Tuesday 26 August 2014

Housing numbers in East Devon ...................................... "The region, which is earmarked for 11,000 new homes..."

Ahead of tonight's meeting at the District Council on housing numbers:
Futures Forum: Housing in East Devon: "the delay (and the developer free-for-all) could influence how residents vote in the next local elections in May 2015."
Futures Forum: Housing in East Devon: "I don’t see it as the floodgates opening, but I do see a stampede coming.”

... at which a new report will be considered:
East Devon District Council - News

... the Leader of the District Council and the Chair of the East Devon Alliance were interviewed on BBC Radio Devon this morning:

Housing estimate for East Devon “doesn’t bear any sense of reality”

Tuesday, 26 August 2014 1 Comment by Claire

The housing assessment that proposes just over 11,000 houses for East Devon “doesn’t bear any sense of reality,” according to EDDC leader, Cllr Paul Diviani.

Speaking on BBC Radio Devon this morning, Cllr Diviani told reporter, Jenny Kumah (who asked whether he was determined to get the local plan in place by next May’s council and general elections) that he “hoped” EDDC would have it ready” as soon as we possibly can.”

The 11,000 houses refers to the latest housing assessment undertaken by consultants, for East Devon, Mid Devon, Exeter and Teignbridge Councils, following planning inspector, Anthony Thickett’s rejection of EDDC’s local plan.

He declined to comment on whether he would try to get the local plan in place before the elections.

EDDC cannot say when the most fundamental piece of work will be finished, which is the housing assessment. Once this is complete there will probably need to be further public consultation, because the housing numbers for towns and villages are likely to change.


Housing estimate for East Devon “doesn’t bear any sense of reality” - Claire Wright 


August 26th 2014

This morning the Chairman of East Devon Alliance, Paul Arnott, once again went head-to-head with a top EDDC councillor – this time EDDC Council Leader Paul Diviani on the lack of a Local Plan. The EDA Chairman said that he was not surprised but still disappointed that, having been dealing with this project since 2007, EDDC still is not in a position to put a (third) draft Local Plan forward to the Planning Inspectorate and leaving the district vulnerable to speculative development. And he comes up with a STUNNING REVELATION why he thinks current research for the Local Plan is wrong and the reason why it is being held up. Read on …

Councillor Diviani trod the well-worn track of saying that there really is nothing to worry about – EDDC has so far won more than 70% of its appeals and (occasionally) says no to developers. The EDA Chairman noted that it is NOT EDDC alone that champions these appeals – particularly in the case of Feniton and Seaton, where it was local people who raised funds and made their case to inspectors, so implying that EDDC alone does this is somewhat disingenuous.

However, then came the total shock. You may recall that two sets of consultants employed by EDDC before the last iteration of the Local Plan said that they thought that around 12,000 homes should be built in the district. EDDC (and, it has to be said members of the East Devon Business Forum and developers, sometimes the same thing) said, no, no – this could not be right and at least 15,000 homes were needed – which is what got put in the draft put before the Inspector.

The Inspector threw out the plan, specifically saying that he could see no back-up research that confirmed the 15,000 number that EDDC came up with. So, EDDC went ahead and commissioned a THIRD set of consultants to check this work. and lo and behold, they have come back with a figure of 11,000!

And what does Leader Diviani say to this – THREE sets of consultants coming to around the same figure? He says, no no – this CANNOT be right. The government wants us to build more houses, we NEED more houses so we are going to “look at the figures again” because they must be “realistic”.

So, here we have it – Councillor Diviani thinks he is more expert than THREE sets of consultants and will not give up until – presumably – another set of consultants comes up with the figure that he and the government want. A figure not based on evidence.

So, we ask ourselves: where did the figure of 15,000 that Councillor Diviani so desperately wants come from? Developers? Out of thin air? from the Government which has told us (via the NPPF) to come up with LOCAL figures backed up with LOCAL evidence?

Some very, very, trenchant questions need to be asked. Not least by our councillors and, particularly, by Councillor Diviani




EDA Chairman 1 – Leader of East Devon District Council own goal – and a STUNNING revelation!!!! | East Devon Alliance

Interestingly, back in 2009, the figure of '11,000 new homes' was still being proposed by the District Council:

The region, which is earmarked for 11,000 new homes...

Body blow for new East Devon homes hope - News - Midweek Herald

But a District Council report out in January this year insists that the number should be 15,000 - plus 'windfalls':

East Devon Local Plan Examination Topic Paper
Topic Paper 1 – Housing – January 2014

4 Evidence and Case for East Devon Housing Provision 

4.7 The conclusion of the Roger Tym and Partners report were instrumental in informing the new Local Plan housing provision. The Roger Tym’s report indicated an East Devon need figure of around/ up to 11,000 new homes. The 11,000 figure was based on the most up to date and available data. However, the figure and its underlying assessment, did not take into account East Devon need within a broader Exeter HMA context. In very crude terms housing that could otherwise have gone to Exeter City but for which there are capacity constraints within the City boundary to accommodate.

4.8 The Exeter Core Strategy (now adopted) provided for 12,000 new homes and was produced against a backdrop of a then 15,000 RSS requirement. Bearing in mind an Exeter ‘under-provision’ of 3,000 (albeit noting RSS figures are out of date) it was recognised that East Devon would need to provide for an element of a wider Exeter need.

4.9 In response to providing for the around 11,000 housing need figure in the Tym’s report identified for East Devon we added in a 4,000 additional housing element. It should be noted that 4,000 is higher than the RSS 3,000 that Exeter’s Core Strategy did not provide for.

