• Minority report on EDDC’s Local Plan

    9th January 2013 | News | Claire
  • Minority Report

    NB. I would like to speak at the Examination In Public.

    ® 6.36
    Following the 2011 elections I was appointed to the Local Development Framework Panel to work on a revised plan, which came to be known as the Local Plan.

    Deeply concerned about the unevidenced level of growth for the district, I was often a minority of one on the panel, as my views (which were based on valid evidence despite what some councillors claim) were overridden again and again.

    This is why I have chosen to prepare for you what I have decided to call a ‘minority report.’
    ……………………………………….

    Covering letter

    Dear Planning Inspector

    I have carefully studied the evidence underlying the development proposed in the East Devon Local Plan and its predecessor, the Local Development Framework for well over two years and what I have read concerns me very much.

    I am also unhappy with the way that the Local Plan Panel (which reconvened following a big campaign against its predecessor, the Local Development Framework) was railroaded into making decisions, without the necessary evidence.

    The Local Development Framework (LDF) meetings, up until May 2011, had, controversially, taken place behind closed doors.  That is three year’s worth of meetings closed to the press and public.  Even the minutes (eventually made public after persistent campaigning) were marked confidential and not circulated widely within the council.

    There was such concern about the way the councillors (the LDF Panel chairman at that time was a planning consultant and builder, as well as deputy leader of the council) were running the panel in 2009 that the Planning Advisory Service (PAS) was called in.  The report is here – see from page 46. http://www.eastdevon.gov.uk/oscc_ldf_report_020210.pdf

    Referring to ‘corporate priorities changing’, the PAS executive summary states:  “This has led to concerns by some that members and the LDF Panel have placed more focus on identifying possible development sites to meet the five year land supply than evaluating different options and alternatives for a core strategy.”

    Many people are asking why EDDC does not have an up-to-date Local Plan. 

    Under ‘current position’ in the PAS report on page 49, it states:  “The council is way behind the proposed timescale set out in that document, which had projected the core strategy to be adopted by September 2008.”
    (This represents a potential SIX YEAR delay on finalising a Local Plan).

    The report then alludes to a planned draft ’preferred options’ consultation for early 2010.  In fact, the LDF core strategy was not released for consultation until August 2010, following which a huge campaign started (of which I was a member) against the levels of growth and the weakened countryside protection policies.

    The LDF Panel, for much of its duration, met twice a month.  Many residents will want to know why it took the LDF Panel so long to come up with its (unpopular) recommendations, which has now resulted in EDDC being in the depths of a planning ‘nomansland’, with neither an up-to-date Local Plan, nor a draft Local Plan that is considered to have much weight attached to it, according to a recent planning inspector’s appeal report.

    The PAS report, at this time (2009), records a 5.2 year land supply in East Devon.  Many residents will also have questions over this, given there is now no five year land supply in the district with serious implications for the ability to control development, as a result.

    In paragraph A4, the PAS report makes further criticisms concerning the interaction between councillors on the LDF Panel and developers.

    It reports that councillors were meeting developers, apparently without officers being present (a dubious practice), undertaking site inspections and encouraging planning applications to come forward early, in advance of the completion of the LDF. 

    This, the PAS warned, could lead to early major planning applications that are departures from policy…. The warning of course came true, with two major applications at Westclyst and Axminster (Cloakham Lawns) being approved using a draft LDF just a few weeks old.  These two applications totalled more than 800 houses.

    The steer to these developers, states the PAS report, is being made without ‘scenario testing’ of other options, the use of sustainability appraisal and the assessment of how they fit in with the long-term vision.
    A further paragraph, which raises further questions, states that LDF Panel councillors appeared to be following “local agendas” rather than planning a long-term vision for the district.

    This PAS report gives a revealing and worrying insight into how this behind closed doors panel was operating.

    From reading the report it would appear that councillors on the LDF Panel may have wrested from the officers, control of the LDF process, turning the document into something that suited them … Unfortunately, five years later, every resident in East Devon is paying the price.

    During the LDF consultation process, starting in August 2010, a district wide campaign was launched against the LDF and its growth and weakened countryside protection policies. (I was a founder member of that campaign group – Communities Before Developers).

