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21 Aug 2014

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Affordable and Social Housing, DCC, Duty to co-operate, EDDC, Environment (local), Local Plan, Neighbourhood Plans, NPPF

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The delayed Local Plan – the missing document tracked down and a commentary on it (“What the Dickins”)

An EDA correspondent has tracked down the elusive “attachment” to the agenda of the Development Management Committee regarding the delay to the Local Plan (see post below)

DM260814-Emerging Housing Numbers

and a critique of this document is given below by the same correspondent:

What the Dickins?

A paper by Matt Dickins, EDDC’s Planning Policy Manager, to be presented to Development Mgmt Committee on 26 August  (see link above) makes for depressing reading. Residents of East Devon hoping that EDDC will finally be getting its act together on housing land provision will be deeply disappointed.

As many will know, EDDC is obliged to prove that it has an objective evaluation of housing land provision. The absence of such an evaluation, and EDDC’s failure to prove both a five-year land supply and have a Local Plan in place, means that it remains open season for developers. An objective evaluation of housing land need is achieved through the production of a Strategic Housing Market Assessment (SHMA). In his scathing review of EDDC’s draft Local Plan earlier this year Planning Inspector Anthony Thickett called the absence of an up to date SHMA a “serious failing” on the part of the Council. (He also found that EDDC’s argument for 4,000 ‘overspill’ migration numbers, mostly from Exeter, had “no empirical basis”.)

Does Mr Dickins come bearing good news for EDDC and the people of East Devon that the day of the SHMA is at hand? Not at all. His paper comprises six pages of complacent waffle. Notwithstanding that some research should have already been done, “unfortunately there have been delays”. There may need to be discussions with adjacent authorities. (We know that, Mr Dickins. Exeter CC is looking to appropriate East Devon countryside.) While Mr Dickins’ paper points out that demographically East Devon is likely to see a major increase in population from the over 65s – surely implying a need for more sheltered accommodation in towns with services than new build on greenfield sites – his paper concludes lamely that “at this stage it is not possible to provide a timetable for completion of the full SHMA work”! The consequence? “We can only conclude that we do not have a 5 year housing land supply and continue to consider application [sic] accordingly”.

To translate: EDDC has no idea when the SHMA will be finished, it won’t even venture a guess, and in the meantime the lack of a five-year housing land supply [and Local Plan] means that developers will consider to maintain the upper hand in a district where two-thirds of the land is AONB. This is a woeful paper: DMC should send Mr Dickins to the Naughty Step and require him to try again. Time someone got a grip while there is any countryside left in East Devon.

5 thoughts on “The delayed Local Plan – the missing document tracked down and a commentary on it (“What the Dickins”)”

  1. Pingback: East Devon Alliance | East Devon Alliance

  2. To be fair to Matt Dickens, if he has been told to submit a paper but, for whatever reasons, has not actually reached the point of being able to issue the SHMA, then he is likely to issue a report that is “woeful”. But this does not necessarily mean that Mr Dickens is at fault. A few questions that I think need to be answered before we aim our criticism at Mr Dickens (a council officer) rather than at our elected representatives who are normally the ones who should be held responsible:

    1. Did Mr. Dickens have sufficient resources to be able to develop an SHMA in the time-scales allowed? The budget, and hence staff, for the Planning Policy unit is set by the Council (presumably based on decisions made by the Cabinet), and my understanding is that has been cut year on year. So if it is lack of resources that has resulted in non-delivery, it is not Mr. Dickens who should be held responsible.

    2. Is the hold-up due to non-delivery by partners? My understanding is that the EDDC SHMA needs to be undertaken in partnership with several other local authorities, and if they have not delivered that may not be Mr Dickens fault either (though I would have expected him to have commented on this in his report if it were the case).

    Te real questions that need to be asked of Mr, Dickens at DMC seem to me to be:

    A. What is the cause of the delay to providing a SHMA?

    B. What additional resources (if any) do you need to deliver this as quickly as possible?

    C. When can you commit to delivering the SHMA for consultation based on current resources? When can you commit to delivering it if you get the increased resources you are asking for in B.? Based on these when would the Planning Inspector be able to review it again?

