on a very prominent position above the 100 metre contour in the AONB and Undeveloped Coast and can be seen from many viewpoints both at short and long distances. As they are positioned to take full advantage of the wind they could not be more visible and have a more damaging impact on the protected landscape. In addition one footpath runs over the site, another footpath and a public access route run adjacent to the site and it would be impossible to use any of these these without being aware of the considerable and damaging visual impact and the noise of the turbines.

The application therefore contravenes to very significant extent policies designed to protect the landscape including Devon Structure Plan Policies CO3 and CO5 protecting the AONB and coastal development and South Hams District Council Policy CS9 in the Core Strategy and Policy DP2 in the Development Policies DPD.

2. Despite the considerations above the application's Landscape and Visual Impact Assessment comes to the extraordinary conclusion that there is no significant landscape or visual effect even on the footpath crossing the site. The Assessment has been carried out by the turbine contractor and cannot be considered as impartial. This application needs an Environmental Impact Statement carried out as required by the Department of Communities and Local Government.

3. The load factors claimed for the turbines are very high - 44%. In general wind turbine load factors are between 20% and 30% and there is no reasoning put forward in the application to support the higher figure. The benefits to the applicant and climate change are there grossly overstated.

There are other issues which while not strictly being material planning issues have been considered by the Society.

4. If approved, this application would set an example which would be used as an argument for many further applications which the District Council would find hard to resist. The whole of the South Hams could rapidly become covered in turbines thus effectively comprehensively damaging the whole countryside including the AONB, the Undeveloped Coast and Areas of Great Landscape Value.

5. There is no evidence that the applicant has considered other methods of generating renewable energy which have less impact on the landscape some of which are highly suitable for use on farms such as Biomass and Anaerobic Digestion.

The Society urges the District Council to reject this planning application

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

e-mail from the Society to SHDC on 8 October 2011: Planning application 33_46/1890/11/F - Land adjacent to Alston Nursery, Alston Gate, Malborough, TQ7 3BT Resubmission of planning application 46/2144/10/F for mixed tenure residential development comprising 10 open market and 7 affordable dwellings, associated landscaping, access and other works.

Case Officer: Mr Malcolm Elliott

Affordable houses in the right location are a priority of the community and Malborough is a good location with opportunities to travel to employment in Salcombe and Kingsbridge.

But this application departs from the local plan in two ways - it is outside the Malborough development boundary and does not provide the numbers of affordable housing required in the Core Strategy policy CS6.

The development proposed offers no more to the local community than if it had conformed to the local plan. Approval of the application would be dangerous precedent which could be repeated widely.

The Society suggests that the development should offer more to the community. The District Council should inform the developer that approval will only be given if the number of affordable houses is raised to the number required by Policy CS6 in the Core Strategy.

John Chalmers
South Hams Society

e-mail from the Society to SHDC on 19 September 2011: Planning application 19/2035/11/F - Erection of a general purpose agricultural building on land at SX 756482, Firs Cross, East Allington

Case Officer: Mr Chris Mitchell

This application is for an isolated agricultural building on a site within half a mile of the boundary of the AONB.

The building is not integrated into any existing buildings.

It appears that the building will be visible from points in the AONB to the south west of the site. This would be contrary to Policy C03 of the Devon Structure Plan and Policy CS9 of the District Council's Core Strategy both of which require that great care be taken that development on sites adjacent to the AONB do not damage its natural beauty.

The Society suggests that the District Council should ask for a report from the Landscape Officer and comments from the AONB Unit.

John Chalmers
South Hams Society

e-mail from the Society to SHDC on 4 September 2011: Planning application 08/1853/11/F - SX 7447 4791 HigherTorr, East Allington - temporary erection of 50m anemometer mast

Case Officer: Debbie Crowther

The proposed mast would be visible from many parts of the AONB, including the Avon Valley and its roads and footpaths. The mast therefore contravenes Policy CO3 of the Devon Structure Plan which requires that great care should be taken that development on sites adjacent to an AONB do not damage its natural beauty. The proposal also contravenes Policy CS 9 of the District Council's Core Strategy which states that on sites outside an AONB development will not be permitted which would damage their natural beauty and character.

The mast is also very near to a long established nesting site of peregrine falcons who hunt their prey in the air at great speed. The cables of the extensive guying system used to support the mast would be a hazard to the birds when hunting. The deflectors proposed would do little to reduce this danger to the birds.

The applicants have made it clear in public that they intend to apply for two wind turbines near to the site of the mast whose hub will be at the same height as this proposed mast. This application is clearly a preliminary to the later application for the turbines and is designed to produce evidence of their efficiency and to soften their impact.

The application for 3 wind turbines at near-bye Beeches Farm was refused by the District Council and on appeal by the applicant this decision was upheld only 2 years ago on the grounds that it had an adverse impact on the AONB. This mast on the site of the proposed turbines is less than 800 meters away from the Beeches Farm proposal and is even nearer the AONB boundary - about 100 meters away. There is no reason to suppose that the decision by the District Council or the Planning Inspectors would be different.

The proposed mast would therefore serve no purpose which would justify its adverse impact on the AONB. We therefore urge the District Council to refuse this application on the grounds that it does not comply with its own and the County's policies.

