A plan to build thousands of new houses across East Devon was unveiled last week, with proposals for specific areas in the county.
I have since spent time talking with strategic planning officers to try and understand the detail of the national policy driving this.
Strategic planning is technical and complicated and takes some learning. I was heavily involved in strategic planning while a councillor on East Devon District Council between 2011 and 2015, so I felt compelled to examine this new plan and its proposals.
I will endeavour to explain my findings below!
Government housing policy
The GESP refers to a target of 53,260 houses to be built across East Devon, Exeter, Mid Devon and Teignbridge between 2020 and 2040.
Each planning authority has been instructed by central government how many houses they must build, based on Office of National Statistics data on births and deaths.
The GESP headline housing number has taken account of local planning consents already in the system and those developments already built out in the existing Local Plans, so these are deleted from the original government requirement.
But it’s not that simple.
Ministers have theorised that the more houses that are built the more that prices will be brought down… so each planning authority is instructed to apply a percentage increase (also set by central government and varying widely from authority to authority) to the ONS figures, based on people’s average incomes versus average house prices.
In East Devon this gap has historically been very wide, so, East Devon District Council has had a comparatively high affordability uplift applied.
This might sound sensible except that the theory is surely flawed. I have not seen a shred of evidence that building lots of houses brings down prices. It simply makes more money for landowners and developers!
This policy appears to have nothing to do with true affordability, nor will it tackle the amount of developers (between 40 and 50 per cent approximately) that are granted large scale consents, then afterwards argue viability issues and end up getting the social housing element of the development reduced (because planning authorities usually can’t afford a legal fight against a national housing developer).
Housing proposal breakdown across the four districts (per year)
The total GESP housing number breakdown by authority/per year, including the ‘affordability uplift’ is set out below:
East Devon -900
Exeter – 638
Mid Devon – 364
Teignbridge – 760
GESP area – 2663
This can be seen under ‘Local Housing Needs Assessment’ here – https://www.gesp.org.uk/evidence/
Affordable/social housing element within GESP
As yet, affordable housing ratios have not been agreed and will emerge through the consultation process, assuming the document is approved for consultation in each authority.
We need more housing, especially social housing, but what so often happens with these sorts of plans is that the intention is there by the planning authority, but the reality differs once developers use national planning policy loopholes to their advantage and claim the scheme is unviable once they are granted consent by the cash strapped planning authority.
Or they may claim that not enough houses are being built and obtain consent that way. This is a technical land supply argument if the build rates slip below a certain figure and usually not the fault of the planning authority at all but of the classic developer tactic of landbanking for profit!
One of my many frustrations of the planning system, is that it is weighted in favour of developers, with loopholes running right through national planning policy that simply result in lengthy appeals, or planning authorities capitulating on inappropriate schemes simply because they know they don’t have the resources to fight an expensive public inquiry appeal.
Given that around 40 to 50 per cent of large scale housing applications end up being brought back to planning committees with developers pleading poverty over affordable housing, the government would do better to focus on tightening up the rules in the National Planning Framework to ensure developers cannot wriggle out of such commitments.
Developers fund the Conservative Party
But of course developers historically provide generous funds for the Conservative Party, which saw its coffers swell considerably after the 2012 planning reforms.
The recent Jenrick planning scandal confirms that nothing appears to have changed. I live in hope that it will but given that there seems to be little or no accountability in this government, people need to vote with these issues in mind in elections before anything changes.
The employment land con
Employment land (read industrial estates/business parks) is usually fields allocated for industrial or business park use.
For employment land there is acknowledgement that there are long term vacancies at many existing sites, such as at Skypark, near Exeter Airport, which is barely developed despite being heavily marketed as a flagship business park for years.
If Skypark can’t attract occupants, with its J30/M5 prime location, how can less prominent allocations possibly?
The employment land policy doesn’t take account of home working (especially now), online working or the change in working practices over recent years. Or that many people do not work in business parks or industrial estates in any case!
I did a survey of every single industrial estate/business park in East Devon back in 2011when I was involved in strategic planning – and found that most had significant numbers of empty units. Yet that didn’t prevent a vast amount more land being gobbled up by warehousing allocations in the 2016 adopted Local Plan, despite many people making these logical arguments during the many consultations!
The approach causes unnecessary concreting over of green fields and with it, important trees , woodlands and nature.
Police investigation into planning in East Devon, in 2013
Over the years a small number of local landowners achieved massive extensions to their existing East Devon sites, contrary to planning policy at the time. They then achieved even greater extensions in the existing Local Plan.
This (and other issues) during the preparation of the existing EDDC Local Plan, resulted in a police investigation in 2013, following a sting operation by two undercover Daily Telegraph journalists. The story was front page news under the heading ‘Councillors for Hire.’
East Devon District Council reported the councillor in the Telegraph story, to the police under the Corruption and Bribery Act. And the man, who died last year, was forced to resign. The police investigation was shelved after a few months, citing lack of evidence.
When the police investigation was dropped I was named by the chief executive as the key witness, in a council press release.
But my point here is that it’s blindingly obvious that the ‘employment land’ planning model is outdated and outmoded. And seems little more than a vehicle for many landowners to increase the price of their fields with an eye on the ultimate prize of housing.
Areas of Outstanding Natural Beauty
Two thirds of East Devon is designated an Area of Outstanding Natural Beauty – The Blackdown Hills AONB and the East Devon AONB. It’s harder to get consent in AONBs and developers must pay more attention to design and build to ensure it doesn’t detract from the attractiveness of the setting.
