Is YOUR village on the EDDC list for expansion? And another east/west divide

East Devon District Council Strategic Planning Committee are going to discuss:

“Principles for accommodating the future growth needs of East Devon”

on 4 September 2018.

The Committee are being asked to endorse

“The proposed principles for growth” as the basis for future discussion and consultation on accommodating extra growth in the district.”

The document is described as the “start of the debate” for future East Devon growth points for both the GESP (The Greater Exeter Strategic Plan) and the East Devon Local Plan review, which is required to be updated within the next two years.

For the last few years East Devon District Council have achieved their own Local Plan agreed target of 950 dwellings per year. (EDDC Target is 17,100 dwellings between the years of 2013 to 2031).

Recently Central Government decided to calculate each District`s housing requirement targets on a set matrix. East Devon’s build out figure has been set to be 844 homes per year. However, the report suggests that rather than achieve the Government target of 844 new houses per year there is a proposal to build out much higher levels of growth.

The report explains that the objective of higher growth could be achieved by what is called a “Growth Deal” with Central Government where a group of Councils agree to build more housing in return for infrastructure investment from central funds.

This proposed “Growth Deal” is being prepared by the Councils of East Devon, Exeter, Teignbridge and Mid Devon through the “GESP” Greater Exeter Strategic Plan.

It is recognised that Exeter is unable to provide the housing land required to sustain the expected growth of the city, and the rural areas and towns in the rest of the combined area will be required to increase their housing requirements in exchange for the infrastructure improvements for access to and from the city of Exeter.

Improvements to the motorway junctions, new roads, extra park and rides, rail improvements, new stations and an integrated transport system are all identified as priority improvements to overcome the already chronic delays on Exeter`s transport network. There are also aspirations for a “sports hub and concert venue” for Greater Exeter to be included in the GESP infrastructure needs.

The report gives a brief synopsis of the towns in East Devon and concludes that other than the new town of Cranbrook there is limited scope for growth due to the various towns’ proximity to the AONB designated areas, or they are bordering on the coast or close to flood plains.

The conclusion from the report is that the existing towns will only accommodate minimal growth, and with two-thirds of East Devon being included in the AONB of the Pebblebed Heaths or the Blackdown Hills the only area that can accommodate substantial growth is within the North West part of the district.

The report describes this area as the Western most quadrant of this district to the North of Exmouth and West of Ottery St Mary. The land is described to benefit from being relatively flat with no landscape designations. It is also well served by main roads with good vehicle access via the M5, A30, A3052 and A376 and has good existing public transport links with the railway line and existing bus routes.

There are 3 possible ways described as to how development could be achieved in this area.

1. Establish a further new town. Basically, create another Cranbrook. However, the report considers that the creation of another new town in the area could harm the delivery of Cranbrook.

2. Establish a number of new villages. Create a series of modern Devon villages but the report considers that this option would be most damaging in landscape terms.

3. Centre Growth around Existing Villages.

Growth would be required to be substantial with around 400 to 500 extra homes to be added to a number of existing villages (The report does not state how many villages will be required within this area). However, this could harm the character of the village and the existing community.

The new NPPF acknowledges that:

“The supply of a large number of new homes can often be best achieved through planning for larger scale development such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by necessary infrastructure and facilities.”

A list of the Parishes within the expansion area for extra housing area

By referring to a map of the area these are the Parishes(villages) which are within the West of the district which could have development of between 400 to 500 extra dwellings, parishes identified could be:

Nether Exe
Rewe
Brampford Speke
Upton Pyne.
Stoke Canon ​

All these Villages are North of Exeter and access is by way of the A377 – which is not listed as one of the featured roads, so it is unlikely these will be included.

Broadclyst
Clyst Honiton
Sowton
Rockbeare
Wimple.​

These Villages are close to Cranbrook and therefore unlikely to be selected to avoid the villages and town merging.

Clyst Hydon
Clyst St Lawrence
Aylesbeare
Marsh Green

These Parishes are remote from a main road or railway station which probably eliminates them because of their unsustainable location.

Lympstone

This Village is already designated in the report to provide growth for Exmouth.