John Watling
South Hams Society
The Drey
Beadon Road
Salcombe TQ8 8JT

e-mail from the Society to SHDC on 5 July 2011: Planning application 33/1061/11/O: The Port Light, Bolberry, Malborough, Kingsbridge, TQ7 3DY - Outline application with all matters reserved for the redevelopment for bar/restaurant, 11 holiday apartments, swimming pool, owners dwelling, store/workshop/staff bed-sit

Case Officer: Debbie Crowther

The Society agrees that the hotel needs redevelopment but feels that the current design can be improved by making it more compact.

The principle of siting the buildings around a courtyard seems appropriate and attractive but in our view the courtyard should be reduced in size by bringing the surrounding buildings closer together. This would have several advantages:

it would make the design more coherent,

it would provide better shelter from winds in a very exposed site,

it would have less impact on the surrounding landscape.

We think that the owner's house might be better related to the main courtyard.

We support the Parish Council's conditions particularly that all necessary accommodation required should be within the the major blocks so that small later additions can be avoided.

We suggest that the car park can be be better concealed with planting.

John Chalmers
South Hams Society

Letter from the Society to SHDC on 4 July 2011: Planning application 53/1494/11/F - Field at SX 7939 4198, Marber Cross to Ridge Cross, Chillington - change of use of land for horses and provision of 3no stables, tack and feed room and haystore in enclosed yard with landscaping

Dear Sir,

The Society objects both to the proposed buildings and to the change of use, on the grounds of the harm that would be caused to the landscape of the South Devon AONB, in contravention of adopted policies.

County Structure Policy CO3 reads: In designated Areas of Outstanding Natural Beauty, the conservation and enhancement of their natural beauty will be given priority over other considerations. Within these areas, development will only be provided for where it would support their conservation or enhancement or would foster their social and economic well-being provided that such development is compatible with their conservation. Particular care will also be taken to ensure that any development proposed adjacent to such areas does not damage their natural beauty.

These developments would not support the conservation or enhancement of the AONB. Nor would they foster its social or economic well-being.

Lest it be claimed that the site is out of sight, this policy makes no distinction between what can and what cannot be seen from public viewpoints. This is understandable: we can have no idea what land will be open to the public in even twenty years' time, let alone for the infinite period for which the AONB is intended. If the protection is to be meaningful it has to apply to the totality and we should as far as possible avoid making exceptions which will inevitably create precedents.

In fact the site is quite widely visible, even at this time of the year when the hedges have not been cut. It can be seen from the public footpaths to the N and NE, and it is very visible from many of the houses which look into the AONB from the high ground on the northern slopes of Chillington and even as far back as Coleridge House.

DP2 opposes unsympathetic intrusion into the wider landscape. Even if the landscaping of the buildings were to be so successful as to avoid detracting from the natural beauty of the area, the riding track, the associated white tape and other accoutrements would certainly damage it, as can already be seen.

DP15 and DP18 would appear to oppose the proposed change out of agriculture and the erection of the new buildings. These proposals would not support the essential needs of agriculture (rather the reverse) or of the local community. They would not make use of existing buildings, be well related to an existing farmstead or group of buildings , or be complementary to any agricultural operations. No management scheme has been submitted.

In his e-mail of 24 June Mr Roberts expresses the opinion that the development being requested is reasonably required for the keeping of three ponies. This only raises the question of whether the site is a good place to keep three ponies. As is acknowledged in the design and access statement, the land has actually been used for horses rather than agriculture for some time. Together with the parcel adjoining it to the east, it presents a sorry picture - weed-infested, unkempt and cluttered with items unrelated to farming. It would surely be much better if it were brought back into cultivation.

In connection with another current application (43/1013/11/F) the South Devon AONB Manager and the council's landscape officer have both raised concerns about the cumulative impact on the landscape south of Chillington of fields moving from agriculture to horse related activities. The Society echoes those concerns and asks that, through the application of the many policies protecting the natural landscape, the trend be curtailed.

Yours faithfully,

John Graham
Secretary

e-mail from the Society to SHDC on 26 June 2011: Planning application 33/1313/11/F: Field to north of Marlborough to Salcombe Road - A381 Resubmission of retrospective application 33/0323/11/F for erection of general purpose agricultural building

Case Officer: Mr Dean Kinsella

We have examined the drawings and documents of this application and all the sites mentioned in it. We have also examined two earlier applications for the same building, Application for Prior Notification of Agricultural Development 0246/10 and Application for Planning Permission 0323/11, now withdrawn.

The existing building was constructed under Permitted Development Rights for agricultural holdings of more than 5 ha determined under Application 0246/10. This application was incorrectly determined as the building and the site were being used for horse related uses not agriculture.

We understand that a District Council enforcement officer visited the site which lead to retrospective application 0323/11. The building is within an undeveloped area of the AONB and an extremely unfavourable Landscape Impact report on this application concluded that the application be refused.

There were also several other issues outstanding from application 0246/10.

The building as constructed has walls of timber boarding and a fibre cement roof while the application states that the walls and roof will be dark grey steel sheeting.

The Landscape Impact report on application 0323/11 states that loose boxes for horses are within the building and this contravenes condition A.2.(1) of Part 6 of the permitted development which forbids livestock to be kept in the building if it is within 400 metres of a protected building, in this case Horsecombe.

The entrance to the site is by a gateway on a layby to the A381. Frequent use of this entrance may be a highway hazard. Access to the building from this gateway is via a track of rolled stone. These access arrangements are not mentioned in the applications.

