Sunday, 16 February 2014

Public Examination of the New East Devon Local Plan ..... ..... EMPLOYMENT LAND

As well as voicing concerns about the over-provision for housing in the Local Plan:
Futures Forum: Public Examination of the New East Devon Local Plan ... housing: numbers much too low for developers... much too high for CPRE
Dr Margaret Hall of the CPRE questioned the amount of employment land proposed:

Dr Hall said the branch remained “unconvinced” by the council’s recommendation for 64 hectares of employment land – double the recommendation made in the Roger Tym Report which was commissioned by the council in 2011 to assess the amount of employment land needed. Dr Hall raised concerns that its provision will not be met by redeveloping quality Brownfield sites but by building on Greenfield sites. She explained that if there ends up being an over-provision of employment land, there is the potential of it being used for more houses instead.

East Devon branch of Campaign to Protect Rural England raise concerns over amount of development planned across the district | Exeter Express and Echo


This was one key comment, by Dr Margaret Hall of CPRE, put to the Inspector for consideration, as the Examination in Public (EiP) of the Local Plan continued today.

Today’s focus was on the amount and the distribution of employment provision in East Devon District Council’s new Plan.

For reference, a glimpse of existing employment sites is here:

Here is a very prescient observation about the whole process of how much employment land was included in the draft Local Plan - from 31st August 2010:

Yesterday, I made yet another forey into “The Woodshed” from whence something nasty comes in the book Cold Comfort Farm (see below), otherwise known as The Knowle, ancient seat of East Devon District Council. My reason: to see how the thorny question of employment would be handled at the Local Development Framework Panel meeting.

I made my small, humble contribution, asking why the only two reports which had ever been submitted to the former LDF Panel managed to reach such different conclusions. One by Atkins (consultants employed by EDDC who have done lots of these things, some in Devon) said that in 2007 (yes, isn’t it a long time ago) there was about 88 hectares of employment land available. This report was savaged by our old friends in the East Devon Business Forum which said there was only 6 ha available not 88 ha and MUCH more industrial land was needed (with EDBF members no doubt happy to help find the land to put in the pot that they say needed filling to the brim).

I pointed out that the EDDC “Task and Finish” group which was set up to examine these two reports was eerily similar to the EDBF membership, Councillor Brown being in both groups (Chairman of EDBF and representing the National Farmers Union not EDDC at the EDBF), Councillor Goddard (EDDC rep to the EDBF) and Councillor Ingham (who seems to have been the only one with no previous connection to the EDBF). Who guards the guards? I am investigating exactly which other councillors were on the TAFF and hope to have the information shortly.

I asked if EDDC could clarify exactly who was on their Task and Finish group, since I can find no documentation that actually lists its members (confusingly, its reports only speaks of councillors present at meetings but does not list which of those councillors were members of the Task and Finish group). I also asked, given the big discrepancy between 88 ha and 6 ha just how much weight was going to be given to each report?

Sad to say, I didn’t really get a straight answert to either question. However, Nigel Harrison (EDDC’s Economic Development Manager and the raporteur for EDBF, (which is mostly if not wholly funded by EDDC, by the way) did provide some clarification of one thing. The 6 ha of the EDBF was (I am paraphrasing very slightly here) “land where if someone rings me up and asks where there is 50,000 sq ft of employment land available now, I can tell them where it is”. So, it’s just a snapshot of what is available on a particular day. Funny then that it should form the basis of evidence for an LDF supposed to last from now to 2026 but no-one mentioned or queried exactly what it represented!

Councillor Brown said that he was upset that I had brought this up as he had “talked to me about it” before. I made it VERY clear to everyone assembled that, to my knowledge, I had NEVER discussed this with him, so one of us obviously has memory problems.

