Does not having a new Local Plan or Land Supply in place leave East Devon vulnerable to development?

The draft Local Plan is out to a further round of consultation:
Futures Forum: Local Plan: latest comment on 'minor to major' changes
East Devon District Council - News
Inspector rules that EDDC Local Plan must be resubmitted, after further public consultation | Save Our Sidmouth
Now EDDC’s Local Plan has to go back to the drawing board: 53 major problems | Sidmouth Independent News
EDDC’s Plan Unravels? | Sidmouth Independent News 


The District Council had earlier expressed fears that any such delay would have worrying consequences, leaving East Devon 'vulnerable to speculative planning applications and development':

Under the rules for preparing local plans set out by the Government, changes to the draft plan must be minor or they will require another lengthy round of public consultation and analysis,setting back the process and delaying the completion of the plan.We have worked to avoid this as the prolonged absence of a final local plan leaves our area more vulnerable to speculative planning applications and development in locations that are unacceptable to local people and the council.
www.eastdevon.gov.uk/east_devon_extra_july_2013.pdf
Council counters criticism over Local Plan - News - Sidmouth Herald


These fears have been expressed elsewhere:

Just over half of English councils do not have an adopted local plan in place only three weeks before the government's planning reforms are due to fully come into force, according to figures published by countryside campaigners.

CPRE: 52% of councils without plans as NPPF deadline nears

http://www.claire-wright.org/index.php/post/black_wednesday_protest_demo_-_saturday_23_march_feniton/

The biggest threat remains EDDC’s failure to get its housing land supply in order, and to have an approved Local Plan in place. Absence of an approved Local Plan means that developers can argue that there is no reason why Feniton shouldn’t take literally hundreds more houses. EDDC suffered a major blow this week when the Planning Inspectorate decided that recent changes EDDC had made to the Local Plan were, far from being minor, major enough to have to consult the public all over again. 
Fight for Feniton’s report September 2013 |

Susie Bond of Fight for Feniton’s Future said: “Feniton is just one of a number of villages across England facing massive development. We are particularly vulnerable because EDDC failed to ensure it had enough housing land identified and because it has no local plan in place.”

One Year On Still People on the Streets over #NPPF | Decisions, Decisions, Decisions

So, will development in Newton Poppleford stop there, now its fulfillment of housing for the next 13 years is complete?
Sandra SempleSeptember 18, 2013 
I find it very surprising that some people can agree with the outcome. It has only happened because EDDC has no five year land supply. Had the local plan been in operation this application would not have been allowed and would almost certainly have failed at appeal. If it had been turned down then would those who supported it this time have supported it next time? And, if so, why? The new Local Plan says that we do not need this development.
King Alfred Way | Sidmouth Independent News


On the other hand, there are arguments that that the District Council could be more 'proactive' in determining development:

An interesting item on the influential planning blog “Decisions, Decisions, Decisions” about a plaintive complaint from Horsham District Council (which has a 5 year land supply deficiency) that they are being forced to build more houses than they need. The planning consultant who runs the blog comprehensively dismisses  the points made by Horsham but does make the following point:

The government has now published in its Beta guidance guidance on prematurity, this largely repeats the extant guidance from ‘Planning system general principles’ and both suggest that plans prior to submission have some but limited weight.  If Horsham were successfully able to argue that development would be of such a scale to preempt the plan making process and that the draft plan had a high degree of conformity with the NPPF they stand a strong chance on appeal.  

Surely this should be the case in Feniton and possibly elsewhere. 

Can you refuse developers when you have no 5/6 year land supply? Possibly | Sidmouth Independent News
Horsham Leaders Letter to Boles Confuses Several Issues | Decisions, Decisions, Decisions

As the judge made clear, however, this is not to say that the absence of a five-year housing land supply will always be conclusive in favour of the grant of planning permission; the absence of such a supply is merely one consideration required to be taken into account, albeit an important one.

Although, to be fair, the rest of the article makes it pretty plain that if you do not have a 5 year land supply (or in the case of East Devon, a six year land supply) you are pretty much shafted if your local authority does not go in to bat for you.

An up to date explanation of the implications of having no 5 year land supply | Sidmouth Independent News
Martin Goodall's Planning Law Blog: Development management under the Localism Act

In the influential blog “Decisions, Decisions” in the entry on 10 February by planner Andrew Lainton, he goes into detail on the recent decision to allow the construction of 130 dwellings east of Butts Road, Ottery and says, in conclusion:

The key (classic) tactical error here was to attempt to puff up the 5 year supply by inviting applications which is tantamount to saying there is not a 5 year supply.  If East Devon has admitted it did not have a 5 year supply, invited applications on favoured sites and then swiftly approved them it would not have had a problem.  The appellant would be arguing its case at the forthcoming local plan EIP instead as its application would have been approved as the current local plan would not have been ruled out of date.