    In addition to this campaign and many residents objections, Natural England, Devon County Council and other key consultees strongly objected to the levels of growth and weakened protections for the countryside.

    As a result of the campaign and objections from key consultees, the LDF was withdrawn in 2011 and the adopted Local Plan used once again, as the primary document to determine planning applications.

    Following the 2011 elections I was appointed to the LDF Panel (of six councillors) to work on the revised plan, which would later come to be known as the Local Plan. 

    There had been a total of six councillors on the LDF Panel for many years.

    But shortly after my appointment, a further five councillors were appointed to the panel. This resulted in my proposals and arguments against the unevidenced level of growth, being outvoted virtually every time.

    A team of consultants – Roger Tym & Partners – were employed in 2011 to check the projections on housing and employment land.

    However, at our second meeting – on 2 July 2011 – the panel was railroaded by the chairman of the panel, into making a decision about the overall level of housing growth.  The recommendation was backed by the panel – to back 15,000 houses minimum – without the advice of EDDC’s consultants, Roger Tym, who did not submit their report until months later.

    Roger Tym submitted an interim report shortly after this meeting, but there were no recommendations published at this stage.

    When the final Roger Tym report was submitted some months later, the LDF Panel was informed by the head of planning that no one from the consultants were available to present their findings. 

    This was most frustrating and I had many questions because their report had outlined a very much lower level of growth than EDDC had outlined.  I rang the consultants and left a message to speak to one of the consultants. 

    But my call was not returned and I later received a message from EDDC’s head of planning policy asking me not to contact the consultants directly again.  This was not proper procedure, I was informed.

    This meant that no one from the LDF Panel was able to ask the consultants directly about any aspect of their report. 

    An unsatisfactory situation indeed.

    The level of development proposed in East Devon is vast, with the district proposed to be grown by about one third in just 15 years.

    However, independent evidence points to a significantly lower level of growth – both in housing and particularly in employment land. 

    Employment land proposals are particularly worrying, with two EDDC commissioned independent reports advising relatively low levels of growth, being set aside in favour of the views and wishes of major landowner-developers in East Devon.

    There has been much campaigning by East Devon residents, for well over two years, against the level of development proposed by EDDC.  This I am sure, will become very clear to you, during the Examination In Public.

    I very much hope (as do many many others in East Devon) that you will be able to find a way to reset East Devon on a path of realistic and achievable growth, that will not despoil our beautiful landscape, that our main industry – tourism – so relies on.

    This is so important, particularly in view of EDDC’s chaotic existing planning situation, following two planning appeal decisions ruling that EDDC could not demonstrate the required five year supply of land for housing.

    I have set out my own findings below, which are supported by robust evidence, below.

    Claire Wright
    Independent East Devon District Councillor
    Ottery St Mary Rural Ward

    ……………………………………………………………………………………………………………………….
    Spatial strategy 1 ® 6.36
    Housing – strategy 2 – scale and distribution ® 6.40
    The level of growth planned in the spatial strategy for both housing and employment land, is far in excess of what is required.
    The regional population projections (RSS) were produced at a time when the economy was booming and these proposals now represent an overly optimistic level of growth in East Devon, unlikely ever to be achieved in the plan period to 2026.

    The recession has had a significant impact on population change in East Devon and as a result there has already been far fewer people migrating to East Devon than would have, under a more buoyant economy.

    This trend is expected to continue well into the plan period and these findings are supported by EDDC’s own consultants, Roger Tym & Partners (RTP), commissioned in 2011.
    RTP criticises the ONS data as using a short-term population data period, taken from when the economy was booming, rather than using a more reliable 20 year average.

    Although at the time of producing this paper the most up-to-date ONS data is not available, RTP’s position is supported by the most recent census data from 2011, which shows in-migration to be significantly lower than as predicted by the last set of ONS population statistics.

    It would seem likely, that studying RTP’s table 4.2, that a projection along similar lines (given that the economy is still struggling) would be far more accurate.