So, here we are, 88 ha and 6 ha. What to do? Fear not, Mrs Little has a plan. ANOTHER report, this time by Roger Tym (the same people who have done the housing report). And will this one be reliable? Well, no-one seemed to be able to say as they could not decide (and had never previously decided it seems) (a) what actually constitutes employment land and (b) whether it should just be square metres or whether location, quality and availability should also be included. It led to a very unsatisfactory decision to basically “wait and see”. I’m not sure what for or how long but that was the decision.

So, how much employment land DO we need? Hectares and hectares if you believe EDDC and EDBF. Councillor Skinner pointed out that these are recession years, so we should not be taking current levels of interest or need into account, since things can only get better. However, this one was swiftly demolished by Councillor Giles (from the floor) who pointed out that in the EDDC agenda documents in front of us all it stated that only 32 h (AVERAGE 2 ha per year) extra of employment land had been required over the last 16 years, some of which have been the boomiest ever!!! This led to a rather odd contribution from the Leader of EDDC, Councillor Diviani who said (paraphrase again) well, if I have 70 seat restaurant I don’t expect it to be a sell out every night but occasionally I might seat 70. Which seems to mean: lets have lots an lots of empty industrial units because one day we might need it! But just because you have a 70 seat restaurant doesn’t mean that you might ever seat 70 – surely it depends on the price and quality of the food and the location of the restaurant! Back to the drawing board, though no-one can decide what the drawing board … no let’s not go there.

Other nuggets: the guy from Skypark said: if you insist on including masses of sites in East Devon like all the people in suits here want we have a problem as the oversupply could mean that we will not be able to develop Skypark! There were quite a few developers or planning agents there in their smart suits, one of whom made a great hit with the Chairman who fulsomely complimented him twice on two different presentations for two local developers.

And what about the airport – where they say they are going to provide 2,500 jobs on 15 ha of land – and the inter-modal freight facility – where they say they might, but only might, have around 400 jobs? Is this employment land? Is it counted by East Devon in the LDF? Er, no. Why? Because it isn’t East Devon that is bringing these project forward! Employment land: it walks like a duck, it quacks like a duck, it looks like a duck, but it isn’t a duck because it’s not OUR duck.

Tip: no point in reading the press release sent out by EDDC after the meeting. In my humble opinion it bore no resemblance to the meeting at all. Indeed, reading it, I am more and more convinced that EDDC and I live in parallel universes!

Employment Land | Sidmouth Independent News

A comment at the SIN blog compared numbers:

Yesterday, the Employment Land Supply figures below were presented to the East Devon Local Plan inspector. 

We can see, despite a 5 year interval, the figures given by the independent experts Atkins and Tyms for the rest of ED are similar 

- ie 50% less than the EDDC Local Plan 2013 estimate. 

(Note how after the TAFF 2007 report the figures were inflated!)

Source: Total Hectares: West End:  Rest:  ED
Atkins 2006:                         124:  90:    34
LDF 2010:                             186: 111:   75
LD 2011:                               180:  87:    93
Roger Tym’s 2011:                 133: 101:   32
Local Plan 2013:        192(incl IM): 122(incl IM): 68

(Note: IM = Intermodal Freight Interchange = 44Ha)

And a blog entry from Independent Councillor Claire Wright - from 2nd November 2011:

An interesting submission to the draft Local Plan which made similar points:

This is the District Council's paper on Employment Land from 2013:

Here is an extensive report from last Thursday's session:

Consensus on “excessive” levels of industrial land - almost

Thursday, 13 February 2014 1 Comment by Claire

An observer has kindly reported on today’s EDDC local plan examination in public session on the very thorny issue of the amount of industrial land proposed…. here’s what happened…

There was a marked difference from Wednesday’s session on housing, when there had been so many participants that some people were parked two rows back from the main tables.

Yesterday many well known (and some not so well known) housebuilders were anxious to demonstrate that the EDLP did not provide sufficient housing, and to urge the Inspector to provide more. The wildest claims and demands came from Mr David Seaton who wished to see the housing provision in East Devon almost doubled at nearly 30,000 additional dwellings up to 2026.

