Community Infrastructure Levy – to be reviewed even before we get it!

EDDC has got nowhere near introducing CIL – and now the government wants to review it! Heel-dragging on the Local Plan means it hasn’t happened here. It was supposed to fund infrastructure from developers.

Well, at least EDDC won’t need to write anything about it!

What mainstream media isn’t telling you about that DCC Cranbrook Report!

What the Express and Echo article on Cranbrook DIDN’T report:

Firstly, that along with Councillor Moulding, other EDDC (or former EDDC) councillors were part of the DCC task group which were closely involved with the development of Cranbrook: councillors Bowden and former EDDC Leader Sarah Randall-Johnson.

and bits of the report that didn’t make the mainstream media have been extracted here:

Developers are house builders, not town builders. The planning of e.g. the town centre and open spaces is the responsibility of the district council as the local planning authority whose responsibility it is to ensure that developing land commercially is coordinated with building a new community with social as well as physical facilities and infrastructure. It took five years to negotiate the original Section 106 Agreement.

Numerous concerns were shared with the task group in relation to the developers’ activities, among them a large number of incidents relating to the quality of the completed homes, including compliance with plans and residents struggling to encourage developers to address any shortcomings. Landscaping of community space has followed rather than preceded development and the management and maintenance of future community space and development land is lacking. The number of complaints regarding the quality of the built environment resulted in some community representatives being concerned about Cranbrook’s future reputation and the success of future phases.

Despite numerous invitations it was disappointing that none of the four house builders were available to comment on the concerns which participants shared with the task group.

Community Infrastructure

There is no standard model for planning community infrastructure and negotiating with developers, service commissioners and providers, but what is critical in creating a new town is upfront funding to support delivery the development of roads, community infrastructure and affordable housing from the public purse. Some of those facilities, e.g. the primary and secondary schools, Clyst Honiton bypass and Younghayes Community Centre, have been finalised ahead of schedule in Cranbrook. For others, notably the train station, there is a strong public perception that facilities are substantially behind schedule. Building and operating facilities without residents to use them is not viable but equally, residents expect facilities as soon as they move in. Participants repeatedly called for a multi-disciplinary team to plan and shape the future provision of services in Cranbrook.

In the absence of alternative public transport provision other than a limited but expanding bus service, car parking facilities were described as inadequate, including insufficient car parking allocation per bedroom, no visitors’ car parking, allocated parking bays being situated away from homes and garages being physically too small for cars to fit in them. Concern was expressed that habits formed in the early days would be hard to unlearn and that transport infrastructure should be delivered in line with residential development. Residents criticised “blue sky” bicycle thinking ignoring the reality that today’s Society had a two car per dwelling dependency which should be catered for in new development.

The roads in the town are not yet adopted, and as they are carrying significant volumes of construction traffic, the County Council does not currently have timescales for when responsibility will be transferred. The maintenance for the roads remains the responsibility of the developers, including gritting in the winter. The task group understands that the developers have an agreement with Devon County Council to finance gritting by the highway authority in severe weather. Several participants expressed concerns about dangerous car parking by residents and developers on pavements, corners and junctions but Devon County Council cannot extend its civil parking enforcement service until the roads are adopted.

Safe access routes to the Cranbrook Education Campus (primary and secondary schools) were due to be completed by the end of August 2015, including secure footpaths. An Infrastructure Site Manager employed by the Developer Consortium was overseeing their completion.

The task group remains concerned about the secondary school being located next to the railway line. Network Rail has committed to delivering awareness training for the children once per year in the school. The school was also planning to operate manned gates.

The main road through Cranbrook is not finished which might cause problems for parents whose children attend both the Cranbrook Education Campus. They would have to drop children off at both sites at similar times with no direct access route to both.

A pre-school facility would have assisted at an early stage.