East Devon District Council 5 year land supply tactics criticised | Sidmouth Independent News
Key #NPPF 5 year Supply Appeal – 25 Year Supply and Still Loses, A Key Tactical Error by East Devon | Decisions, Decisions, Decisions


There has been severe criticism of the whole process of 'determining' the 5-Year Land Supply for housing in East Devon:
5 year | Search Results | Sidmouth Independent News



However, the District Council itself makes clear that the current Local Plan remains in place:

Current Local Plan (1995-2011)

The East Devon Local Plan (1995-2011) - Adopted July 2006. This document is the current, adopted Local Plan.  It was adopted in 2006 and sets out the current planning policy for development In East Devon.  The policies of the current adopted Local Plan will remain in place until the adoption of the New Local Plan (2006-2026).  At this point all current policies will be superseded.

Development proposals are judged against the relevant policies of the development plan for the area.  In East Devon, this is currently made up of the adopted East Devon Local Plan, the Devon Structure Plan and the Devon Minerals and Waste Local Plans.

East Devon District Council - Planning Policy (inc LDF & Local Plan)


And yet, what will happen if the Inspector choses to reject the draft Local Plan in its entirity, rather than focus on '53 major problems'?
Council votes to suspend local plan examination
Back to the drawing board for South Somerset Local Plan | This is Dorset
Now this IS spooky | Sidmouth Independent News


And if the 5-Year Land Supply and the provisions for employment land in the draft Local Plan are proving so 'problematic', to what extent should the process of drafting these policies be examined? 
Hull Local Plan rejected by HM Inspector; lessons to be learnt | WeAreResidents.org


Which brings matters back to the full circle of considering any 'influence' the East Devon Business Forum had on these procedures.
EDBF | Sidmouth Independent News 


But for the time-being, the TAFF set up to consider the EDBF has been suspended - due to fears that the Local Plan would be further delayed,
presumably leaving East Devon 'vulnerable to speculative planning applications and development':

Reproduced below are two comments on Councillor Claire Wright’s blog which give an insight into the way that the EDBF TAFF postponement has been justified and a comment on it:

At 06:52 pm on 27th Aug Graham Troman wrote:

Yes, I have postponed the next Taff meeting for two reasons.We need more information regarding a new business group for eastdevon.The main O&S committee supported the Taff to look at planning issues regarding employment land,but not to hold up the local plan process.On balance we need a local in place and will resume when the Inspector 
has done his Job.

Taff Chairman, Graham Troman

9. At 08:00 pm on 27th Aug Sandra Semple wrote:

The TAFF should be looking into historical evidence of the influence of the last group – particularly in the light of developments we all know about – and it is not necessary to wait for this. I very much doubt that we, the taxpayers of East Devon, will get what we are entitled to:  a full in-depth examination of the influence of EDBF on employment land input into the Local Plan and why Atkins and Tym consultants’ reports (commissioned by EDDC and which came to very similar conclusions) were ignored in favour of EDBF which wanted vastly more employment land – especially when EDBF say in their minutes that they never even discussed. Tym and many of those same EDBF members now have planning applications in for vast amounts of development.

East Devon Business Forum Task and Finish Forum – latest news | Sidmouth Independent News
Claire Wright - Your Independent East Devon District Councillor for Ottery Rural
Futures Forum: Lobbying: East Devon Business Forum 
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Local Plan: Consultation on Proposed Post-Publication Changes

Following on from the Inspector's comments:
Futures Forum: Local Plan: latest comment on 'minor to major' changes
Futures Forum: District Council's Local Plan: comment from the Inspector: that the proposed changes are in fact major...
there will have to be a further round of public consultations on the Local Plan...

As reported in the Herald today:
Council mistakes lead to new public session on Local Plan
Home - Sidmouth Herald

This was in fact flagged up earlier this month, with comparisons made with South Somerset:

Concerns raised over local plan

Thursday, August 01, 2013

Exeter Express and Echo

CONCERNS have been expressed about the integrity of East Devon District Council's Local Plan.

A planning inspector last month raised concerns over parts of the proposed Local Plan for South Somerset District Council – which shares the same Chief Executive as East Devon. Following a Public Examination of the plan, the inspector initially suggested that the council either withdrew the plan and started the process again or proceeded with the plan in its current state with the likely outcome that it would be rejected. Following representations from the authority, the inspector subsequently confirmed the council could temporarily suspend it for six months while the concerns raised are addressed.

East Devon District Council officials have subsequently rubbished concerns that it faces a similar result as South Somerset because the authorities share Mark Williams as chief executive, branding such claims as a "fanciful non-sequitur".

East Devon's Local Plan, which outlines where around 15,000 homes as well as employment land could be built between 2006 and 2026, is due to go to Public Examination in November.

