2. Issue. I invite you, please, to note that:
a.English planning policy explicitly favours the ambitions of developers before the Devon public.
b.Developers may be seeking to avoid scrutiny during the Coronavirus pandemic.
b. Devon’s cultural and natural environment is at risk from unsustainable cumulative urbanisation.
c.The National Planning Policy Framework (NPPF) gives undue weight for impact on highways to quantitative impact assessments, rather than qualitative judgements.
d.Your advice is sought on how to ensure that a planning proposal in our Village is given fair scrutiny, rather than being passed by default?
3. Policy Background. Planning policy changes before and potentially after the Covid-19 pandemic, risk favouring property developers and shutting the public out from the planning system. We fear small groups of senior councillors may make decisions on controversial developments, with little or no involvement from members of the public or opposition councillors. A number of our more elderly villagers are disenfranchised when online consultation replaces Parish meetings as now. These meetings are important for village democracy and the greatest happiness of the greatest number. We fear that some development proposals, like the one in our Village below, may be allowed to progress, after online-only public consultation.
What will it mean for Devon’s character if HMG eases up planning even more to encourage a ‘bounce-back’ after COVID?
4. Planning Pandemic. The Prior Notification for the Change of Use of an existing Agricultural building at St Isidore Farm, opposite the medieval listed St Nicholas Church and Lych Gate, in the tiny historic village of Combe Raleigh is the latest in a constant stream of, what we consider, to be undesirable applications in our village, Combe Raleigh. This tiny village is situated in an area of outstanding natural beauty (AONB). The proposal, which was refused permission about 2 years ago, was submitted very conveniently only a few days after the lockdown, when the Parish Meeting had been suspended due to Covid-19. We suspect the developers are deliberately evading engagement. Anecdotally, we hear that many developers are taking advantage of Covid-19 to avoid scrutiny of planning applications. To make matters worse, since the Devon Structure Plan was replaced by the National Planning Policy Framework in 2012, change of use for this agricultural building does not require a detailed application. Prior Approval permission means that the owners/developers would then be free to operate within the existing structure. In this case the ‘deadline for determination’ is 23rd June.
5. Cumulative Urbanisation. In our view, our Village, like many others, is being ruined by cumulative suburbanisation and East Devon District Council is permitting a steady stream of unsuitable development, including agricultural change of use, without due regard for the AONB, Grade 1 and Grade 2 buildings etc. The farm, formerly known as ‘Barton Farm’, divided in the last few years into ‘The Barton’ and ‘St Isidore Farm’, is, in the words of the AONB Management Plan, an example of the ‘on-going trend towards amalgamation of farm units, separation of farmhouse from the land, and cumulative development of agricultural buildings. As such many farms are becoming essentially residential, for keeping horses or as small holdings, there is a risk of our countryside taking on a suburban appearance with increased houses, people, traffic, noise and light. The distinctiveness of Combe Raleigh, as part of the Blackdown Hills AONB, has a timelessness and tranquillity. Its very character relies on retaining a natural feeling without being over managed. Although hard to quantify it is all too easily lost through, for example, increasing standardisation, creeping suburbanisation, changing agricultural practices and loss of distinctive elements of the natural and historic environment’ (Blackdown Hills AONB Management Plan). Each individual application may not have a significant impact on our Village as a whole, but cumulatively they are eroding the area’s distinctive character.
6. Hamstrung Highways
. The really regrettable matter is that Devon Highways Department can do nothing in the face of the National Planning Policy Framework (para 109). Before 2012, the Devon County Structure Plan provided Standard Highway Reasons and Conditions (Planning – Highways Development Management Advicedevoncc.sharepoint.com › sites › _layouts › guestaccess
) for refusing applications which previously would have included: Access; Inadequacy of Submitted Information; Access Gradient; Access Alignment; Pedestrian Access; Access Width; Access Route; Traffic Conflict – Commercial Use; Piecemeal Development; Isolated Land; Footway Deficiency; Off-street Parking; Turning Space; Loss of Parking; Surface Water; Precedent for Conversion to Multiple Occupation; Green Lanes and Sustainable Development. None of these qualitative judgements are currently admissible to stop development. For example, in respect of Green Lanes, Highways could no longer refuse a proposed development on the grounds that it ‘is likely to result in an increase in vehicular traffic using a road/ roads which is / are considered unsuitable for that purpose, due to its / their condition and the standard to which it is / they are maintained, contrary to Policy TR10 of the Devon County Structure Plan
.’ National Planning Policy Framework requires quantitative
evidence such as formulae that “assume” numbers of movements for an agricultural undertaking and for a shop rather than an assessment of the authentic situation and qualitative judgement. Devon Highways is forced to prefer artificial intelligence over human intelligence and common-sense!
7. Disingenuous Development. Despite the localism agenda, it is difficult for members of a small rural parish to defend against wealthy and experienced developers or their apparent political influence. Michael Groombridge (85) (British but registered as resident in Switzerland) and his wife Ms Adriana Lozinska (50+?) (Polish but registered as resident at Isla Canela Golf Resort in Spain), the owners of St Isidore, are experienced business people with a closely guarded extensive incremental development plan. We believe that their longterm interests are to “sell up and go”, having, in their wake, permanently changed the vista of a historic Devon village after achieving their planning ambitions. We do not think their “heart” is in the village or that their development proposal is for the “wider public good”. We are broad minded people not NIMBYs.
8. Conflict of Interests
? Coincidentally Adriana Lozinska has influential advisers and friends including Andrew Leadbetter, Leader of the Conservative Group on Exeter City Council, Cabinet Member for Economy, Growth & Cabinet Liaison for Exeter in Devon County Council and Director of Visit Devon (https://www.checkfree.co.uk/Company/08308177/HQ-CROSS-BORDER-SERVICES-LTD/Company-Details/
). Leadbetter is a Co-Director with her of HQ Cross Border Services Ltd, a Management Consultancy, registered at St Isidore Farm and presumably supports the development agenda. The Groombridges have been lobbying the village to canvas support and defend their proposal by sending an e-mail recently, following the publication of 38 objections on the East Devon Planning portal. Approximately 25% of central village households have written to the planning portal to object to their plans.
9. Conclusion. Despite our village, Combe Raleigh, being in the Blackdown Hills AONB and despite a previous planning application for change of use being turned down a few years ago, despite around a quarter of households in the Village centre publicly objecting, our Village is struggling to prevent this and other proposed developments from destroying our tranquil Devon environment. We would, therefore, be grateful for your advice and support, please.