    I am sure that (as a member of the public) I will not be allowed to ask these questions myself at DMC? So who would be able to ask them?

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  3. I have now had time to fully digest the report and do some further research and it looks like the LP resubmission is extremely unlikely to be this year, and possibly (if not probably) after the elections in May 2015.

    A good starting point for documentation about the activities relating to fixing the Local Plan can be found at http://www.eastdevon.gov.uk/lpsubmission which has a chronology and links to all the major documents.

    My analysis of the situation is as follows:

    1. The SHMA consultancy contract seems to me to be in a shambles.

    However, Section 3 of this recent report gives the breakdown of this Best Practice into 6 stages, and paragraph 3.2 states that the work on the SHMA has only reached the first of the 6 stages in the PAS guidance.

    Moreover, in a both letter to the Planning Inspector in mid-April 2014 http://www.eastdevon.gov.uk/lettersinspector12.pdf and the draft action plan of 8 May http://www.eastdevon.gov.uk/actionplan02.pdf attached to a letter to the Planning Inspector on 22 May 2014 http://www.eastdevon.gov.uk/lettertomrthickett220514.pdf Mr Dickens was saying that the SHMA would be available in June 2014.

    I have no reason to doubt that Mr Dickens was reporting these dates because that was what he was being told by DCA, but I cannot see how DCA could be reporting in May 2014 that they would finish in June 2014, and yet in August 2014 we have only completed the first of 6 stages to complete the SHMA.

    The current report says NOTHING about the state of the SHMA contract with DCA. My experience in public sector outsourcing (having worked on both sides of the fence – though admittedly in IT rather than Planning Policy), this is likely now to be a major issue. DCA is certainly running late (and in consultancy, time is literally money) and so very likely to be running over budget and likely to make a loss on this piece of work, and it seems to me that there is a very high probability that there will need to be major contract renegotiations (DCA will likely claim a “change in scope”, EDDC will deny most of it, arguments will go back and forth – all of which will delay things further), and possibly eventually an agreement for EDDC to spend a lot more money spent to get this work completed by DCA – or worse still the contract being re-let and re-awarded to someone else to start again at the beginning.

    So questions I want to know about the DCA contract:

    A. Why has the SHMA not been delivered by DCA? Why were they still predicting they would deliver in in June as late as early May, and why were we surprised by its non-delivery with only 1 of 6 stages currently completed?

    B. Is DCA still committed to deliver the SHMA within the current contract & existing costs?

    If so, what is DCA’s revised schedule, and what happens if they miss it again?

    If not, what are the EDDC plans to get the contract back on the rails so that the SHMA can be delivered, and what are the likely timescales and additional costs for revised or new contracts?

    2. Timescales

    The special DMC meeting on 8 May 2014 http://www.eastdevon.gov.uk/combined_dmc_agenda_080514.pdf page 5 onwards, discusses the draft Action Plan response to the Planning Inspector, and on page 19 there is a timetable which suggests that by now they would be providing “Feedback report on comments received [from the Consultation on the new SHMA] to Development Management Committee” for approval so that “Feedback sent to Inspector” by the end of August.

    However if you look at the draft Action Plan, it is clear that there are several other pieces of work to do before Feedback to the Inspector, so this seemed unrealistic even then.

    As far as I can see, the following still need to be done:

    A. The remaining 5 stages of the SHMA as documented in Section 3 of the current report.

    B. The activities described in the draft Action Plan.

    C. The activities in the timetable from 8 May.

    Personally I cannot see these being completed this year, and I would guess that it might take considerably longer than that.

    SUMMARY

    The DMC needs to get a grip and take both control and responsibility for the completion of the Local Plan.

    They need to find out the state of the contract with DCA and get it back on the rails.

    They need to create a robust plan for redelivery of the revised Local Plan to the Inspector, providing additional resources to the Planning Policy unit if that is required to speed things up.

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