By contrast only 14 people debated the employment provision today. The other difference was that unlike Wednesday`s session where all the housebuilders and developers wanted more (often much more) housing, and everyone else wanted less; there was almost a consensus that the local plan advocated massive over-provision of employment land.

Inspector displeased

This morning got off to an eventful start with the contribution from Sidmouth resident Mike Temple. He suggested that the over-provision was a result of the influence of the now disbanded East Devon Business Forum, and of its Chairman “the disgraced former councillor Graham Brown.” The inspector intervened to say: “I don’t think we want to use words like that.”

The words used certainly do raise the hackles of many local people, but on reflection I think the words the Inspector was referring to, were probably “the disgraced” rather than “Graham Brown.”


A succession of speakers were critical of the employment provision advocated in the Plan. Margaret Hall of CPRE said it was at odds with the Roger Tym report, commissioned by EDDC in 2011. Its findings had not been accepted because it suggested a much lower level of development than EDDC wanted.

Excessive provision

Tipton resident David Boyle described the allocation as “excessive”. He said that this was partly due to a very ambitious EDDC target to reduce the number of people travelling from East Devon to work in Exeter by 50 per cent. David Boyle also said that the projected growth rates were unrealistic, and would create problems if accepted.

Dorset County Council also had concerns about the plan’s commuting predictions.

Absurd levels of employment land

Prof Steve Wilks for the Green Party said that the Plan “absurdly” over-provided employment land. His argument for a much lower provision was that East Devon had virtually full employment.

He said that East Devon is not self-contained, it is closely linked to Exeter and other centres. There is major employment provision at Skypark, the Science Park and Cranbrook and also in Exeter; and the Plan population projections are too high, and do not reflect the latest census information.

Prof Wilks added that many environmentally unsuitable sites had been proposed, such as the five hectares of employment land at Sidford. He said that EDDC’s own evidence showed that the plan is advocating three times as much employment land as is necessary.

Seriously excessive over provision

David Valentine for Gittisham Parish Council, said there was substantial over-provision. He was not concerned about the West End, but in the rest of East Devon there was seriously excessive over-provision.

Mr Valentine said that the formula providing a link between the provision of new homes and new employment was wrong. The amount of employment land being planned was sufficient for a very much greater number of homes than the plan provides for. He stressed that he was not seeking a higher housing provision – the opposite was the case.

Loss of employment sites

EDDC officers said that the figures were “net,” so the loss of sites such as Manstone in Sidmouth (scheduled to become housing as part of the Knowle relocation project) should be taken account of.

EDDC commissioned work ignored ... and influence of East Devon Business Forum

Cllr Claire Wright referred to the EDDC Employment Land Issues Task and Finish Forum (ELITAFF) of 2007, which was a piece of work undertaken by East Devon Business Forum and had been chaired by former councillor, Graham Brown .

Reference to this work appeared to take the inspector by surprise – it appeared that EDDC had not submitted it as evidence for the examination in public, despite relying on it as evidence in the paperwork available for today’s session. Claire Wright offered to give the inspector a copy.

Claire Wright explained that the ELITAFF had been formed by East Devon Business Forum, following the production of the Atkins report, which had been commissioned by EDDC. Atkins advocated a low level of employment provision. The ELITAFF had examined the sites considered by Atkins, and had concluded that many of them would not come forward; that there was therefore a need for many more sites; and had recommended a substantially higher level of provision than Atkins.

Following this piece of work many major planning applications had come forward from those landowners and developers involved with the study, that were then approved as departures from the adopted local plan.

Cllr Wright said that the report could not be described as objective and also was flawed because it only considered sites that were available immediately. It also did not take into account empty units.

She asked the inspector to approve the much more sensible Roger Tym number instead, which was roughly half the amount of land (and possibly less still) than EDDC was proposing.