Ian Makintosh, chairman of the East Devon Alliance campaign group, said he has concerns about the robustness of the Local Plan and pointed to a planning inspectorate's recent finding – that the council cannot demonstrate it has enough land suitable for the demand for houses in the next five years. Local authorities are expected to demonstrate five years as part of the Government's National Planning Policy Framework. "What has happened at South Somerset throws into question the competence behind our Local Plan and we are concerned what happened there may happen in East Devon at public examination stage," he said. "As long as there is no Local Plan the land is at risk of developers."

Tony Green, member of campaign group Save Our Sidmouth (SOS), said members were also fearful that East Devon's Local Plan may fall short of an inspector's expectations.

Concerns raised over local plan | This is Exeter

Here is the invitation to make representations from the District Council: 

Consultation on Proposed Post-Publication Changes to the Local Plan

East Devon District Council invites you to make representations on the Proposed Post- Publication Changes to the Local Plan. The consultation will run for six weeks from Friday 23 August 2013 until 12 Noon on Monday 7 October.

The Council submitted its Local Plan and associated documents/evidence for examination on 2 August 2013. The submission material included a schedule of proposed changes to the Publication Draft of the Local Plan which was approved by Full Council on 24 July 2013. However, on 15 August 2013 the Planning Inspector (Mr Anthony Thickett BA(Hons) BTP MRTPI Dip RSA wrote to the Council indicating that it would be appropriate to consult on these changes.

Representations should be made regarding the Proposed Post-Publication Changes only, though you may wish to refer to background evidence/reports produced to support the Local Plan. These are available in the Local Plan Document Library which is available at www.eastdevon.gov.uk/lpsubmission. Please refer to the change number your representation is in regards to. This can be found in the left-most column of the table in the Schedule of Proposed Post-Publication Changes available at http://www.eastdevon.gov.uk/lpchanges and at the Council Offices. A Representation Form is also available at this address along with a Guidance Note for making representations at this stage. This is the preferred method for making representations, however any representations submitted during the consultation period will be taken into account, reported back to Full Council and forwarded to the inspector.

Representations should be emailed to localplan@eastdevon.gov.uk or sent to Planning Policy, East Devon District Council, Knowle, Sidmouth, EX10 8HL.

Yours faithfully,

Graeme Thompson

(Planning Policy Officer)

Here is today's comment from Sidmouth Independent News:

Make your new comments on the Local Plan

And when does consultation on the 53 major amendments to the Local Plan start?  Today:  the day before a long bank holiday and with no announcements in the press to tell people that it has started.  It mentions that they will be writing to all those without email addressed and to statutory consultees.  But when will those people receive their letters – perhaps more than a week into the new consultation period.  Is this proper procedure one has to ask.

How many people know that the site is up and running and the clock has started ticking?

If you wish to make comments online go to

http://www.eastdevon.gov.uk/lpchanges

and make sure you make as many comments as possible.

You have until 12 Noon on Monday 7 October 2013 to submit your comments

23 August 2013 – noon 7 October 2013

Mr Anthony Thickett has been appointed as the Independent Inspector and he has advised that he cannot undertake his examination of the document because there are 53 changes from an earlier version that he feels should be consulted on first.  The new consultation will cover all the changes made since the previous consultation – not just the 53 mentioned by the Inspector. But it is only those changes to the earlier version of the plan that may be the subject of any new comments.

The changes made to the Local Plan that the Inspector insists should be consulted on are HERE.

http://www.eastdevon.gov.uk/proposedchanges.pdf

Comments on these changes (and only these changes) can be made HERE

http://www.eastdevon.gov.uk/lpchanges

Representations should be emailed to localplan@eastdevon.gov.ukor sent to Planning Policy, East Devon District Council, Knowle, Sidmouth, EX10 8HL. Representations received after 12 Noon on 7 October 2013 may not be accepted.

Make your new comments on the Local Plan | Sidmouth Independent News
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A new East Devon local plan will have to implement the strategy set out in the Greater Exeter Strategic Plan by 2023

Next Tuesday sees a meeting of the District Council's 'strategic planning committee' - and the final item on the agenda looks at 'strategic planning' in a very big way:

12 New Local Plan Timetable (pages 194 – 199) 

This report sets out a first draft of a timetable for production of a new Local Plan for East Devon. It does so on assumption that the Greater Exeter Strategic Plan will be produced to publicised timetables. 

eastdevon.gov.uk/media/2744658/290119strategicplanningcombinedagenda_opt.pdf

And the strategy is to produce a new East Devon local plan - which was to have run for the next decade or so - because of the GESP: 

The new local plan will provide policy to implement the strategy set out in the GESP and there can be expected to be many detailed policy considerations, and some topic matters, that GESP will not address; these will fall to the new local plan.