    From studying RTP’s table 4.4, it is clear that East Devon’s net population has not grown as much as predicted – the population has grown by some 4000 fewer than projected by ONS reports.
    As a result, Roger Tym’s low migration scenario would be a far more accurate analysis of housing need in the district until 2026.

    The tough economic times are thought by economists generally to continue until at least 2014.  If this is so, then the projected numbers of dwellings in the plan, which do not seem to have been significantly trimmed from the levels envisaged when the UK was experiencing a buoyant economy, will not in fact all be required until several years after the end of the current plan period. 

    Not only is there huge Government debt, but consumer debt is truly enormous.  This in turn, will have an impact on banks being willing to loan mortgages and until debt starts to decline it is difficult to see the availability for loans for house purchase improving very much.

    Whichever way this issue is examined, it is clear that the level of in-migration to East Devon will remain subdued through much of the plan period. 

    There should be several thousand fewer houses proposed for East Devon in the EDLP, until 2026. 

    Calculations by the East Devon Campaign to Protect Rural England bear out this scenario, as do calculations by retired planning inspector, Peter Burdon, who has produced a compelling submission.  I strongly recommend that the planning inspector studies both of these submissions carefully.

    “The number of households cannot increase without an increase in the number of dwellings except by households sharing dwellings … So there is a danger that housing forecasts of additional households will involve a circular argument – they are used to justify increases in the housing stock but these increases enable the additional households to be formed, a type of self-fulfilling prophecy.” 
    Source: Roger Tym report, page 47, paragraph 4.25.

    Strategy 2 – scale and distribution of residential development (Overspill from Exeter) ® 6.40
    “In the absence of the RSS the planned overspill from Exeter should be treated as a planning decision jointly agreed between East Devon Council and Exeter City Council.  As we have shown in the historic migration patterns, there has been little previous net in-migration from Exeter to East Devon ….”  Roger Tym report, page 48
    COMMENT: I am unclear why East Devon has taken such a large amount of Exeter’s housing allocation, particularly in view of the sentence above. 

    This figure could be up to 8000 houses.  I note that Teignbridge District Council has taken only 2,000 from Exeter, and Mid Devon District Council has taken very little.  Presumably, Cranbrook will provide some houses for Exeter residents but this is a truly enormous number of houses to provide for another authority in a neighbouring district.

    Windfalls or unplanned development ® 6.41
    Windfalls are outlined in the Local Plan as 4000 over the plan period or 130 a year, taking the housing numbers up past 19,000.  This level of housing growth, seen in context with the rest of the housing allocations, will grow the district by around one third, in just 15 years. 

    There is an allowance in the National Planning Policy Framework for windfalls to be counted where there is confidence that they will come forward.  There is a good argument, in my view, for windfalls to be included in the main housing numbers of around 15,000, NOT in addition to.

    Employment land – ® 6.36,  ® 6.38
    I OBJECT to the vast amount of employment land proposed, which would appear to be at least two and a half times what is required in East Devon.
    In spite of a vast amount of sound evidence to the contrary, the enormous amount of employment land originally proposed in the Local Development Framework has not only remained, but in effect has grown due to new proposals for commercial or industrial units in villages. 

    From studying the Local Plan, as well as the EDDC’s consultants, the Roger Tym report, I have calculated the following:
    Total employment land allocated for East Devon in the Local Plan, appears to be at least 263ha or over 650 acres.
    Draft strategy 1– Overall spatial strategy for development in East Devon – states that the figure is 150 ha of which 122 ha will come forward through strategic allocations.  Oddly, this figure has markedly decreased from both the May 2012 consultation document and the December 2011 consultation document.

    I am unhappy that two columns that were present in the December 2011 consultation document, with information on commitments and employment land development between 2006 and 2011, have now been deleted.

    The amount of land committed for employment use, but undeveloped, was significant, totalling over 100 ha (or 250 acres).  According to the table printed in the December 2011 consultation draft Local Plan, this committed employment land is spread fairly equally across the district with 65 ha at the west end and around 40 ha in the rest of East Devon. 