This leaves the following Parishes most likely to be included for further expansion in the proposals:

Poltimore
Huxham
Clyst St Mary
Clyst St George (includes the village of Ebford)
West Hill
Woodbury​ (includes the village of Woodbury Salterton and Exton)
Farringdon.

The “Principles for Growth” which the committee are being asked to agree to:

• A significant proportion of growth to be in the Western part of the district by either a new town or extending a number of villages or building new villages.

• Plus, modest growth in existing towns with strategic growth around Axminster, Exmouth (including Lympstone), Honiton and Ottery St Mary.

• All other Villages to be encouraged to provide modest growth through their Neighbourhood Plans.

• Focus development on main transport corridors if possible.

Conclusion:

For the last few years, East Devon has successfully complied with the government`s Housing Strategy, with their current Local Plan and at present build out rates, this will over subscribe the Government Building Target until the year 2031.

The Government is not forcing East Devon to co-operate with Exeter to provide some of their housing needs. This decision is totally at the discretion of the District Council and their leaders.

Yes, Exeter is a thriving growth city, and it is recognised that the road and rail connections are dire, but why destroy the character of a part of East Devon for these improvements?

The very reason people choose to relocate to Exeter, its surrounding towns and villages is the beautiful Devon countryside; the building of a mass of new housing will simply make the area a mirror image of the existing areas the people are wanting to move away from!

So, to satisfy the aspirations and needs of the City of Exeter, the rural west area of East Devon will be required to build many more houses with either another new town or new villages or building an extra 500 houses to a number of existing village communities.

Will the Strategic Planning Committee endorse this proposal or not?

“If we value rural Britain, we can’t build houses all over it”

“Government housing policy has lost all contact with planning Britain’s countryside. This week the Campaign for the Preservation of Rural England (CPRE) is up in arms over house-building in green belts, and over the lack of what it calls affordable housing. These are a distraction. It is planning as such that has collapsed.

The CPRE is concerned that 8,000 houses were built last year on green-belt land, or 24,000 over the past decade, and that hardly any were affordable. This has predictably raised a green light over all green belts, with developers rushing forward with applications for 460,000 new homes now in process. Already, unplanned and sprawling “toy-town” estates are spreading across the home counties, the Fens, the Somerset Levels and the Severn Valley. It has sucked development into the south-east of England, denuded town centres and put ever more pressure on transport corridors. It is the worst sort of “non-planning”.

New green belt housing applications push total to a record 460,000
The issue should not be green-belt building or affordability. All rural land is now in contention. As for affordability – usually 20% off market price – such a subsidy is always short-term, and should never be a loophole for allowing building where it would otherwise be stopped.

New houses in the countryside have intense local impact, yet they form a trivial element in the housing market, of which some 90% involves existing stock. Policy should be aimed at genuinely boosting supply. This means cutting Britain’s shocking underoccupation of existing buildings. It means help with downsizing and subletting. It means not taxing sales, as stamp duty does. It means densifying urban sites and being more flexible on building uses. Modern “green” development is in cities.

Local planning must be restored. The government claims the right to decide how many new people come to Britain. It should grant local people the same right, to control the pace and nature of settlement in their communities. New planning rules deny them that right. They dictate that, should local people fight imposed targets, they will lose any further say in the matter, allowing free rein to development. It is heads we win, tails you lose localism.

Britain’s reputation for town-and-country planning has all but evaporated over the past decade. Each change in planning rules, usually dictated by the building lobby, has drawn ever more of the countryside into speculative play. The solution does not lie in arguing over a few hundred green-belt acres and a few thousand subsidised houses. County land-use planning has to be restored. Landscape considered worthy of long-term preservation – and much of it is still outside national parks – should be “listed” for its scenic and environmental value, like conservation areas in towns. Other land could then be declared a potentially developable land bank.

Listing the landscape would replace the present fighting with proper planning. Everyone would know where they stood. Rural Britain would not, as now, be up for speculative land grab. The old mistakes would not be repeated.”

https://www.theguardian.com/commentisfree/2018/aug/06/planning-system-uk-landscapes-listing-rural-britain

New planning rules = developer free-for-all again

As Owl understands it (feel free to correct) Local Plans and Neighbourhood Plans are now basically ripped up unless developers are BUILDING just about everything for which they have permission (building, not land-banking).