Application 0323/11 and the resubmitted application are identical apart from the inclusion of the maps showing further land held by the applicant. There was no obvious reason for withdrawing 0323/11 except for the fact that the highly critical the Landscape Impact report would make it difficult not to refuse permission and the possibility of an enforcement order to reinstate the site.

It is clear that the applicant saw the planning officer for this resubmission so there is a presumption that planning approve it. To facilitate this the damaging Landscape Impact report is omitted from the current application and as yet there is no report from the AONB Unit.

However all the reasons for refusal of the earlier applications remain.

The current planning application 1313/11 repeats the incorrect assertion that the building and its site are used for agricultural purposes. Our site inspections confirm that all the other land holdings mentioned in the application are also used for horse related activities. The current application makes no effort to include the other issues mentioned above - materials of construction, the housing of livestock and access to the site and building -all material issues of planning.

The building is located within the AONB and the Undeveloped Coast area in a very prominent position free from other development. The "Devon banks" shown surrounding it do not conceal the barn when viewed from the east and north. It is visible from many parts of the estuary such as Batson creek and the northern stretches of Widegates, often on the skyline. It is visible from a number of points on the old Kingsbridge to Salcombe road including long stretches from Rowden Cross to Blanksmill and Woolston and from Ilton Cross to Horsecombe. It is also visible from the road from Higher Batson to Horsecombe. The building forms a prominent scar in the landscape when viewed from the elevated locations such as the cross roads above Horsecombe and Ilton Cross. The Landscape Impact report of 0323/11 confirms this view. It is notable that no comment from the AONB Unit has been obtained or apparently sought by the planning officer despite the new protocol.

This application is directly contrary to County Structure Policy CO3 on the AONB, District Council policy CS9, Landscape and Historic Environment, of the Core Strategy and to DP 15, Development in the Countryside and DP 18, Horse Related Uses and Structures, of the Development Policies DPD.

The District Council and the public have been deceived by repeated assertions of agricultural use for the building and information on other planning matters has not been supplied. By encouraging a further application without the Landscape Impact report the District Council has given the impression that it is prepared to overlook these matters and the damage to the AONB to cover up its initial mistake in granting permitted development.

The Landscape Impact report for the earlier application 0323/11 considered the application should be refused - a conclusion also urged by the Society. There is no material difference between that and the current application and the Society strongly urges that this resubmitted retrospective application which does considerable damage to the AONB should be refused and the applicant required to reinstate the site.

John Chalmers
South Hams Society
9 Croft Road
Salcombe
TQ8 8DZ

(A more general letter to SHDC, dated 16 June 2011, on protection of the AONB is at Other Documents.)

e-mail from the Society to SHDC on 21 June 2011: Planning application 43/1013/11/F: Proposed stables adjacent to sewage works, Frogmore and Sherford

Case Officer: Lucy Hall

The South Hams Society agrees with the points made by the AONB Unit in objecting to this application and recommends that it be refused as not conforming to DP 15, Development in the Countryside and DP18 Horse Related Uses and Structures.

John Chalmers
South Hams Society
9 Croft Road

Salcombe TQ8 8DZ

e-mail from the Society to SHDC on 2 June 2011: Planning application 33/1061/11/O: Outline application with all matters reserved for the redevelopment for bar/restaurant, 11 holiday apartments, swimming pool, owners dwelling, store/workshop/staff bed-sit - The Port Light, Bolberry, Malborough, Kingsbridge, TQ7 3DY

Case Officer: Mr David Kenyon

This is an important application seeking to extend a substantial building in a rural setting within the AONB yet at present there is no comment from the AONB Unit.

The Visual Impact Assessment is inconclusive.

Highways have indicated they wish to comment but the results are yet to be available on the website.

It has not been possible for me to obtain the Water Borehole report from the website. Its importance is stressed by an objection from neighbouring residents.

For these reasons the Society suggests that the period of consultation should be extended beyond 27th May so that these omissions can be rectified.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

e-mail from the Society to SHDC on 19 May 2011: Planning application 41/1031/11/F. Resubmission of householder application 41/2791/10/F for alterations and extension to dwelling - 6 Bonfire Hill, Salcombe, TQ8 8EE

Case Officer: Mrs Gaille West
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The existing building contains one dwelling. However the proposal in the application is certainly for two dwellings although there is an internal staircase connecting them. There is no acknowledgement of this in the application. Would permission to split the dwelling and additional parking be required?

John Chalmers
South Hams Society
9 Croft Road

Salcombe TQ8 8DZ

e-mail from the Society to SHDC on 9 May 2011: Planning application 41/0652/11/F. Resubmission of 41/2426/10/F for demolition of existing dwelling and erection of 3 no. three storey houses and 1 no. two storey house - Loughrigg, Coronation Road, Salcombe, TQ8 8EA

Case Officer: Mr Dean Kinsella

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I oppose this application because the three houses with three stories make this application overdevelopment and out of character with the neigbourhood. As a result of this and the clumsy massing of the blocks these houses are an unattractive termination to Coronation Road.

I also oppose this application because I note that this application includes new vehicular access points to the site which will result in a loss of resident's parking. The application does not make clear the exact extent of the loss.

Parking at the lower end of Coronation Road is already over subscribed because it has to cope with the requirements of the residents of Shadycombe Road and Croft Road in addition to Coronation Road and those persons who work in the town and manage to get permits. The loss of more spaces is therefore of serious concern to residents.