    In the December 2011 consultation document the overall number hectares allocated for employment land totalled around 180 ha.  In the current December 2012 consultation document the figure has mysteriously dropped by 30 ha to 150 ha.  In other words around 75 acres of employment land has gone missing, but where?  From studying the current table, compared with the December 2011 table, I remain unclear.

    What is clear, however, is that there is over 100 ha of land previously committed for employment use, but not yet developed.  This raises a serious question over the justification of the amount of employment land allocated in the draft local plan.

    I don’t have faith in the numbers relating to employment land printed on page 34 ® 6.38.  There is more land than this proposed for employment use, but not all of it is counted in the figures. 
    Taking the housing evidenced need into account, as outlined above, and the vast oversupply of employment land, even for the higher growth set out in EDDC’s Local Plan the only sensible recourse is for the council to radically reduce the amount of employment land allocated.

    From studying page 79 in the Roger Tym East Devon Housing and Employment Study 2011 report, and comparing the list of developments in the west end with the EDDC draft Local Plan chapter on the west end at ® 6.56 it appears that not all the developments that will provide significant levels of employment are counted in the Local Plan figures.

    ® 6.66 I OBJECT to the Sainsbury’s distribution centre figure not being included in the overall figures for employment land. (I have included in this figure in my own calculations).  The warehouses total around 65ha, according to consultants, Roger Tym.  Roger Tym consultants have included this development in their own calculations for employment land.

    It is important to NOTE that: 
    – this distribution centre will reportedly will provide hundreds of jobs.
    –  a 160 bedroom hotel has already been given planning consent.  Presumably this will also provide very many jobs. 
    – a combined heat and power plant has also been given planning permission.  This will provide many jobs.
    Intermodal freight terminal ® 6.59

    It was very disappointing to see Sainsbury’s given permission to occupy the 65 hectare (163 acres) distribution centre next to the freight terminal, without the funding to enable the rail junction.  The rail junction was a stated priority in the existing Local Plan and Sainsbury’s should have been asked to sign a Section 106 agreement in order to provide the funding to build it.  The huge distribution centre, which will serve the south west, will generate an enormous amount of lorry movements each day.
    I PROPOSE that the rail junction be given absolute priority and is funded and completed as soon as possible.

    Roger Tym advises reductions for all towns and at the west end in employment land for sound economic reasons.  Aside from spoiling our countryside and turning East Devon into a district with a focus on a light-industrial industry, Roger Tym confirms that too much provision of employment land will have the opposite effect of job creation and instead, depress the market.

    ® 6.36, ® 6.38 Page 36 of the Roger Tym East Devon Housing and Employment Study 2011, paragraph 3.62 states:  “A common misunderstanding is that because unemployment has increased we need to provide more development land to build more economic floorspace, so planners should be allocating more land.  However, in reality, we probably want to do the exact opposite.  This is because the floorspace vacated in the recession is still available for occupation and therefore, the physical space capacity to employ people has not been taken away.”

    “The recession has undermined developer confidence and the vacant space depressed values.  Adding further supply to allocating too much new land may only depress values further and undermine market confidence.”

    ® 6.36, ® 6.38 Independent Atkins Report 2007
    In 2007 EDDC commissioned Atkins, at a cost of £30,000, to independently assess the need for employment land in the district.  Atkins concluded that there was only a slight undersupply of employment land in East Devon, mainly due to the large number of unoccupied premises. 

    Roger Tym consultants were commissioned in 2011 at a cost of £25,000 to assess the demand for future housing and employment.

    ® 6.36, ® 6.38 East Devon Business Forum involvement
    From carefully studying the information that has led to the employment land proposals in the draft Local Plan I have concluded that the only piece of evidence relied upon by EDDC to justify its position, is a Task and Finish Forum (TAFF) report from East Devon Business Forum (EDBF), which was then adopted by the Corporate Overview Committee and Cabinet in 2007 and submitted as evidence for the Local Development Framework process. 

    It therefore seems likely that the views of landowners and developers on EDBF led directly to these proposals. 

    During the Local Development Framework Panel meeting on 30 August 2011, when employment land was discussed, EDDC Business Development Manager, Nigel Harrison, defended the 2007 EDBF Employment Land Task and Finish report on the basis that the list of land submitted with the report had helped him determine the ‘immediacy’ of available land or units, when receiving phone calls from businesses.