That means we will have to scrap the current East Devon local plan which runs to 2031:
Local Plan 2013-2031 - East Devon

And bring in a new one by October 2023: 

290119strategicplanningcombinedagenda_opt.pdf

The East Devon Watch blog has just put together a piece showing the implications of this top-down 'strategic planning' approach:

GREATER EXETER STRATEGIC PLAN – WHERE ARE WE? IN TROUBLE!

26 JAN 2019

All change on the Planning Front for East Devon.

Ever since David Cameron’s coalition government’s efforts to provide local communities with a say in local planning decisions with the “Localism Act” in 2011 (giving communities the power to draft “Neighbourhood Plans,” designed to provide a degree of self-determination to how local communities could be developed in the future) the powerful developers and landowners lobby has been active to reclaim their powerful grip on developing our communities.

First was the new National Planning Policy Framework (NPPF) in 2012 which threw out the old planning regulations and provided a “developer-driven” new planning policy, with just a “nod” to the Localism Act, Neighboured Plans and District wide plans.

The new NPPF introduced a policy that if the District or Neighbourhood Plan was not “up to date” then there would be a presumption of allowing any proposed development from a developer. Therefore, Councils and local communities quickly set about drawing up their Neighbourhood Plans and District Plans to plug the gap created by the new 2012 NPPF policies.

East Devon District Council who had been dragging their feet for years to complete their Local Plan, finally managed to obtain the approval of the Planning Inspectorate in January 2016 to cover the period up to 2031. Lympstone had got its Neighbourhood Plan approved in 2015 and since then over 30 Neighbourhood Plans are either approved or in the process of being drafted by community groups within East Devon.

It was therefore thought that East Devon and its communities had substantial protection from greedy landowners and developers up to 2031 and with the extra protection of the East Devon Villages Plan, approved in July 2018 (which gave further defined policies for larger Villages and some large Business Parks) residents and developers appeared to understand where development would or would not be allowed.

However, in late 2016 Exeter City Council, whose Chief Executive Karime Hassan (previously East Devon’s District Council officer who created and developed the concept of the new town of Cranbrook) proposed a joint “Strategic Plan”, along with neighbouring councils East Devon, Teignbridge, and Mid Devon.

The four councils then started a joint over-riding masterplan for Exeter and the surrounding area known as the GESP (the Greater Exeter Strategic Plan).

It was clear that Exeter was almost completely built-out and the infrastructure in roads and transport required for further city centre and commercial growth was urgently required if the continued success known as the “Exeter Growth Point” was to continue. Without a joint plan for infrastructure, the commute into the City would become intolerable and hinder the targeted housebuilding requirements set by the Government for each of the 4 separate councils.

In October 2018 the Government draw up yet another updated version of the NPPF (National Planning Policy Framework) very much on the lines of the 2012 Policies, but with various tweaks to assist in the over-riding government strategy of encouraging developers to build many more dwellings.

The new 2018 NPPF provided clearer guidance that if an individual Council was unable to provide enough development land for extra dwellings required by the government’s growth targets, neighbouring councils may be allowed to build out extra housing for their partner and other neighbouring authorities.

According to East Devon District Councils Strategic Planning Committees agenda item 12 for discussion on the 29th January 2019:

“Timetable for production of a new East Devon Local Plan”

Within the introduction to the agenda item it states:

“…given changing circumstances and other factors, that a “light touch” review of the currently adopted local plan is unlikely to be a practical option for a new local plan.”

What the changing circumstances and other factors are, is not explained but it is clear from the report it is clearly in relation to GESP.

Because the GESP Strategic Plan policies will over-ride the East Devon Local Plan policies, the report seems to suggests that the “changing circumstances and other factors” relate to the new GESP policies which override the Local Plan, Village Plan and probably most Neighbourhood Plans – affecting a large area of East Devon! So much so that, rather than the GESP plan dovetailing into the 3-year-old approved East Devon Local Plan and 1-year-old Villages Plan with all the years of public consulting, Council debate and literally years of work by the planning team, it will be jettisoned for a brand-new Local Plan to dovetail into the strategies of the GESP plan!

Although the GESP plan has been in preparation for 2 years, no formal discussion or meeting has been held at any Council Chamber at any of the four Councils involved. Meetings have taken place to consider the 700 plus sites throughout the Greater Exeter area submitted for assessment by what is known as the “Housing and Economic Land Availability Assessment (HELAA) panel” The Panel is made up of “key stakeholders”, with a recognised interest in the development of land for housing and employment, and housing and economic development sector, including housebuilders, social landlords, local property agents and other related professionals together with local community representatives and other agencies. The membership of these meeting has been confidential and there has there been no publication of their deliberations or recommendations.

To be clear: meetings between two lead councillors from each Authority, plus officers have kept the draft policies and site options totally under lock and key – with none of the meetings been reported or minuted.