John Chalmers
9 Croft Road
Salcombe TQ8 8DZ

e-mail from the Society to SHDC on 9 May 2011: Planning application 46/0922/11/F. Redevelopment of hotel to provide new 20-bedroom hotel, 9 holiday apartments, new access and car parking facilities plus restaurant, bar, lounge and terrace - Sun Bay Hotel, Hope Cove, Kingsbridge, TQ7 3HH

Case Officer: Mr Malcolm Elliott

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The Society believes that the redevelopment of the Sunbay Hotel would be of benefit to Hope Cove. The existing building is of no merit and the proposed design is ingenious and by wrapping the building around the contours appropriate to the site.

However the proposal leaves significant problems unsolved. The most obvious is that location of the hotel means that some staff and most visitors will have to travel by car. Of the 38 parking spaces provided 29 will be needed for the occupants of the hotel rooms and apartments. The remaining 9 will not be adequate for day to day use by the 30-40 staff proposed and the restaurant capable of providing over 80 covers. While it is probably not practical to expect on-site parking for all the cars generated by larger functions such as weddings which the new facilities in the hotel will be capable of accommodating, there must be better provision than this and arrangements for the overspill.

The application does not propose any solution to the problem of the extra load on the sewage system which appears to be near or beyond its full capacity.

The development is uncomfortably close to the dwellings on the land above. Although the design does its best to accommodate their outlooks there will be other problems such as the noise of ventilating equipment and the smells from food preparation.

Finally there will be a considerable traffic problem in Hope Cove during the construction and no arrangements have been made to manage it.

The Society suggests that the applicant should be asked to reconsider the scale of the proposal by reducing the number of apartments so that more car parking can be accommodated on-site and the situation with respect to the neighbours above can be improved. A reduced design along the same lines as the original would provide an attractive addition to Hope Cove and of economic benefit to the area.

A condition of any approval should be that a traffic management system be devised and applied during construction.

The sewage problem will remain but it appears that the system must be upgraded in the near future anyway and this proposal may make a contribution to it.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

e-mail from the Society to SHDC on 9 May 2011: Planning application 53/0836/11/F. Demolition of existing dwelling and erection of new 5 bedroom house - Ashley, Holmleigh Road, Torcross, Kingsbridge TQ7 2TJ

Case Officer: Mr Edward Brown

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I apologise for this response being late but I would like to express the Society's support for the various letters of objection sent in by local residents.

This proposal does not accord with the requirement for replacement dwellings specified in G5.31 of your local plan review.

If this oversize house is built it will create a demand for similar increased density of development on adjoining sites which will be difficult to refuse, creating an urban density inappropriate for this location in the South Devon AONB and Coastal Preservation Area.

I would therefore urge you to take into account the point raised in the letters of representation and implement the requirements defined in the Local Plan and its Review.

Yours sincerely

AJ Watling
South Hams Society
The Drey, Beadon Road
Salcombe TQ8 8JT

e-mail from the Society to SHDC: Planning application 33/0765/11/F. Five suites and staff accommodation at Soar Mill Cove Hotel, Malborough, Kingsbridge, TQ7 3DS

Case Officer: Mr Malcolm Elliott

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The first pages of the Design and Access statement appear to be missing from the webpages.

We consider that under the AONB Protocol this design should be referred to the AONB Unit.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

The Haybarn, South Allington - appeal statement - APP/K1128/C/10/2143590

e-mail from the Society to SHDC Development Control, dated 4 March 2011: Planning application 52/0008/11/F: erection of 43 houses at Rowes Farm, Aish Road, Stoke Gabriel, Totnes, TQ9 6PX

Case Officer: Mr David Kenyon

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This site is in the South Devon AONB and Undeveloped Coast area and development must be of sufficient benefit to offset the requirements of policies CS 9 and DP2 of the Council's LDF as well as central Government PPS.

There are numerous reasons why this site does not provide sufficient benefits.

Insufficient affordable houses are provided to meet the Council's target of 50% in policy CS 6 - likely to be 35% in the absence of a grant.

The provision of 65% open market housing is unnecessary - Stoke Gabriel has 90 second homes already.

This is a green field site and therefore does not meet the Council's target in policy CS 5 that 50% of new housing should be on previously developed land.

The site is a habitat of 3 protected species - barn owls, cirl buntings and bats - and adjacent to Hoyle Copse Wildlife site and thus contravenes policy CS 10.

The development will be visible from many sites including across the Dart valley where light pollution may be experienced.

The density of the development at 20 dwellings per hectare is below the requirement 30-40/ha of policy CS 2.

The urban fabric created by the proposal is odd - 2.5 storey houses on a site outside an area of single storey housing of v low density.

There is no employment in Stoke Gabriel and the bus service to Torbay or Totnes is not adequate for work journeys. So all travel will be by car. This is contrary to policy CS 11 and the objectives of sustainable development in PPS 1 and PPS 7.

Vehicular access to site is inadequate - Aish Rd is single track at north of site.

So this application contravenes 7 Core Strategy and Development policies of the Council's LDF as well as numerous central Government PPS.

Lastly there is strong local opposition - over 130 letters of representation objecting to this application. 97% of the population of Stoke Gabriel opposed large developments such as this on the perimeter of the village in the survey for the Parish Plan 2008. There is a Community Housing Scheme proposed for 19 self build houses which would be adequate to supply the affordable houses required

The LDF process itself and new planning provisions expected emphasise importance of taking local views into account.