So this is why the area closest to Exeter – the so called ‘West End’ of the district always seems to contain the vast majority of the development whenever there is a new strategic development plan in the offing.
The pressure on this area, especially services, such as schools and roads, is growing.
Who leads this work?
The GESP work is being supported by Devon County Council officers, however it is being led by the local district councils.
I am informed by officers that the GESP will only carry weight once it has been through a public consultation process and feedback has been considered.
Currently, although a published document, it carries no weight in planning terms, so cannot be used to determine planning applications.
If the GESP is approved, it will exist concurrently alongside Local Plans of each district, which run until 2031. EDDC’s Local Plan was adopted in 2016, plans for 17,100 houses and runs to 2031.
The document has over-allocated land by 20 per cent, in case it doesn’t all come forward.
There is a chapter on the climate emergency and there are a range of what appears to be relatively robust policies relating to reducing the impact of climate change, including energy storage, onshore wind, solar pv, and development that achieves net zero carbon development.
The document states that approximately 12.5% of the GESP area is currently covered by recognised woodland (National Woodland Inventory), which equates to approximately 27,000 hectares. This is broadly consistent with the national average for England of 13% coverage, which is three times lower than the European average of 37% and makes the UK one of the least wooded countries in the continent.
It adds: “10,000 hectares of new woodland will be created within the GESP area by 2040. The Councils will seek to encourage or deliver appropriate woodland creation in areas identified in Figure 9.1 as offering the highest opportunity to expand and connect existing woodland. Development proposals located within these areas of higher priority will maximise opportunities to undertake woodland creation.”
Planning officers have informed me: “We currently have approximately 27,000 ha of recognised woodland in the GESP area. By 2040 we want to increase this to a total of 37,000 ha, in line with recommendations from the Committee on Climate Change. “
That doesn’t of course mean there won’t be a huge loss of individual trees, small groups of trees and hedgerows, given that the vast majority of development is planned for agricultural land.
- The definition of woodland is a minimum area of 0.5 hectares with tree crown cover of more than 20% of the ground.
The link below goes to the documents used as evidence for the GESP.
The proposals below are for East Devon specifically:
Proposal: 1,300 dwellings plus industrial/business use
Location: Farmland adjacent to the A3052 to its highest point at the top of Windmill Hill. Adjoins Crealy Adventure Park to the west and Greendale Business Park to the south.
Area: 107 hectares
Proposal: 10,000 houses plus industrial use
Location: A large area of farmland extending from the A30 to the A3052. Adjoins Hill Barton industrial area to the south.
Area: 660 hectares
Oil Mill Lane
Proposal: 4,000 dwellings plus industrial/business use
Location: A large area of farmland extending from the A3052 to Woodbury Road. Adjoins Crealy Adventure Park to the north-east.
Area: 380 hectares
Proposal: Motorway Services Area (this is a possible relocation of the services at J30 of the M5, in order to build housing on that site).
Location: A series of agricultural fields towards the River Clyst. The M5 passes north-south through its centre and Poltimore and Broadclyst are 400m to the west and east respectively.
Area: 44.3 hectares
Proposal: 1,050 dwellings with possible business/industrial use
Location: Lies between west of J30 of the M5 motorway. Includes motorway service station.
Area: 36 hectares
Proposal: Industrial/business use. Extension to existing Science Park
Location: An area of land adjoining the A30 and close to Junction 29 of the M5. The site slopes east to west towards the River Clyst. The village of Sowton is situated adjacent to the south.
Area: 30 hectares
Topsham and M5
Proposal: 1,500 houses (permissions already exist for 286 dwellings, two care homes and 47 assisted living apartments)
Location: Between the M5 and Topsham and approximately 5 km from Exeter city centre.
Area: 95 hectares
Westclyst and Mosshayne
Proposal: 1,600 dwellings and possible industrial/business use
Location: Agricultural land and marshland surrounded by the M5 motorway, railway and the River Clyst.
Area: 117 hectares
Proposal: 540 dwellings and small scale business/industrial
Location: A rectangular shaped site adjacent to the southeast of the existing built-up area of Axminster. It is currently in agricultural use and includes farm buildings and a small number of houses. The site is bounded to the south by the A35, the west by the A358 and the north by Woodbury Lane.
Area: 54 hectares
Proposal: 2,800 dwellings and business/industrial
Location: Predominantly agricultural land surrounding the village of Feniton, on both sides of the railway
Area: 352 hectares
Proposal: 1,100 dwellings plus small scale business/industrial
Location: Agricultural land to the east of Honiton situated primarily on land rising towards and surrounded by the Blackdown Hills and East Devon Areas of Outstanding Natural Beauty. Site is sandwiched between the A35, Exeter Waterloo railway line and the A30.
Area: 73 hectares
Proposal: 2,500 dwellings and business/industrial
Location: Predominantly agricultural land to the north and east of the village of Whimple, located on both sides of the railway.
Area: 242 hectares
Exeter Airport Business Park
Proposal: Business/industrial use
Location: Agricultural land sandwiched between Exeter airport and the A30
Area: 27 hectares
Exeter Airport North
Location: Within active airfield uses and hosting supporting infrastructure on the north side of the runway at Exeter Airport, south of Skypark and Cranbrook’s proposed southern expansion area
Area: 22 hectares