However, all is to be revealed AFTER the local council elections in May 2019 – consultation has always been scheduled to begin no earlier than June 2019.

This suggests that the draft policies and site options affecting East Devon will be so radical and so totally at variance to the East Devon Local Plan and Villages Plan that they will all require total re-writing, with a brand-new Local Plan (subsidiary to GESP) and all the costs and uncertainties this will bring.

Why have these Councils been so secretive on the GESP proposed development site considerations for proposed strategies for commercial and housing development for this part of Devon? Could it be that Tory controlled East Devon, Teignbridge, and Mid Devon Councils have elections on May 2nd this year (Labour Exeter elects only one-third of its council this year) and a brand new super-growth plan – superseding their Local Plans – will not be considered much of vote-grabber?

Don’t say you weren’t warned!

Greater Exeter Strategic Plan – where are we? In trouble! | East Devon Watch
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Localism: The uses and abuses of power: "No politician willingly surrenders control downwards."

Strong words from Simon Jenkins, chair of the National Trust, writing in yesterday's Guardian:

"Labour's hatred for localism, and especially elected localism, is as visceral as that of the Tories.
This is not a party matter; it is professional tribalism. No politician willingly surrenders control downwards." 

Schools are held hostage by politicians' control-freakery | Simon Jenkins | Comment is free | The Guardian

The issue of 'local vs central' has been touched on before:
Futures Forum: Jeremy Rifkin and the Collaborative Commons
Futures Forum: Relocalisation

LOCALISM AND POLITICS:

If 'localism' is to mean anything, it surely needs to allow 'local people' - and not simply their County or District Councillors - to affect change.

Radical localism requires a new relationship between local authorities and communities as well as local and central government. 
One question to ask is whether devolution is too often stopping at the top two tiers of local government. Organisations – in this case councils - are sometimes guilty of spending a little too much time arguing for greater powers and responsibilities to be devolved to them, without taking the next step of thinking what should be devolved beneath them.

whatnextforlocalism.org/wp-content/uploads/2013/01/WNFLsmall.pdf
Welcome - Localis - Local government and localist think-tank

However, if Simon Jenkins is right - that politicians in general are loathe to surrender power - the question arises as to how much politicians in local government follow the same instincts.

Here is an example:

Wilmslow Town Council has submitted its comments for the Planning Inspector who will consider the Cheshire East Local Plan saying that, despite all the consultation responses, the plan does not reflect many of the local priorities.

The letter to the Inspector says:

"Despite CEC going through three major consultations which engaged Wilmslow residents in numbers not seen previously, the submitted plan contains very little of the local priorities.

"Wilmslow is surrounded by greenbelt and the creative use of brownfield, windfall and previously developed greenbelt land is critical to retaining the character of Wilmslow, yet the local plan gives relatively little attention to the use of this land and appears to proactively direct developers to greenbelt and greenspace. If there is a requirement on Cheshire East Council to ensure effective local consultation, then the Local Plan fails to meet the test of localism despite the number of consultations entered into.

"The Town Council, aware of local feelings towards greenbelt, has tried within the process to apply a common sense approach. We accept the need for some development and that the safeguarded land at Adlington Road should be developed, albeit later in the term of the Local Plan when critical infrastructure issues could be effectively overcome.

"Local Plan fails to meet the test of localism" - wilmslow.co.uk

In East Devon, there have been more than three consultations on its local plan:

Since 2006 the council has undertaken almost continuous consultation with the communities of East Devon, along with other stakeholders including developers, landowners and infrastructure providers to input into the Local Plan’s development.

East Devon Local Plan - What's happening?

East Devon Local Plan - further consultationEast Devon District Council - Planning Policy (inc LDF & Local Plan)
Futures Forum: A history of the East Devon local plan ... part one

But the local plan has been rejected by the Inspector - provoking considerable frustration:
Has the Local Plan Inspector lost his patience with EDDC? | East Devon Alliance

"They have had five years to produce their plan, and now they are back to square one."

“Given the seriousness of the situation, the starkly complacent comment by council leader Paul Diviani, that he is ‘very relaxed’ about starting work again on the Local Plan, is incomprehensible.”

Campaigners: ‘We need root and branch reform of EDDC’ - News - Sidmouth Herald

However, the District Council has promised yet more 'consultation':

"After spending so long refining our plans and consulting on them, at some point you have to jump in and say, ‘OK – let’s see how close we are to what the Government wants to see’. In the circumstances I am relaxed about the extra work we have to do. We will now put together an action plan showing what we will be doing and when."

Local Plan Verdict: More work needed - News - Sidmouth Herald


LOCALISM, POLITICS AND BUSINESS:

The subject of 'localism' also touches on the subjects of lobbying, gravy trains and subsidies:
Futures Forum: Crony capitalism and lemon socialism in East Devon........ The costs of "substantial growth and expanding business"
Futures Forum: Greenfield vs Brownfield: part two
Futures Forum: 'Planning gain' - the replacement for S106 cash from developers - the Community Infrastructure Levy - but is it still 'bribery' by a different name?

