Below is a comment, left on a previous post, which is repeated here as it contains much useful information:
‘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.‘
P.S. The press release at http://www.eastdevon.gov.uk/communications_and_consultation.htm?newsid=1174 says three things of note:
1. Matt Dickins states: “It is likely to be months rather than weeks before we will have an objectively assessed housing need against which to revise our housing land supply figures. In the meantime, based on the available information, we can only conclude that we do not have a five-year housing land supply (+20%) and so should continue to consider each application accordingly”.
2. “New guidance from the Planning Advisory Service, issued in June 2014, also needs to be taken into account.” – this guidance is a statement of Best Practice and since EDDC’s consultants were presumably chosen as experts already in the field of developing SHMAs this Best Practice guidance should not make a material difference to their delivery and should not be considered an excuse for non-delivery of the SHMA as promised in June 2014.
3. “In common with many local authorities around the country, East Devon has not met its affordable housing needs in recent years and so needs to play catch-up in this sector of the housing market.” So, EDDC should stop allowing developers who got planning permission with a specified number of affordable homes to later come back to DMC and get their affordable home numbers reduced.
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Cock-up or set-up?
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Also, of course, with elections in May 2015 we will enter the period of “purdah” when nothing that could affect political decisions by the public can be published by the Local Authorities. The Sidmouth Beach Management Plan looks likely to fall victim to this fate because of the delay of about 9 months on a project that was only a few months old. That project is getting delayed faster than elapsed time. Perhaps the Local Plan is entering the same state of delaying faster than it is growing older.
This is EDDC all over.
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