When the first residents moved into Cranbrook in the summer of 2012, there was no social or community infrastructure or service provision beyond the completion of their homes. The task group repeatedly heard how this was a problem especially for the more vulnerable residents, including single parent families and residents without access to private transport. Social housing occupants were housed in Cranbrook and thereby removed from established communities, with shops, public transport and public services, and lived in Cranbrook in isolation. The complete lack of healthcare, social care or other professional support during the first 18-24 months meant that some residents were left to struggle on their own, exacerbating existing problems, including (post-natal/long-term) depression and drug/alcohol dependency.

Participants repeatedly expressed how there was provision for young children under the age of five in the form of open spaces and safe play areas, and some surrounded by unsafe fencing, but still no facilities exist for older children and teenagers. This resulted in problems, e.g. older children using the park and making it an unpleasant environment for younger children to play. Although funding had been available in the Section 106 Agreement from the beginning, the youth bus had only commenced at a later date. The task group understands that this provision was temporally withdrawn following an alleged antisocial behaviour incident at the end of July 2015. Participants commented that the provision should increase in order to combat antisocial behaviour issues, rather than be withdrawn.

The Cranbrook Medical Centre opened on 20 April 2015, nearly three years after the first residents moved in. An unsuccessful tender for new services and premises had been issued by the then Devon Primary Care NHS Trust in the past. The reorganisation of the NHS saw the responsibility for the commissioning of primary care services transfer to NHS England which awarded the contract to Devon Doctors. A funding challenge remains: Core services delivered in GP surgeries are funded per capita based on the number of formal registrations with a surgery. Although the current practice in Cranbrook has a capacity for approximately 3,500 patients, only 514 patients were formally registered at the end of July 2015. NHS England has provided some core minimum funding to the practice whilst the list size remains low and this will be paid until the registered population reaches a certain size, at which point capitation-based funding will be applied; another example of upfront funding required in the initial period. Two GPs, who are building their work load up to full time, and one nurse are currently practicing.

A backlog of patients who still need to be registered remains. When moving to Cranbrook, residents had to register with the Pinhoe & Broadclyst Medical Practice in cases where their old surgeries would not keep them registered. The Pinhoe & Broadclyst Medical Practice was difficult to access with public transport from Cranbrook which had proved a challenge for the more vulnerable members of the community.

Cranbrook is forecast to have approximately 20,000 residents by 2031 and the GP surgery will have to slowly evolve in order to grow in conjunction with the growth in residents and their future healthcare needs. The surgery will need a new building in the future with sufficient capacity to expand in a modular way to grow with the population. It would therefore be important for the NHS to be able to access Section 106 funding as appropriate to enable such premises to be facilitated, although there are concerns around State Aid which will need to be addresses as GP practices are effectively private businesses. NHS England is currently working with other health partners to develop a joint response to planning applications being received.


The independent pharmacy is being accommodated in temporary premises at present and the task group heard from participants how its provision might have been better coordinated and co-located with the GP surgery with improved forward planning.

One of the objectives in the development of Cranbrook is to develop the employment infrastructure, i.e. create one job per residential dwelling. Employment opportunities exist in nearby Exeter, the SkyPark and the Science Park and eventually in the town itself, with the intention that Cranbrook develops as a small enterprise town. The development of small-scale employment spaces is currently being pursued with the conversion of two residential dwellings into offices. Commercial properties in the town centre have not yet sold. The task group questioned where spaces are in the town for small- and medium-sized enterprises to establish their businesses. An Economic Development Strategy has been developed for Cranbrook.

Talaton planning refusal will affect many other communities in East Devon

Two planning applications for 10 and 25 houses in Talaton have been refused on appeal. It is best to read the full document (see link below) for how it might affect YOUR community.