A new “Housing Delivery Test” will apply from November 2018. If DEVELOPERS have not built enough homes using these calculations COUNCILS will be penalised by having planning decisions taken from them and DEVELOPERS WILL BE ALLOWED TO BUILD JUST ABOUT ANYWHERE. Just like the old days when we had no Local Plan. Neighbourhood plans will then also count for nothing.

As the CPRE points out:

“…Rather than delivering ‘what communities want’ as it claims to promise, the new planning rulebook and its new ‘housing delivery test’ will result in almost all local plans becoming out of date within two years. It is a speculative developers’ charter and will lead to the death of the plan-led system.

“Without a local plan, councils and communities have little control over the location and type of developments that take place. This results in the wrong developments in the wrong places – local communities’ needs are ignored and valued countryside destroyed for no good reason.”

https://www.pbctoday.co.uk/news/planning-construction-news/revised-national-planning-policy-framework-provokes-mixed-feelings/43866/

Nice one, Tories!

For the geeks amongst us, the methodology of the “Housing Delivery Test” – (9 pages) which will be implemented from November 2018 – is here:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/728523/HDT_Measurement_Rule_Book.pdf

Devon and Somerset – a new Klondike gold rush?

The LEP housing numbers, anticipating 50,000 new households in Devon, are almost certainly driven in part by the heroic assumptions about the local economy, as Owl has pointed out many times.

As we know, the LEP assumption is 4% growth per annum for the next 18 years. Such a sustained economic boom would invoke a ‘Klondike’ style immigration rush into Devon and Somerset, as the economies of all of the rest of the western world failed to compete with us at that level.

East Devon’s current Local Plan is based upon an anticipated annual UK economic growth rate of 3% from 2007, which has turned out to be just over 1%.

This, of course, is why many of our employment sites are dormant (and one of the many reasons why we do not need a new site in Sidford), and all our town centres are struggling – there simply isn’t demand.

Even if economic growth was to average 3% growth from now until the end of the Plan period, which looks incredibly optimistic, we would still have 33% more employment land than we need, according to East Devon’s own numbers.

The LEP’s projections have been laughed at by everyone – especially, Owl gathers, in Whitehall.

But they feed into a whole raft of housing and economic projections, that will ultimately emerge as policy around the region.

What assumption will be used for the Greater Exeter Strategic Plan (GESP) projections, Owl wonders? Now delayed until after the next local council elections in 2019?

Will the GESP team dare to condemn the LEP numbers, or will they adopt them, even when they must know they are nonsense?

What might happen if those without vested interests in the growth of expensive housing in the area were for once denied a say due to conflict of interest?

And where are the signs of the revisions of our Local Plan, based on current realities, that are required every 5 years?

Expansion of Cranbrook not going down well with – Cranbrook

“A total of 138 consultation responses were received from town and parish councils, councillors, specialist bodies, developers and the public. A wide range of issues were raised, including technical concerns about transport issues, such as problems providing vehicle access to some parts of the proposed expansion areas and how rail services can be improved to deliver a half hourly service into Exeter.

It was also noted that some additional land had been put forward by landowners for development through the consultation and this now had to be considered for inclusion in the plan.

… People were mainly concerned about the location and extent of development to the south of the London Road, particularly where this intrudes into Rockbeare parish and the Green wedge that was designated to prevent settlement coalescence (joining up) between Cranbrook and the village.

The community at Rockbeare raised strong concerns with these proposals, which also conflict with the emerging Rockbeare Neighbourhood Plan that has recently been out to consultation. Members were advised that this development was important for bringing the London Road into the town, as well as for creating a sense of place along the road as an entrance to Cranbrook….”

http://eastdevon.gov.uk/news/2018/03/councillors-review-report-on-cranbrook-plan-development-plan-document-dpd/

Risk of green wedge between Cranbrook and Rockbeare being swallowed up despite Local Plan rules

“Cllr Rob Longhurst said: “The main thing I would be concerned with is the idea that a green wedge could be disposed of if it doesn’t fit. It was put there for a reason after long debate and I think it is wrong to suddenly discard it as being inconvenient.”