Because small businesses - which do not enjoy the advantages of lobbying, gravy trains and subsidies - are the backbone of the local economy:
Futures Forum: Michael Shuman and economic localisation: "Those counties with the highest density of local and small business were those that actually had the highest level of per capita income growth and were doing the best job of reducing poverty."

Because Walmart and other megachains employ primarily low-wage workers, and have huge multi-national presences, little of the money spent in your local superstore will remain in the local community. A study of the economic impact of local businesses versus large chain stores in New Orleans found that just 16 percent of money spent at the large chain remained in the local community, compared to 32 percent for independent businesses. Educate your consumers about how buying local can help your regional economy, and you may be able to sway them from switching allegiances.

Facts and Fiction About the “Walmart Effect” | Intuit Small Business Blog.

Again, if Simon Jenkins is right - that politicians in general prefer to hobnob with the powerful and are loathe to surrender power - another question arises as to how politicians in local government 'work with certain business interests'...

Interestingly, in East Devon, its leading District Council officers and councillors have chosen to address the district's business group about the local plan:
Futures Forum: East Devon Business Support Group... 'updated' on the draft Local Plan

This grouping was formed following the demise of the East Devon Business Forum
Futures Forum: East Devon Business Group... or Forum
Futures Forum: East Devon Business Group: disbanded
Futures Forum: Lobbying: East Devon Business Forum

"It is clear from pronouncements by senior officers that the District Council has never felt comfortable dealing with community representatives and it is this approach which throws doubt on the soundness of the District Council’s consultation process, especially with regard to strategic economic policy."

https://www.visionforsidmouth.org/media/65397/representation-to-local-plan-final-version-vgs-14jan13.pdf

Here is a report given by Karime Hassan, the District Council's then-Corporate Director, when addressing the East Devon Business Forum in February 2011:

“Karime Hassan reported that the biggest challenge facing the Business Forum was ensuring that there was a clear voice from business in East Devon. Before the formation of the [East Devon] Business Forum, engaging with business in East Devon had not always been easy, whereas in Exeter City there was a single voice for business. It had always easier to engage with resident groups and those who opposed development rather than those who were supportive. He confirmed that the regulatory regime that local authorities imposed could be felt to stifle business, particularly within the planning process. The way the local authority engaged with business was a matter of fundamental importance and had improved greatly due to the relationship EDDC had established with the Business Forum.

“The greater weight that had been given to the views of business since the establishment of the Business Forum was recognised, particularly over issues such as the lack of employment land supply... 

“Karime Hassan reported that the establishment of East Devon Business Forum had made his job as Corporate Director of EDDC easier as it was the voice of business in East Devon.”

http://www.eastdevon.gov.uk/030211edbf.pdf

http://sidmouthindependentnews.wordpress.com/2013/01/07/-the-influence-of-the-east-devon-business-forum-on-the-local-plan/East Devon Proposed Local Plan Consultation 2012

The District Council has promised to consider the influence of the EDBF - but only once the local plan has been passed:
Anyone remember the East Devon Business Forum Task and Finish group? | Sidmouth Independent News
East Devon Business Forum airbrushed out of Local Plan employment land sections | Sidmouth Independent News
The Business TAFF drags on | Sidmouth Independent News
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East Devon: "urban sprawl”, taking neighbourhood plans into account ... and the continuing delay in the District Council securing a Local Plan

The District Council's website carries clarification on where we are with the Local Plan process:
The new Local Plan - East Devon District Council
Publication and submission of the Local Plan - East Devon District Council

What is the new local plan?

A new Local Plan for East Devon is in production. It sets out policies and proposals for the development of land in East Devon and has been produced following extensive consultation. The plan was submitted for examination in 2013 and hearing sessions were held in February and March 2014. We have, however been asked to undertake additional work on the plan with a view to a reconvened hearing session or sessions. If ultimately found sound at examination and subsequently adopted, the new plan will supersede the currently adopted Local Plan.

What is the new local plan? - East Devon District Council

Post-publication changes consultation

On 15 August 2013, the Local Plan inspector (Mr Anthony Thickett BA(Hons) BTP MRTPI Dip RSA) wrote a letter to East Devon District Council indicating that it would be appropriate to consult on the proposed post-publication changes to the Local Plan. Consultation took place for six weeks from Friday 23 August 2013 until 12 noon on Monday 7 October 2013.

A Consultation Feedback Report has been produced by us. To assist users of the plan we have also produced a tracked changes version of the plan that shows the text changes in situ and also shows the change number alongside these. The comments received can be viewed in the Local Plan representation library.