Basically, although the Inspector had a LOT to say about how he did not trust EDDC’s figures on 5 year land supply or its planning abilities in general particularly with regard to Cranbrook, the unsuitability of the suggested S106 option of village hall extra parking, the lack of sustainability AND Talaton’s nearness (within 10 km) of the Pebblebed Heath weighed heavily in his decision:

30. From the information in front of me, the Council has not demonstrated that previous under delivery has been accounted for within its five-year supply calculations. Even if the previous under-delivery has been accounted for within the estimated need of 17,100 identified within the SHMA, which is not certain, the way in which the Council have addressed the previous under-supply is not consistent with the aim of addressing it within the first five years, where possible. In the Council’s projection the 17,100 has been split evenly over the plan period, ‘the ‘Liverpool’ method. Whilst the PPG is not prescriptive in stating that any under-deliver must be recovered within the first five years it sets a clear preference for this approach, ‘where possible’. No evidence was presented by the Council to suggest that it would not be possible to recover any previous under-supply over the next five years and the Local Plan Inspector has previously written to the Council to advocate the ‘Sedgefield’ approach with the aim of boosting housing supply.

31. Moreover, I have concerns that the projected delivery rates for the new settlement at Cranbrook are not supported by clear evidence. The predicted completion rate for the two phases of the development over each of the following five years is 467 dwellings per annum. However, the March 2015 HMU identifies that there had been 757 completions between ‘summer’ 2012 and August 2014. It is not clear when development commenced but the published completion rate suggests a figure in the region of 350 to 375 dwellings per year over the two year period. The Council suggested orally at the Hearing that there is evidence to suggest that delivery rates are likely to increase but no firm evidence was submitted to show how the predicted delivery rates had been derived. In effect, those predictions show an increase of approximately 100 dwellings a year at the site, over and above the published rate of completion to date. That rate of delivery is not supported by the evidence presented to me.

I conclude that the location of the site is such that the proposed developments would result in unsustainable travel patterns resulting in an increase in the use of the private car. The harm resulting from those unsustainable travel patterns would be comparatively greater for the proposed development in Appeal B due to the greater number of dwellings in that scheme. Both proposals would be contrary to the requirements of policy TA1 of the LP and policy TC2 of the ELP, which state that new development should be located so as to be accessible by pedestrians, cyclists and public transport and well related to compatible uses to as to minimise the need to travel by car.

the proposed car park [for the village hall] is not directly, or even indirectly, related to the impact of the proposed scheme and is not necessary because of it. Thus, the offer to provide the car park is not a matter that I can take into account in reaching my decision, having regard to paragraph 204 of the Framework and regulation 122 of the Community Infrastructure Levy Regulations (2010). Whether an individual landowner or developer chooses to offer the car park to the Parish Council is a matter for their consideration. It is not a factor that can be taken into account in reaching my decision.

…The appeal sites are within a 10km radius of the Pebblebed Heaths SAC/SPA. The Council have referred to the South East Devon European Site Mitigation Strategy10 (the Mitigation Strategy) which identifies that planned residential and tourist accommodation development within that radius would, in combination, have a detrimental effect on the integrity of the SAC/SPA, as a result of increased recreational pressure within the designated SAC/SPA boundaries. Both main parties agree that mitigation is necessary in order to off-set the harm caused by the proposed developments and clause 3.3 of the s.106 agreements in relation to both proposals indicates that planning permission should be refused in the absence of the proposed mitigation11. Based upon the findings of the Mitigation Strategy I concur with that view.

Paragraph 7 of the Framework identifies three dimensions of sustainable development, based on economic, social and environmental factors. The Framework identifies that these strands are mutually dependent and should not be considered in isolation. In this case, the village is not in a sustainable location in terms of its proximity to shops, services and employment opportunities. Future residents would be largely reliant upon the private car. That reliance would not foster a move towards a low carbon economy and would be contrary to the environmental dimension of sustainable development.

The full document is HERE13.1832 & 1833.mout

Who shapes our future?