    As I said at this 30 August meeting, Mr Harrison’s statement does not justify using this information, which was not independent, for the Local Development Framework and subsequent Local Plan, which is strategically planning for at least 15 years. 

    In 2007, the landowners and developers on EDBF examined and dismissed the independent Atkins employment report in 2007, as ‘fundamentally flawed’.  EDBF subsequently submitted its own findings to EDDC – the Employment Land Task and Finish Report, which claimed that only 6 ha of employment land was available in the district.

    At the EDBF meeting on 9 August 2007 the EDBF chairman informed the meeting he had gained support for EDBF’s stance on the Atkins report.  The minutes state:
    “The Chairman advised that he had made a presentation to the Corporate Overview Committee on 26 July 2007 on the issue of the Atkins Report and employment land supply within the district. Members of the Corporate Overview Committee had fully supported the view that the findings of the Atkins report were fundamentally flawed and that there was a lack of employment land within the District.”

    Subsequently, the minutes from the EDBF AGM on 31 January 2008 states: “Members (of the Corporate Overview Cttee) noted that the work the Business Forum had done on the Atkins Report had made an enormous difference to the final report prepared by the Employment Land issues Task and Finish Forum.  The report was now being used by the Development Control Committee as a base when considering planning applications for employment land.” 

    And in the same EDBF minutes:  “It was noted that the report would help set an agenda to inform future employment land provision in respect to future planning policy and development decisions (particularly in relation to land supply shortfalls).”

    22 November 2007 – Corporate Overview Committee meeting minutes conclusions and recommendations:
    that the Employment Land issues Task and Finish Forum report and more detailed evidence be used to:
    a) help inform production of the issues and options report for the East Devon Core Strategy and also;
    b) that the Development Control Committee take full account of employment land availability issues when considering planning applications.

    Given that this work was carried out by major landowner-developers, these findings cannot be described as independent. 
    The report produced should NOT have been used to form the basis of evidence for strategic employment land provision in the Local Development Framework.  Nor should the evidence have been retained and used as evidence in the Local Plan.

    This sequence of meetings and decisions led directly to a series of major application approvals that were contrary to planning policy.  Many of the approvals were on EDBF members land. However, despite the expansions being described as necessary and vital, it appears that much of the land allocated under these departure approvals, has NOT yet been developed.

    Net out-commuting v out-commuting
    Adding additional areas of land to the amount of allocated employment land in the local plan in the hope of reducing out-commuting from towns for employment purposes would appear to have caused some double-counting. 

    A number of those out-commuting from one town will be commuting to another East Devon town, so that much of the additional land provided for this purpose is unlikely to be utilised. 
    If a worker is attracted to a job created on new land in their home town, their old job in the other town will become vacant.  If it is filled by a local from the other town who might have previously been travelling to another East Devon town, he will not need new employment land to give him a home town job.  The same applies for the opposite commute.  There is therefore no basis for providing additional employment land for this purpose on the scale proposed.

    Allocations for retail, hotel and catering, and health and social institutions, are normally the subject of specially designated allocations.  These may be expected to come forward as needed and be controlled under separate and specific Local Plan policies.  It is not normal practice to allocate such land in this way. Such allocations should be deleted from the non-B class employment land allocations.

    Devon County Council view
    During the preferred approach Local Development Framework consultation in autumn 2010, Devon County Council in their submission, stated that the proposals for employment land were so excessive that a planning inspector at the examination in public, may find them ‘unsound.’

    Dorset County Council has likewise expressed ‘serious concern’ over the level of employment land proposed, in the EDDC Local Plan consultation of December 2011.  DCC representative, Gill Smith, quotes from the Roger Tym report to underline her point.

    Under the National Planning Policy Framework, par 22, it states: “Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.” 

    The dangers inherent in this policy coupled with EDDC’s significant oversupply of employment land, as well as the government’s clear direction on housing growth above all other considerations, must be blatantly obvious for all to see.
    PROPOSAL: Adopt the independent advice of Atkins, of Roger Tym and of Dorset County Council in relation to employment land and substantially reduce the employment land provision.