Post-publication changes consultation - East Devon District Council
East Devon District CouncilThe New East Devon Local Plan 2006 to 2026: Proposed Submission Draft of the Plan

Ten days ago, the Express & Echo carried this piece:

Further delays to East Devon District Council’s vital development document?

By Exeter Express and Echo | Posted: January 21, 2015

EAST Devon District Council has not confirmed when a public consultation regarding its Local Plan, which was due to start this month, will commence, or why there is a delay.

The document, which sets out where around 15,000 houses could be built in the next decade or so, went back to the drawing board in April when a Government inspector ruled that the Local Plan, was “unsound” with “serious evidential failings”. The inspector asked the council to provide further evidence to support its housing projections. A council spokesperson said the work is being carried out through a Strategic Housing Market Assessment and is nearing completion – but was unable to say when it would be. The SHMA report was expected last summer but the council subsequently said it was expected in November, but the wait continues.

Dr Margaret Hall, secretary of the East Devon branch of the Campaign to Protect Rural England is among the district’s residents to warn that as long as the Local Plan is delayed, “our countryside is not safe”.

While the wait for the plan continues, the council can only refer to the Government’s controversial planning guidelines, the National Planning Policy Framework document, which favours sustainable developments. And the council cannot demonstrate it can satisfy the Five Year Land Supply criteria – that it has enough land suitable for the likely demand in houses over the next five years. So, in the meantime, the council has admitted that its ability to determine new housing developments is “limited” – and this is giving developers the upper hand.

Inspector Anthony Thickett ruled that more data was required to ascertain the likely housing demand and back-up the council’s prediction that 15,000 houses are needed by 2026. He called the absence of an up-to-date SHMA a “serious failing”. And he warned that more houses may be necessary. The delay to finalising the plan is set to cost the council a further £12,000, by way of consultants’ studies fees, on top of the 2013/14 inspection budget of £110,000 plus £50,000 in reserve funding.

After consultation on proposed changes occurs, a draft report from the inspector, with any proposed modification, is expected – it had been anticipated by the summer, after which a subsequent consultation period will follow, with the adoption of a plan likely by the end of 2015, although there is no knowing if this desired deadline can now be met.

Further delays to East Devon District Council’s vital development document? | Exeter Express and Echo

This update is from this week's edition of the Express & Echo - reiterating the same point:

Latest Exeter News | Exeter Express and Echo

Meanwhile, there are concerns that the lack of a Local Plan continues to keep East Devon vulnerable to unplanned development:

East Devon MP voices concerns about prospect of Exeter – Exmouth “urban sprawl”

By Exeter Express and Echo | Posted: January 21, 2015



WHILE listening to his constituents’ concerns regarding the prospect of over-development, East Devon MP Hugo Swire expressed his own concerns about the prospect of an “urban sprawl” between Exmouth and Exeter. The Cabinet Minister made the comments at a recent public meeting called by Vaughan Rosser, a GP and chairman of the Ebford Residents Association with support from Clyst St George Parish Council, amid fears the two settlements are on the verge of being engulfed by new homes.

With a total of 35 houses in the pipeline seeking approval or with approval, Ebford could increase by 53 per cent. And in Clyst St George, if an appeal pending for 25 houses is upheld, the village would swell by 65 per cent. More than 100 people turned out to raise concerns with the MP and hear what he had to say.

Mr Swire stressed that MPs have no statutory role in planning and cannot adjudicate in local planning matters. But he said he was “extremely sympathetic” to the residents’ concerns and was worried about an “urban sprawl” along the estuary corridor from Exeter to Exmouth.

He also expressed concern at the delay in East Devon District Council securing a Local Plan, which sets out where around 15,000 houses could be built in the next decade.

In April, a Government inspector ruled that the council’s Local Plan, was “unsound” with “serious evidential failings” and more data on likely housing demand was required. Consultation is due to get under way soon and, if all goes according to plan, an adoption of the plan is not likely to happen until the end of the year.

Meanwhile, the council can only refer to the Government’s controversial planning guidelines, the National Planning Policy Framework document, which favours sustainable developments.

And the council has admitted that its ability to determine new housing developments is “limited”, it cannot demonstrate it can satisfy the Five Year Land Supply criteria – that it has enough land suitable for the likely demand in houses over the next five years – and this is giving developers the upper hand.

The MP said he would like to see Cranbrook utilised for “much needed” new houses in order for the integrity of existing communities to be preserved. “There is only one main route from Exeter into Exmouth which is already very busy, one secondary school in Exmouth and the primary schools are very full,” he said. We need to think very, very carefully about all this development and I would have thought that with Cranbrook up the road, the answer would be to continue building there.

“Every day that goes by without a Local Plan, is a day too long,” he continued. “Development is always going to be a hugely contentious issue in this part of the world, but there’s a huge shortage of houses, however it’s important that people know what the housing supply is going to be in their areas over the next 15 to 20 year period.