Cllr Mike Allen (who had been the Chair of the Local Plan Panel) said that the morning’s debate had been all about numbers. He wanted the debate to go back to reality.

He said that the EDDC objective was to improve the economic well-being of East Devon people, particularly of women, and to provide sustainable employment options whereby more people could work nearer to where they lived.

He said that the five hectare site at Sidford – which he did not support – had come in very late in the process.

Cllr Allen said that the 2007 ELITAFF had been produced by realistic business people.

Approvals table disappears

Cllr Claire Wright asked what number of commitments (land allocated and land granted planning permission) had been taken account of in the local plan. She said that an earlier version of the plan had included a table of commitments. In the most recent version of the plan the table had disappeared.

The inspector asked EDDC for the latest situation, but only received a vague response.

Turning to Claire Wright, the inspector asked: “”You think there is a greater stock than is being shown?” which produced the answer: “Yes.”

The inspector tried again with EDDC who were unable to offer an explanation for the disappearance of the table and were unable to provide an up-to-date table.

The inspector asked EDDC to sort this out, and to put the table on the website.

Vacant premises

Local resident, Graham Cooper said that there were many unoccupied commercial premises, and some had been unoccupied for years. Mike Allen said that take-up was increasing.


Dorset County Council was concerned that a vast amount of the whole of employment land proposed, was scheduled to come forward in the early part of the plan. This was inconsistent phasing.

EDDC began to answer by referring to sites at Sidford and Honiton, but the inspector interrupted to say that it was a wider point, and that there should be more sophisticated phasing. However he seemed to accept the subsequent EDDC answer that there were practical difficulties related to attempts to enforce this.


Emily McIvor for the Green Party said the plan gave insufficient consideration to constraints such as those relating to AONBs. She said the plan should give more consideration to employment options that were not dependent on the allocation of land.

Incoherent options

Prof Steve Wilks for the Green Party said that it was difficult to see a link between the commentary in the plan, and the policies in the plan.


Prof Wilks said that the excessive proposed provision of employment land at Honiton would lead to/be dependent on massive inward commuting. He asked where all the commuters would come from.

He said that the allocation included provision for EDDC relocating its offices from Sidmouth to Honiton. However it had recently been announced that EDDC was now intending to relocate to Skypark, not Honiton.

Lack of evidence

David Valentine of Gittisham PC said that the only document relating to any sort of viability study was a letter from the landowner. Echoing Mandy Rice Davies` court statement in the 1960s Profumo/Keeler scandal, he said “and they would say that, wouldn’t they?”

Knowle relocation project

Mike Temple also referred to the recently announced EDDC intention to relocate from Sidmouth to Skypark, rather than Honiton. He said that this would result in a loss of jobs for East Devon people, as many of the jobs would be taken by Exeter residents.

A Sidmouth’s resident had prompted an interjection from the inspector at the beginning of this morning’s proceedings.

There was a nice symmetry at the conclusion of this part of the plan examination in public where a Sidmouth contribution prompted the inspector to ask for a high level discussion. I think the request was for strategic, rather than localised contributions, rather than an appeal for more intellectual discourses.

Readers might wonder why this report contains no arguments for greater employment provision. Essentially this is because no such arguments were made. The closest such offerings came from David Seaton who in a restrained (in length and in what he was seeking) contribution claimed that the plan had got it about right.

Just before the session concluded Cllr Wright queried an earlier point made about a possible future consultation.

The planning inspector replied that if he decided the plan was unsound but could be made sound with his recommended “modifications”, these would have to be consulted on.

EDDC would organise the consultation he explained, but it would belong to the planning inspectorate.

Tomorrow is the environment session…


1. At 12:27 pm on 14th Feb Sandra Semple wrote:

Amazing the way that the words “East Devon Business Forum” have been expunged from the draft Local Plan - like they had nothing to do with the housing and employment land figures when, in fact, they had EVERYTHING to do with it - even the almost constant assistance of an EDDC officer.

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