For all these reasons the South Hams Society urges the Council to refuse permission for this application

John Chalmers
South Hams Society
9 Croft Road
Salcombe
TQ8 8DZ

e-mail from the Society to SHDC Development Control, dated 28 February 2011: Retrospective application for retention of general purpose agricultural building - Field North of Malborough to Salcombe Road, A381, SX726 398, Malborough, Devon

Case Officer: Mr Dean Kinsella

This barn is located within the AONB and the Undeveloped Coast area in a very prominent position. The "Devon banks" shown surrounding it do not conceal the barn when viewed from the high roads to the east and north. The barn is particularly damaging to the AONB when viewed from the cross roads above Horsecombe and forms a prominent scar in the landscape. The planning application does not offer any explanation of the barn's purpose and it is isolated from any other agricultural buildings. Its location appears quite arbitrary. It appears to be directly contrary to policy CS9 of the Core Strategy and to DP 15 of the Development Policies DPD

It is hard to resist the conclusion that because of these factors the barn has been constructed before a planning application was made in the belief that the council will find it harder to refuse a retrospective permission.

The Society believes that permission should be refused and the site reinstated.

If the applicant provides an adequate explanation of the need for a barn and its location a condition should be attached to the permission requiring extensive landscaping including the planting of a substantial area of native trees around the barn that in due course will conceal it from view.

John Chalmers
South Hams Society
9 Croft Road
Salcombe
TQ8 8DZ

e-mail from the Society to SHDC Development Control, dated 18 February 2011: Planning applications 2782 and 2783/10 - Borough Farm, East Prawle

Thank you for sending the revised landscaping plan and design and access statement for these applications. (The latter still quotes the wrong grid reference)

The building that has now been erected under permission 10/2208/10 is of a very bulky and industrial appearance that is out of place in this completely rural site, and two more similar buildings can only make the blight worse.

It is acknowledged that a number of similar buildings have already been allowed in the general area, mostly without the benefit of any landscaping.

It is also acknowledged that if the proposed buildings are coloured dark green (as opposed to black), if the roadside hedge is allowed to grow up, and if the council can ensure that the planting scheme is adhered to until the broadleaved trees are above them (perhaps twenty years?) this site will look like a wood. But the landscape in this part of the AONB is coastal plateau, characterised by open fields with tight hedges but almost no woods.

So in terms of policy CO3 it cannot be argued that the proposals would enhance or conserve the natural beauty of the AONB - they would inevitably degrade it. Nor does the revised design and access statement make any clearer how they would foster the social or economic well-being of the AONB. The Society's objection stands.

John Graham

Secretary

Site Address: Dormers, Ilbert Road, Thurlestone, Kingsbridge, TQ7 3NY: Objection to SHDC planning application 55/2921/10/F, submitted 3/2/11:

Case Officer: Mr Dean Kinsella

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This application is within the AONB and adjacent to the Undeveloped Coast and South West Coastal Path. The increased bulk of the proposed house will be seen from many view points around the area. This contravenes Policy DP2 Landscape Character of the Development Policies DPD.

The development also lies within Policy Area 2 of Thurlestone where development which would alter the character of the area is not permitted. DP1, High Quality Design, of the Development Policies DPD also requires development to respect local character.

On these grounds the South Hams Society objects to this application and suggests that planning permission should be refused. The AONB Unit should be asked to comment on this application.

John Chalmers
South Hams Society
9 Croft Road
Salcombe

TQ8 8DZ

Letter from the Society to SHDC Development Control, dated 18 January 2011 and copied to South Devon AONB Manager: Planning applications 2782 and 2783/10 - Borough Farm, East Prawle

The South Hams Society objects to these applications on the grounds that the development would damage the AONB. (It is incidentally at grid reference SX78143796, not SX78372890 as stated.)

Nowhere in any of the papers relating to the building for which permission 2208/10 was granted only two months ago can we see any indication of an intention to apply for further development. In his submission on the current applications Mr Roberts says that if they are approved all of the buildings on the site would house only about half of the applicant's cattle. The site is right on a substantial public road but is a long way from any residential property, so both security and animal welfare might well be advanced as reasons for needing a house. So there appear to be good reasons to believe that in the future there may be more applications which would turn the site into an even bigger development than is now being applied for.

Even at this stage the development proposed is a very large and prominent one for an AONB, and we think it should be rigorously tested against the provisions of county structure policy CO3. The applications make no mention, for instance, of any benefit to the social and economic well-being of the designated area.

Because of the weather we have not been able to check visibility but the site is high and from the map we would expect it to be prominent from several viewpoints, including a number on the footpaths and bridleways close to the coast. It appears that no landscape assessment was carried out for application 2208/10.

If the council has any thought of approving these applications, we believe that it should first ascertain the applicant's full intentions for the site. It should then seek professional input from the South Devon AONB Unit or use its own staff (if qualified) to produce and publish a landscape assessment following the Guidelines on Landscape and Visual Impact Assessment, 2002 (see Natural England's letter of 24 November 2010 to Mr Munday of SHDC. A copy is attached). There should also be a careful study of what colour and finish on the buildings might best help their concealment.

Letter of 24 November 2010 from Natural England to SHDC

D Incoll
CEO
South Hams District Council

Dear Sir

Planning Applications 61/1630/10 - 1637/10

I am writing with concern for the way the AONB requirements as set out in your Development Control Core Policies DC19 and DC20 are seemingly repeatedly ignored in resolving planning applications.