    Unemployment
    The figures used by Roger Tym on unemployment – over seven per cent in East Devon are not reliable as they are extrapolated by the Office of National Statistics. 
    A far more accurate source of the data and one that the Local Plan should be founded on, and is also used by Devon County Council, is from the District Claimant Count rate – those people claiming job seekers allowance. 

    In East Devon the unemployment figure is only just over 1.5 per cent and is the lowest of all the districts in Devon. See link (dated December 2012) below: http://www.devonomics.info/people/monthly-jsa-analysis-claimants

    Empty units
    According to EDDC’s own records there are around 400 empty commercial and industrial units in East Devon.  The work of East Devon Business Forum, which forms the basis of the employment land allocations in the Local Plan, did NOT take into account empty units, according to the Employment Land TAFF report, published for consideration by the Corporate Overview Committee in November 2007.

    Strategy 31 – Employment land in villages ® 6.154
    I will refer to the policies more closely under the relevant section but in principle I totally oppose these policies.  The evidence against the level of employment land proposed across the district is now overwhelming.  There is no justification whatsoever to allocate even more of this land in villages. 

    The policies are loosely defined and there need be no justification to build warehouse or industrial units.  Certainly residents in my ward – Ottery St Mary Rural – are very opposed to this sort of development, according to consultation responses received by Ottery St Mary Town Council.

    Under the National Planning Policy Framework (NPPF) empty units can be converted into housing if a developer or landowner can prove there is an oversupply of units nearby or that the land has not been developed.  Given the arguments set out above, I imagine that this would be quite an easy thing to prove!

    ® 6.154, ® 6.227 D1 – Design and Local distinctiveness – The concept of industrial development in villages is a significant change in local planning policy and if plans are endorsed they are likely to damage village attractiveness and distinctiveness.  Why would we wish to pave the way for industrial estates on the edges of villages?
    I OBJECT to the principle of business parks or industrial estates being created in, or next to, villages.

    ® 6.118 Strategy 24 – development at Ottery St Mary
    There is too much development proposed for Ottery St Mary and it is out of proportion compared with its population and other towns in the district. 

    A recent planning appeal on land next to Butts Road for 130 dwellings, will increase (with the remaining allocations), the housing in the town by almost one quarter (22 per cent) in less than 15 years.  This is a far bigger percentage than any other town, apart from Axminster.

    The planning appeal was on land to the EAST of the town. Everyone, including ward members, Ottery St Mary Town Council, many members of the public and EDDC had agreed that development should take place on the WEST side of the town.

    Ottery St Mary Town Council stated in its submission to the LDF Panel of September 2011, that a maximum of 300 houses were appropriate for the town, which was eventually agreed.  But the appeal decision means that Ottery is now scheduled to receive well over 400 houses, which will swamp local infrastructure such as schools, health services, sports facilities and the sewage system (all already over capacity).
    PROPOSAL: Delete the strategic allocation at Island Farm for up to 180 dwellings, which is on grade 2 agricultural land and is on land beyond the flood plain, moving the town up the hill towards West Hill.

    Ottery St Mary employment land ® 6.118
    There are four hectares of industrial/commercial land already committed but not developed at Ottery.  The Local Plan has arbitrarily allocated a further two (reduced from three). 
    Roger Tym consultants, however recommend on p77 of their report that an additional 0.67ha should be ‘more than sufficient to create capacity for future development in Ottery St Mary.’
    PROPOSAL: Adopt Roger Tym’s advice in relation to Ottery St Mary, for an additional 0.67ha only of employment land.

    Feniton to Ottery to Tipton to Sidmouth cycleway – ® 6.117 – ERROR
    the references to the cycleway should read as above.  NOT, as in the Local Plan, simply Ottery St Mary to Tipton St John.

    Health services
    An agreement was recorded at a Local Development Framework Panel meeting on 28 February 2012, stating “The health consortia (Wakely and WEB) would be consulted upon planning applications with clear health/welfare implications, such as major housing applications.”