4.10 New East Devon Local Plan – in responses to consultation feedback and new emerging evidence the Local Plan provides for:
a) 6,000 homes at Cranbrook (40% of total provision);
b) 1,400 homes elsewhere in West End (9% of total provision); and
c) 7,600 homes in the Rest of East Devon (51% of total provision).

Provision = 15,000

Adding in a Projected Windfall Allowance this rises to a current approximate estimate of 16,500.


A study carried out by the CPRE contradicted this analysis in its representation to the Local Plan:

East Devon CPRE Representor Number 28. Transaction Number 3220

Housing numbers:
It is important to have realistic and achievable housing numbers. (NPPF 154)
The rationale for choosing 15,000 is not clear from the evidence presented by EDDC. It seems they have placed considerable reliance on the population projections based on the ONS/CLG 2008 statistics. CPRE would argue that these are no longer up to date and have proved inaccurate. More recent assessments are available which take account of the economic, social and environmental
characteristics of the area, as required by NPPF 158. 

These include the Roger Tym Report (Roger Tym and partners (2011) “East Devon Housing and Employment Study 2011”) commissioned by
EDDC, which the Council appear to have largely ignored. CPRE suggest that this more recent evidence supports a much lower housing number target of around 11,000. Furthermore, CPRE consider that housing numbers of 15,000 are not deliverable, and this strategy is therefore unsound for this reason also.

This was reported in the press:

East Devon branch of Campaign to Protect Rural England raise concerns over amount of development planned across the district

By Exeter Express and Echo | Posted: February 15, 2014

Under current proposals 15,000 homes are recommended for the district between 2006 and 2026.

But Dr Margaret Hall, secretary for the East Devon branch of the campaign group has calculated that only 11,000 – 12,000 houses are needed to meet the demand for housing.

After day three of the inquiry, Dr Hall said she had been “impressed” with how objective the inspector had been but still had some major concerns about the amount of houses and employment land planned.

Dr Hall reiterated previous assertions that the council’s housing prediction numbers are based on incorrect population predictions as per the 2008 Office of National Statistics and Department of Communities and Local Government.

The annual population growth, according to the boards, from 2008-2026 was one per cent, when according to the 2011 census the rate was less than 0.5 per cent.

“If you look at census figures, there are not as many people living in East Devon as predicted,” she added.

In addition, 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.

Futures Forum: Public Examination of the New East Devon Local Plan ..... ..... housing: numbers much too low for developers..... ..... ..... much too high for CPRE

The Vision Group for Sidmouth's representation to the Local Plan supported this analysis:

It seems that the District Council has ignored significant findings in the Tym’s Report of 2011 ‘East Devon Housing and Employment Study’. It is clear that the demographic profile for Sidmouth differs to much of East Devon:

“6.21 The West area has higher percentages in the age groups under 55. The East area, which contains the main retirement locations such as Sidmouth, has higher proportions over 54.
“6.25: Movements into the East area are quite different. Here the peak is of retirement‐related moves around the late 50s. There is an earlier peak around the late thirties (together with their children) these presumably being housing related moves. So the net gain in the Sidmouth/ Honiton area is predominantly of middle‐aged and elderly people.”


There are considerable doubts as to how the District Council arrived at its figures for proposed housing in Sidmouth. The Sid Vale Association makes this point:

“3.3. We are puzzled by the arbitrary allocation of 150 houses in the period to 2026. There is no justification in the LDP for this figure, which appears to have been “plucked out of the air”. The provision of housing needs is generally based on population growth, but there are no figures, (current or projected), given for Sidmouth in the LDP. EDDC’s own consultants, Roger Tym and Partners, noted that the population would in fact fall, which appear to have been ignored.”


The Sidmouth Chamber of Commerce welcomed the Tym’s Report in questioning the District Council’s assumed relationship of jobs to households of ‘roughly 1:1’:  

“…rather, they have recalibrated it to an exact relationship of 0.81:1, which a very different number”


To quote directly from the Tym’s Report:

“Job Density:
“2.41 To assess the balance of local jobs and working age residents, a job density chart is shown in Figure 2.12 for all districts in the south west region, with the figure for East Devon highlighted. An equal number of jobs and working age residents would result in an index of 1, and is likely to suggest a good balance of local jobs and local workers. Across the South West districts (weighted) average is 0.81.”


Whilst the Tym’s Report does explore different future scenarios (constant or low migration population levels over the period of the Local Plan), both current and maximum projected job density does not approach the District Council’s proposals of ‘one person, one job’ when matching proposed new housing to required new employment provision. The Tym’s Report provides well‐defined methodologies and evidence; the District Council does not:

“Impacts on Employment Projections and Job Density:
“6.36 A general measure for this purpose is job density, the number of jobs divided by the resident population of working age. Based on ONS job densities in Chapter 2, East Devon had a job density 0.73 in 2008, which was compared to a South West district average of 0.81. Using the latest employment figures (2009) matched against the estimates of working age population in 2009, East Devon is shown to have some 45,000 jobs and a working–age population of 75,000, giving a job density of 0.60.”

> That the District Council has developed such an intimate relationship with the EDBF has allowed the Business Forum to go beyond being merely a ‘consultee’ in the Consultation process and has encouraged it to successfully lobby the District Council “particularly over issues such as the lack of employment land supply.” 
Since 2007, when the EDBF was recommended as a planning consultee for the District Council, the interests of the District Council and the EDBF have corresponded to a considerable degree in the promotion of certain types of economic activity.  
Both the Atkins’ and the Tym’s Reports have been effectively side‐lined by ‘evidence’ supplied by the EDBF, leading to the inflation of numbers for housing and employment land in the draft Local Plan.


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