Anyone who’s been to the new town of Cranbrook lately, will be interested in this link:

Was it Churchill who once said, we shape our buildings and our buildings shape us…

Many East Devon schools at 95%+ capacity and still we allow rampant development

The following schools are oversubscribed or at 95% or more capacity and still we allow free-for-all development without infrastructure:
In East Devon:
Woodbury Church of England Primary, Broadclyst Primary, Exeter Road Primary and Brixington Primary schools in Exmouth, West Hill Primary near Ottery St Mary, Kilmington Primary, Stockland Primary near Honiton, Lady Seaward’s Primary at Clyst St George and Mrs Ethelston’s Primary near Axminster, are all over subscribed. 
This autumn, six more East Devon primary schools join the list by being at 95 per cent capacity or over: Ottery St Mary, Bassetts Farm Primary in Exmouth, Sidbury Church of England Primary School, The Beacon Church of England Primary School, St Joseph’s Catholic Primary School in Exmouth and Feniton Church of England School.

Local Plan consultation – Inspector will reconvene hearings on 7 July 2015

East Devon Local Plan and Community Infrastructure Levy Charging Schedule – Consultation on Proposed Changes:

I would like to draw your attention to a public consultation, which East Devon District Council is undertaking, regarding a series of proposed changes to the East Devon Local Plan and to the Community Infrastructure Levy Draft Charging Schedule.

These changes, together with supporting evidence for the local plan and information about our consultation, can be viewed on the council web site at:

Proposed changes to the Community Infrastructure Levy, as well as supporting documents and forms for comments can be read at:

The consultation will run for eight weeks, starting on 16 April 2015. Anyone can comment on the proposed changes and can reply to questions set by the appointed Planning Inspector. Responses must be received by the council at or before midday on Friday 12 June 2015 at the latest.

Responses received will be sent to Mr Thickett, the Inspector and it is envisaged that the first day of hearing sessions will start at 10 am on 7 July 2015 at the Council Offices in Sidmouth. Paper copies of the plan changes, together with supporting documents and response forms will be sent to libraries and Town Council offices in East Devon where they will be available to the public. We will also make paper copies available for inspection at the Council Offices, Knowle, Sidmouth EX10 8HL. Documents will be available during the normal opening hours for offices and libraries.

EDDC and the Case of the Mysterious Numbers

An article in ine of today’s newspapers is about health and the figures for Body Mass Index and cholesterol ( Sunday Times). It makes the point that figures for “healthy” BMI and cholesterol were picked arbitrarily and based on little firm evidence and may be quite wrong.

Rather like EDDC’s old AND new annual housing figures.

Several readers have made the point that they can find no evidence at all for the figure of 950 houses a year for the next 18 years in any of the latest Local Plan documents. All sorts of figures are mentioned for all sorts of scenarios but 950 does not seem to be one of them.

Perhaps this is why Mr Thickett, the Inspector who is usually so quick at responding to EDDC, has yet to reply to EDDC’s submission of the new draft which they sent to him on 18 March 2015 (with Community Infrastructure Levy rate information sent on 30 March). He usually replies witin a few days.

This new draft must be giving him much food for thought.

Surely not yet another enormous blunder that will allow a developer free-for-all to continue well beyond the life of this (currently) Conservative-controlled district council with its “economic growth” at all costs mantra?

EDDC’s letters to Planning Inspector on latest draft local plan

18 March 2015

Click to access 07-letter-to-mr-thickett-18-march-2015.pdf

30 March 2015:

Click to access 08-letter-to-mr-thickett-30-march-2015.pdf


Click to access cil-letter-31-03-15.pdf

Mr Thickett, the Inspector, is usually quick to respond so we should see replies to all three of these soon (or, indeed, he may have already replied but letters may be awaiting posting on EDDC’s webpage of correspondence with the Inspector:

Questions for the Local Plan

When maximum, minimum and average figures were compiled why was maximum chosen, as maximums can be skewed.

Why was the final figure designated as the MINIMUM number to be built if maximum numbers were chosen?

Where are these houses to be built: sites for such numbers are not identified nor the number of houses per site. This will encourage very large initial developments with no ability to refuse (aaah). Only Clyst St Mary seems to have designated (large) numbers.

Where is the Community Infrastructure Levy document which specifies the cost per square metre of development to support local and district-wide infrastructure for these massive increases?

What is our current 5/6 year land supply?

With the future of the inter-modal freight terminal uncertain why is this not designated as extra employment land?