We have asked for a long time now for the AONB team to be actively included in the statutory authorities (as the Highway authority, etc.) when reviewing planning applications within the AONB. At least such applications in or adjacent to the AONB should be considered by the full Development Control Committee, not just only by a planning officer.

An effective management system will include procedures to implement requirements defined in the DC Core Policies such as those outlined above. The applications above highlight the short comings in your procedures.

In 2007 the new owner of this farm applied for planning permission for a large (893 sq M) agricultural building in quite a prominent green field just inside the AONB. The building was approved under delegated powers.

In the summer of 2008 applications for initially two, later three, more buildings with a total floor space of 1384 sq M on the same site prompted a visit by the Council's Landscape Officer. The first building had by then been erected. His report made it clear that he was horrified at its impact on a sensitive area and was inclined to recommend refusal of any further buildings. The three buildings were approved, again under delegated powers.

In the autumn of 2009 applications for a further two buildings (987 sq M) were submitted with almost no reference to the landscape or AONB. These were again approved under delegated powers despite several letters of objection that they should go to the full Development Control Committee. This took the total floor area to 3266 sq M. So now the blot on the AONB landscape is pretty gross. It is particularly visible across the Avon valley from say Blackdown Rings.

Applications for a further seven buildings (2494 sqM) have now been submitted. If approved they will take the floor area of this "farmstead" to 5760 sq M all in the AONB and the Development Control Committee seemingly never involved.

I would be grateful to have a positive response from you regarding a change in your procedures to actively be seen to be implementing your own defined requirements as set out in your LDF Core Policies.

Yours faithfully

A J Watling
South Hams Society
The Drey
Beadon Road
Salcombe
TQ8 8JT

e-mail of 11/06/10 to Development Control, SHDC:

Planning application 32/0822/10/F Retention of building at Riverside Farm, Loddiswell

The society has on several occasions complained about the continuing damage to the visual environment and the risk to river water quality caused by activity at Riverside Farm. It asks that this application be refused.

The site is in a very prominent place within the South Devon AONB and the proposal would clearly not comply with the adopted policies for the protection of the landscape. Furthermore, the application does not appear to be supported by any independent commercial, technical or environmental appraisal of the project for which the building is now said to be needed.

The enforcement notice requiring demolition of the building was upheld at appeal some two and a half years ago. The society hopes that it will be pursued without further delay.

John Graham
Secretary, The South Hams Society,
The Church House,
Woodleigh,
Kingsbridge
TQ7 4DG

Site Address: Broadley Farm, Diptford, Totnes TQ9 7NJ

Case Officer: Mr George Allpress

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The Society acknowledges the limited contribution that wind turbines can make to reducing carbon emissions although it considers that the case for them is often overstated. They can be considerable intrusions in the landscape and proposals for them within the AONB in general should be unacceptable. This proposal fails on several grounds.

This proposed wind turbine is in a sensitive part of the AONB running up the River Avon. We accept that some views of the turbine from the river are restricted due to the topography and screening by the woods in the valley. But other views especially from locations to the north- east will show the turbine clearly. The photomontages seek to minimise these and are not an adequate representation of the issue.

Depending upon what source is used wind speeds are below or near the minimum for efficient performance and this makes the case less attractive.

Despite the often repeated mantra that there is "no precedent in planning legislation and each case is determined on it's own merits" there is a powerful need for consistency in determining applications. In this case approval of the application would be likely to generate further applications for turbines in the AONB which would be difficult to refuse. The result would be a significant loss of the landscape attraction which brings so many visitors to the South Hams forming a mainstay of the economy.

SHDC needs a general policy to issue public guidance and cover their approach to planning decisions on domestic wind turbines particularly where they are proposed to be sited within the AONB. This should be formulated in collaboration with the AONB. The Society believe that this policy should state that in general wind turbines are not acceptable within the AONB and thus uphold Policy CS9 of the adopted LDF Core Strategy.

John Chalmers
Chairman
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZSite Address:

Land adjacent to Charnwood,
Malborough,
Kingsbridge,
TQ7 3RR

Case Officer: Mr Malcolm Elliott

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The South Hams Society supports this application which provides affordable housing without the burden of unnecessary open market housing to subsidise it, albeit at the cost of commuting to centres of employment.

However there are some concerns about traffic and the lack of pedestrian access to the site. These might be addressed by local widening of the road (including the stretch alongside the allotments) and a crossing to provide pedestrian access to and from the town through the churchyard. The housing layout appears to be able to accommodate this.

The Society suggests that the application be approved subject to conditions in these areas.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

Site Address:
Land adjacent to Charnwood,
Malborough,
Kingsbridge,
TQ7 3RR

Case Officer: Mr Malcolm Elliott

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The South Hams Society supports this application which provides affordable housing without the burden of unnecessary open market housing to subsidise it, albeit at the cost of commuting to centres of employment.

However there are some concerns about traffic and the lack of pedestrian access to the site. These might be addressed by local widening of the road (including the stretch alongside the allotments) and a crossing to provide pedestrian access to and from the town through the churchyard. The housing layout appears to be able to accommodate this.

The Society suggests that the application be approved subject to conditions in these areas.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

Site Address:

Salcombe TQ8 8DZ

From: John Peters

To: development.control@southhams.gov.uk
Sent: Thursday, December 10, 2009 6:13 PM
Subject: A6076CH Comment on application 43/1946/09/F

Site Address: St Martins Church, Sherford Down Road to Sherford Cross, Sherford, Devon,

Case Officer: David Kenyon

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As a member of the South Hams Society Committee and a community representative on the AONB Committee, I wish to point out that the letter by Mr.Chalmers was sent on the understanding that the proposal lies within the AONB boundary which is clearly not the case and I did not see the letter before it was sent.