Cllr Mark Williamson said: “It is so clear in the strategy of the Local Plan that it only takes up a single sentence, saying within green wedges, development will not be permitted. There are six green wedges in the Local Plan so if this was allowed then there will be sleepless nights around the district, where the other green wedges are, particularly around Seaton and Colyton.”

https://www.devonlive.com/news/devon-news/concerns-raised-building-green-wedges-1400152

Blackill Engineering Extension – is this an excuse to drive a new industrial site into the heart of the Pebblebed Heaths?

These days most large developers pay for pre-application advice before submitting a planning application. A recent Freedom of Information request has uncovered the advice that was offered to someone (name redacted) seeking such advice on proposed business units at Blackhill Quarry, Woodbury in early October 2017.

Specifically this proposal was for the erection of AN ADDITIONAL industrial building to support the existing business, Blackhill Engineering, being operated form the site together with the erection of FIVE ADDITIONAL industrial buildings for use by other businesses.

In summary the advice given was that this would not comply with the protective policies that cover this sensitive site. A much stronger employment benefit case regarding the expansion of the existing business to justify a departure from these policies would be needed. The five speculative industrial buildings would not justify a policy departure.

On 20 December 2017, within three months of this advice, planning application 17/3022/MOUT was submitted for outline application seeking approval of access for construction of up to 3251 sqm (35,000 sq ft) of B2 (general industrial) floor space with access, parking and associated infrastructure.

The accompanying justification reads:

“There is considerable and clearly identified need for the existing business at Blackhill Engineering to expand as a result of that business having grown considerably over recent years and with its existing premises now at full capacity. The provision of additional facilities on the application site would allow the company to continue its expansion and so deliver additional economic and employment benefits to the local area…. With the winding down of the existing quarry use of the site, there is a short and fortuitous window of opportunity in which to address BESL’s growth requirements with the reuse of an area of former minerals processing site….It is a crucial part of both local and national employment strategy to protect existing businesses and to encourage their expansion. If approved, the scheme would allow the existing business not to only remain at the site but also to expand. The resulting investment will enable a substantial increase in the provision of highly skilled jobs in the area, increased training opportunities for apprentices and added value to the local economy. Furthermore, the expansion of the Blackhill Engineering will help reinforce the vitality of its parent organisation…”

So, is this application all about the needs of Blackhill Engineering to expand, having already designed flood defence gates for New York City Hospital, worked for the European Space Agency and the pier at Hinkley Point, which in October seemed to require only one building; or more about Clinton Devon Estates trying to generate rent from a new industrial park? Restoration provides no income.

For those interested here is the detailed pre-application advice, given on an informal basis and without prejudice, in about half the words:

The extant planning permission on the site requires a restoration and aftercare scheme to be implemented following cessation of the quarrying operations. As part of this condition, alternative schemes (subject to planning permission) can be considered but two policies are of particular relevance:

East Devon Local Plan- Strategy 7 – Development in the Countryside.

This strategy states that development in the countryside “will only be permitted where it is in accordance with a specific Local or Neighbourhood Plan policy that explicitly permits such development”. In this instance, there is no local or neighbourhood plan which would permit the proposal and, therefore, it is considered that it would not comply with Strategy 7.

East Devon Local Plan- Policy E5 – Small scale Economic Development in Rural Areas.

This policy states that the expansion of existing businesses designed to provide jobs for local people will be permitted where

1. it involves the conversion of existing buildings. Or

2. if new buildings are involved, it is on previously developed land. Or

3. if on a greenfield site, shall be well related in scale and form and in sustainability terms to the village and surrounding areas.

In this instance, the Local Planning Authority recognise the previously developed nature of the site, however, in the ‘Glossary of Terms’ section of the Local Plan (which echoes those contained in the National Planning Policy Framework) previously developed land specifically excludes land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures.

Accordingly, the land would be considered as greenfield.
In terms of Policy E5, as the site would not be well related in sustainability terms to Woodbury or surrounding areas, the proposal would be contrary to policy.

However, if sufficient justification can be made in terms of the needs of the existing business being operated from the site to expand into an additional building, then the economic benefits may outweigh the environmental harm, of the unsustainable location as a departure from the Local Plan.

For this purpose, an economic benefits statement would need to be submitted as part of an application.

The five speculative units being located in an unsustainable location would not be acceptable.”