    However, I cannot find this statement anywhere in planning policy.  It would appear to be most appropriate to be included in the infrastructure policy.
    PROPOSAL:  Include the above statement (in quotes) in a Local Plan policy statement, preferably Strategy 50 – Infrastructure Delivery: ®6.220

    Local health services are under significant strain already, according to GPs from Coleridge Medical Centre, who fear more houses on the basis that they are only just about coping with demand now.  The level of development proposed will completely swamp health services and I really worry about the implications for local residents, of an inundated health system that is unable to cope with demand.

    STRATEGIC POLICIES
    Draft strategy 27 – Development at the small towns and larger villages – ®6.142
    The policy of one job per home is excessive, overly prescriptive and inappropriate.  Population data clearly shows that the majority of people who move here, do so to retire – see p63 of the Roger Tym East Devon Housing and Employment Study 2011.

    Draft strategy 33 – promotion of tourism in East Devon – ®6.159
    There should be greater emphasis on encouraging green tourism, such as creation of cycleways.  These sorts of projects complement East Devon’s rural nature as well as providing economic benefit to a wide range of businesses. 

    ®6.159 On earlier drafts of the Local Plan it is clear that residents support this view.  The consultation draft dated December 2011 stated in the ‘what you said about landscape and AONBs’ that residents want investment in green tourism, which secures the management of natural features and enhances their value for local people and visitors.
    I PROPOSE that green tourism is prioritised in the tourism strategy

    Draft Strategy 34 – district wide affordable housing provision targets ®6.161
    I OBJECT to this policy.  Economic conditions for providing affordable housing for landowners should be taken into consideration, however it should not be the only issue.  Building more affordable homes (50 per cent of all developments) in rural areas where community facilities, shopping, work and transport is likely to be much scarcer, is contrary to national policy relating to sustainability. 
    I PROPOSE that EDDC should build a higher percentage of affordable houses in towns and a lower percentage in rural villages.

    Draft strategy 36 – lifetime homes and extra care homes ®6.167
    This provision should be INCLUDED as part of the overall housing numbers in towns and villages, not in addition to.  If in addition to, it needs to be expressed as part of the housing tables for towns and villages, otherwise it is a hidden number and subsequently the housing tables are misleading.

    Draft strategy 47 – nature conservation and geology ®6.209
    I OBJECT to this policy.  Local, county and regionally designated sites are missing from this list.  East Devon has 8 local nature reserves, 270 county wildlife sites and 21 regionally important geological sites – a very large number of sites that need adequate protection from development.  I PROPOSE that the wildlife sites stated above should be included in this policy.

    Draft strategy 50 – infrastructure delivery ®6.220
    The following minute was recorded at a Local Development Framework Panel meeting on 28 February 2012:  “The health consortia (Wakely and WEB) would be consulted upon planning applications with clear health/welfare implications, such as major housing applications.”  This text should be included in this policy.

    Development management policies ®6.249
    Policy EN4 – protection of Local Nature Reserves, County Wildlife Sites and County Geological Sites
    I OBJECT to this policy.  These wildlife sites should be given far more protection and should be included in draft strategy 47.  If this is not agreed then I would like these sites given the same protection as in policy EN3 – amenity land – where they are developed only if there is a clear community need.

    Policy EN5 – wildlife habitats and features ®6.250
    I OBJECT to this policy.  I would like to see the first two words removed – ‘wherever possible’ – as they constitute a large loophole.  And also the first three words of the next sentence should be removed – ‘where potential arises’ – as they constitute another loophole.  The policy should be clear and unambiguous.

    Policy E5 – small scale economic development in rural areas ®6.324
    I OBJECT to this policy.  Allowing this sort of development outside built-up area boundaries is a dangerous road to go down.  These units are entirely unnecessary, given the evidence relating to the overprovision of employment land in the district, as well as the large number of empty units.  Over time these units are likely to be extended and the result is industrial estates or business parks in villages, which would clearly be damaging to the character and distinctiveness of East Devon villages.  My concerns over conversion into housing also remain.
    Proposals are likely to increase traffic in villages as more people travel to rural areas to work.  Clearly, this is also undesirable.