Bearing in mind the importance of continuing use of our rural churches and the burden of repair that falls on a small part of the community viz the congregation, I would point out that every consideration should be given to maintaining easy use if such buildings are not to fall into disuse. I am sure that English Heritage would not wish to have the additional burden of deciding on the outcome of redundant churches such as this might become. If we are to maintain our landscape and these important buildings in it, more consideration needs to be given to how rural churches may be used. This involves greater ease of access to bring in outside funds. This car park is being supplied free of charge to the local community. The blending of the car park at Modbury Church is a good example. Concerts and other community use is now easier to organise. I do hope that such community values will be considered.

John C Peters
Higher Stadbury
Aveton Gifford
Kingsbridge,
Devon.

TQ7 4PD.

From: John Chalmers john@croftroad.eclipse.co.uk
Date: 12 December 2009 13:37:06 GMT
To: development.control@southhams.gov.uk
Cc: John Peters higherstadbury@googlemail.com
Subject: A6076CH Comment on application 43/1946/09/F

Site Address: St Martins Church, Sherford Down Road to Sherford Cross, Sherford, Devon,

Case Officer: David Kenyon

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And now I must make a second correction to my previous letters on this application. It has been pointed out to me that the site is not within the AONB. However the Site Map shows that it is within the Area of Great Landscape Value, the car park must damage the rural setting of the village and a judgement must be made as to whether the benefits exceed the damage.

I would be glad to have some guidance on the current status of Areas of Great Landscape Value.

My apologies to the applicant.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

From: John Chalmers john@croftroad.eclipse.co.uk
Date: 8 December 2009 11:54:52 GMT
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 43/1946/09/F

Site Address: St Martins Church, Sherford Down Road to Sherford Cross, Sherford, Devon,

Case Officer: David Kenyon

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I must correct my letter of 2nd December was wrong in saying that no consideration had been given to use of the alternatives. The Design and Access Statement makes it clear that use of the village hall car park has been considered.

However I must maintain the Society's opposition to this application. Development in the AONB outside Development Boundaries should only be permitted when there are overriding social benefits. The village hall car park is just across the road from the church's rear entrance so the distance from it to the church is no more than would be covered by those parking in the proposed car park. The Design and Access Statement implies that it is normal usage to drop off those who cannot manage the steps to the rear entrance, at the front of the church.

The congregation is estimated at between 10 and 30 with as many cars as people. In these carbon-conscious times this seems excessive and the congregation must share cars at present.

John Chalmers
South Hams Society
9 Croft Road

Salcombe TQ8 8DZ

Site Address: Old Cotmore Farm, Cotmore, Chillington, Kingsbridge, TQ7 2LR

Case Officer: David Kenyon

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In addition to the reasons for refusal of this application put forward by John Watling the Society would like to add that it would result in the loss of a traditional tourism facility that has the great advantage of having no adverse impact on the AONB during the winter months when the site is most visible.

John Chalmers
South Hams Society
9 Croft Road
Salcombe TQ8 8DZ

--------------------------------------------------------------------------------------------------------------------------------------------------------------

A6076CH Comment on application 53/1976/09/F

Site Address: Old Cotmore Farm, Cotmore, Chillington, Kingsbridge, TQ7

2LR Case Officer: David Kenyon

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This site is within the South Devon AONB and the conversion of a caravan and camping site for limited seasonal use into a development of permanent two storey holiday lodges contravenes the requirements of Policy C4 of the Devon Structure Plan which states that that "development will only be permitted where it would support the conservation or enhancement of the area" and Policy CS9 of the Adopted LDF Core Strategy which states that "conservation and enhancement will be given great weight" within the AONB.

The development is outside development boundaries and therefore is not consistent with Policy CS12 Tourism of the adopted LDF Core Strategy which seeks to centre tourist facilities within town centres and development boundaries.

These policies are not compatible with the development proposed which, if approved, would encourage similar proposals in the undeveloped AONB. We urge SHDC to implement its own requirements as above and refuse this application.

John Watling
South Hams Society
The Drey
Beadon Road
Salcombe

Subject: A6076CH Comment on application 43/1917/09/F

From: john@croftroad.eclipse.co.uk
Date: 2 December 2009 16:24:29 GMT

To: development.control@southhams.gov.ukSite Address: Site off Mill Lane, Frogmore, Devon, TQ7 2NZ

Case Officer: Jenny Draper

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The purposes of the building in this application are ill-defined. It is not an agricultural building in the normal sense as it is not attached to a farm. It appears to be an 8 horse livery stable but could be equally used for many other commercial purposes which may have undesirable effects on traffic and neigbours.

We suggest that a better case must be made for building on pasture land in the AONB outside the development boundary and this application should be refused.

Subject: A6076CH Comment on application 43/1917/09/F

From: john@croftroad.eclipse.co.uk
Date: 2 December 2009 16:24:29 GMT

To: development.control@southhams.gov.uk

Site Address: Site off Mill Lane, Frogmore, Devon, TQ7 2NZ

Case Officer: Jenny Draper

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The purposes of the building in this application are ill-defined. It is not an agricultural building in the normal sense as it is not attached to a farm. It appears to be an 8 horse livery stable but could be equally used for many other commercial purposes which may have undesirable effects on traffic and neigbours.