    Policy E6 – new employment provision in association with residential development ®6.326
    I OBJECT to this policy.  Employment provision for every 10 homes built is entirely unnecessary and overly prescriptive when the statistics clearly outline most incomers are retiring.
    PROPOSAL:  Insert the words:  “or financial contribution” after “we will require” in the second line, to give developers an alternative and far more sensible option.  This approach would also be in line with
    strategy 31 (®6.154)

    Policy E7 – Extensions to existing employment sites ®6.328
    I OBJECT to this policy.  Allowing industrial estates or business parks to expand by 10 per cent once they are 80 per cent occupied is nonsensical and will damage the countryside unnecessarily.  How would the claims of landowners or developers be monitored or checked?  The policy is weak in controls, open to abuse, not justified and should be discarded. 

    Policy SH10 – Retail development in rural areas outside built up area boundaries ®6.344
    I OBJECT to this policy.  It is too loose and could be open to abuse. According to Richard Eley of the Sidmouth Chamber of Commerce, in his submission to LDF Panel, dated 27 September 2011, EDDC already has one of the loosest criteria in the country for controlling farm shops. Mr Eley estimates that there are now more than a hundred ‘farm shops’ operating in East Devon, and at least half of these are operating, without complying with agreed conditions.

    Within perhaps five years, he fears, most of these operations will have acquired a lawful use and Mr Eley fears will be potentially developable into large scale retailing operations. This development would be unplanned and the consequences for town centres would be serious. As many of these businesses are operating on our main roads and tourist routes, the impact upon the appearance of our countryside would be considerable.  I PROPOSE that this policy should be tightened so that 90 per cent of goods sold in these rural shops are from the farm or local to the district.  A strict enforcement policy should also apply. 

    Policy TO6 – Provision of visitor attractions ®6.354
    I PROPOSE that a further point should be added – point 6 should read ‘it would not use the best and most versatile agricultural land.’

    Other policies that do not appear to be included ®6.287
    Justification for development of barns or agricultural buildings in the open countryside.  Current planning policy stipulates that there must be justification provided for building agricultural buildings, such as barns, in the open countryside.  I cannot see this policy in the new Local Plan.  I PROPOSE it is retained.
    Also, the policy that relates to barn conversions.  Currently barns must be worthy of conversion – structurally sound, for example.  I cannot find this policy either.  I PROPOSE it is retained.

    ®6.192 Alfington – ERROR
    In Appendix C – schedule of housing sites and housing numbers – the number of houses allocated for Alfington is stated as eight.  This is INCORRECT.  It should be five.

    ®6.192 Aylesbeare – ERROR

    In Appendix C – schedule of housing sites and housing numbers – the number of houses allocated for Aylesbeare is 50.  This is INCORRECT.  It should be five.

    Tourism (general comments) ®6.345
    Tourism could be linked to around 32 per cent of the East Devon economy (a significant form of income), according to the Tym report (Table 2.5 on P9). In many east Devon shops, tourist expenditure could be around 50 per cent of total turnover.

    The household income figures released by Devon County Council have shown that the economy of many other East Devon towns cannot be sustained alone by the spend of residents.  For town centres to survive it can only be possible through the boost provided by tourism. We need all-year-round tourism, and we need high-value tourism.

    I share the worry of Richard Eley that recent statistics from South West Tourism show East Devon tourism going downmarket faster than any other district in the region. While other authorities have encouraged hotel investment, upmarket restaurants and quality attractions, EDDC has opted for mass tourism such as holiday camps as the focus for tourism policy. 

    High quality restaurants and hotels, as well as green tourism should be the focus for EDDC’s tourist policies.  This gives the biggest boost to the most number of local businesses and is line with East Devon’s natural assets.

    The more we pursue an increasingly industrial future for East Devon by over-allocating employment sites the more we put at risk our natural economy – our tourist industry.

    The evidence is overwhelming that people visit East Devon for its countryside.  This needs to be nurtured and protected. 

    To continue along the path set down by the Local Plan could easily jeopardise the backbone of our economy.  Trying to secure a successful economy is at the heart of the policies within the National Planning Policy Framework, which this Local Plan must comply with.