We suggest that a better case must be made for building on pasture land in the AONB outside the development boundary and this application should be refused.

Subject: A6076CH Comment on application 37/1944/09/F
From: john@croftroad.eclipse.co.uk
Date: 2 December 2009 17:35:04 GMT
To: development.control@southhams.gov.uk

Site Address: Land opposite 60 Noss Mayo, Pillory Hill, Devon, PL8 1ED

Case Officer: Kati Owen

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The proposed 3 storey house would dominate this section of the foreshore and obliterate the cottages behind it. It's position on a restricted plot right on the creek foreshore of Noss Mayo deserves particularly careful consideration. The application provides very little information on it's context and the effect on neigbours and is inadequate to provide a good basis for a decision.

We suggest that the applicant should be asked to resubmit the application and to include in the documentation photomontages of views from across the creek and of both sides from Pillory Hill as well as drawings showing the positions of neigbouring houses, the heights of roof ridges and eaves, car parking and access to the site. We suggest that a site inspection should be made by members of the Development Control Committee.

If planning approval is given it should be subject to conditions which will protect the natural environment of the creek during construction.

From: John Chalmers
Date: 20 July 2009 17:04:25 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 41/1099/09/F

Site Address: The Bothy, Church Street, Salcombe, TQ8 8DH

Case Officer: George Allpress

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The Society objects to the loss of employment accommodation in this application especially as the employment concerned is part of Salcombe's boat building tradition.

From: John Chalmers
Date: 28 July 2009 09:54:21 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 41/1102/09/F

Site Address: Long Park, Higher Batson, Salcombe, TQ8 8NG

Case Officer: Kate Phillips

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The Society recommends that the conditions placed on the original permission, 41/0865/04/F should also be applied to any new permission.

From: John Chalmers
Date: 3 September 2009 12:15:43 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 37/1449/09/F

Site Address: Charnwood, Stoke Road, Noss Mayo, Devon, PL8 1DY

Case Officer: Lucy Hall

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The Society objects to this application on the grounds of increased light pollution caused by the considerably increased area of glazing on the elevation facing the estuary.

From: John Chalmers
Date: 3 September 2009 12:20:52 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 53/1434/09/RM

Site Address: New Development site rear of Penn Cottage, Shindle Park, Chillington, Devon,

Case Officer: David Kenyon

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Because of the major changes from 13 terraced houses to 7 detached houses the Society considers that this should be treated as a new application not a reserved matters application.

From: John Chalmers
Date: 3 September 2009 13:47:53 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 29/1242/09/F

Site Address: The Paddock, Kingston, Kingsbridge, TQ7 4PU

Case Officer: Kate Phillips

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This application for a garage is outside the development boundary of the village and the Society believes on these grounds it ought to be refused.

From: John Chalmers
Date: 3 September 2009 14:26:34 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 41/1308/09/AD

Site Address: South Sands Hotel, Bolthead, Salcombe, TQ8 8LL

Case Officer: Debbie Crowther

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The Society objects to the illuminated signage on the rear entrance on the grounds of increased light pollution of the estuary.

From: John Chalmers

Date: 8 September 2009 19:59:15 BST
To: development.control@southhams.gov.uk
Subject: A6076CH Comment on application 41/1405/09/F

Site Address: Batson Hall Cottage, Shadycombe Road, Salcombe, Devon, TQ8 8NE

Case Officer: George Allpress

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This application proposes use of the Cyder Pound as a boat store on the ground floor and as an office on the first floor. Its use as a boat store must be questionable as the doors on the front wall open directly onto a steep hill near two blind corners some distance from the head of the creek. Moving boats in and out of the store will be difficult and hazardous as the narrow lane will make it necessary to stop all traffic while the operation is carried out. In addition the space for storage of boats is very limited by the position of the large cog wheel in the middle of the space.

The use of the first floor as offices can also be questioned. The natural lighting will be inadequate and neither the Design and Access Statement or the drawings indicate provision of electrical services. There also appears to be a glazed panel in the middle of the floor above the cog wheel.

The absence of credible utility of the building as proposed makes it hard to avoid the conclusion that there is some hidden agenda for other uses such as ancillary accommodation later. Planning permission could not be refused on these grounds but if it is granted the Society suggests that permitted development rights should be withdrawn specifically to prevent the Cyder Pound being used as ancillary accommodation to conform with the view expressed in Mr Elliott's letter dated October 1997.

However there are other significant reasons why this application should be refused on the grounds of internal inconsistencies. Specifically:

the Design and Access Statement refers to a toilet on the ground floor and none is shown on the drawings, the Design and Access Statement refers to a slate roof while drawings show a corrugated metal roof, the Design and Access Statement says that all the cider making machinery will be kept but the drawings show only the press and large cog wheel retained while there are a number of smaller wheels, axles and beams in the existing building which are not accommodated in the drawn proposals and two tanks are shown as removed.

These inconsistencies must be resolved before the application can be considered.

Finally the Local Plan 1989 to 2001 which has been saved until the LDF is completed and approved states that "In view of its extremely sensitive nature development at Batson could only be permitted in very exceptional circumstances". This application cannot be considered to qualify as presenting exceptional circumstances. The approved LDF Core Strategy also emphasises the need to conserve and enhance historic architecture in Objective SO 20 and Policy CS 9(4).

For all these reasons the Society strongly recommends that this application should be refused.