“When the Local Plan was rejected, I argued then for the council to redouble their efforts because there’s the perception that the lack of a Local Plan is a green light for developers and developments are getting through.”

He said Neighbourhood Plans were a vital tool for communities to have their say about development. “These plans are about communities getting together and deciding what sort of development they want , where they want it and what it should look like. It’s important that communities develop these plans because a Local Plan has to take them into account.”

Mr Rosser, added: “We are not trying to block development, we want to use the Neighbourhood Plan process to ensure development is done in a reasonable, coherent and strategic way that’s agreeable to everyone.”

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East Devon MP voices concerns about prospect of Exeter – Exmouth “urban sprawl” | Exeter Express and Echo
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District Council draft Local Plan: how other see it >>>>>> >>> Conservatives and East Devon Alliance

This blog has looked at specific areas concerning the draft local plan:
Futures Forum: District Council draft Local Plan: and the AONB
Futures Forum: District Council draft Local Plan: and Park & Change

It has also looked at how the different groups - the two main groups in the District Council elections - are portraying themselves and each other:
Futures Forum: East Devon District Council elections: what the websites say >>> Conservatives and East Devon Alliance on-line
Futures Forum: East Devon District Council elections: and 'misinformation' >>> Conservatives and East Devon Alliance

Here is the 'official' version of the current draft Local Plan - voted through by the Conservative-dominated District Council:

Council can now demonstrate a robust five-year housing land supply

When this content has been created

6 April 2015

Important changes to affordable housing requirements at East Devon

Five-year housing supply East Devon District Council is now in an even stronger position to defend the district from non-sustainable development. Changes arising from permissions granted since March 2014 and an up to date Strategic Housing Market Assessment (SHMA) means we can now clearly demonstrate a 5.45 year housing land supply including a required 20% buffer. This is a significant improvement on the previous position of between 3.51 and 3.83 years.
However, once the new Local Plan has been adopted, this new figure will rise again, due to the inclusion of proposed allocations that could not previously have been incorporated because of uncertainty over their delivery. Once this has happened, we will be in the position of having a housing land supply of almost six years.
The improved housing land supply figure will have a positive impact on housing restraint policies, which can now be fully implemented.  For example, policies relating to Built-up Area Boundaries (BUABs) will now carry greater weight and proposed developments that do not meet the necessary BUAB requirements can be resisted more strenuously.

Changes to affordable housing allocations

Up until now, East Devon has sought 40% affordable housing (Policy H4) provision on development schemes across the district. This was because we previously believed that the new Local Plan on affordable housing provision, until it was adopted, did not carry significant weight to change the provision. However, a recent resolution by the Secretary of State (in agreement with the inspector) to approve an application for a development of 430 dwellings, a local centre and a care home at Pinn Court Farm, Pinn Hill, Exeter, subject to it having a 25% affordable housing provision, has changed our approach.
On the basis of the Secretary of State’s decision (together with the Inspector), all future affordable housing requirements will be subject to two tiers of provision, depending on the location of the development:

• 25% - This will apply to developments in Axminster, Exmouth, Honiton, Ottery St Mary, Seaton and other major strategic developments within the growth point.
• 50% - This will apply to all other parts of the district.

However, developments outside Built-up Area Boundaries, will need to be treated as an exception and will require an  affordable housing requirement of 66% under a previously adopted cross subsidy scheme designed to encourage the provision of affordable housing.
Affordable housing provision is still subject to thresholds set down recently in government guidance which dictate the scale of developments where affordable housing can be required, these are as follows:

Exmouth, Honiton, Seaton and Sidmouth

Number of dwellings 1-5: no affordable housing
Number of dwellings 6-10: no affordable housing
Number of dwellings 11+: affordable housing (on site provision)

Rest of Devon (rural areas)

Number of dwellings 1-5: no affordable housing
Number of dwellings 6-10: affordable housing (contribution only)
Number of dwellings 11+: affordable housing (on site provision)

6 April 2015 - Council can now demonstrate a robust five-year housing land supply - East Devon

Public gets a chance to comment on latest revisions to planning blueprint

When this content has been created

15 April 2015

Blueprint for housing and other development is subject to Inspector's questions

Eight-week consultation on draft Local Plan starting on 16 April

A fresh public consultation on the future blueprint for planning in East Devon will be launched on Thursday 16 April and will run until Friday 12 June.
Planning Inspector Anthony Thickett has advised East Devon District Council of the matters that he wishes to see consulted upon, following the completion of extra work that planning officers were required to do to supplement the previously submitted draft Local Plan.
The Inspector has given the council a list of questions and these will be available for interested members of the public to view online, at Knowle and at libraries and town council offices across the district for a period of eight weeks.

Awareness

Awareness of the latest opportunity to comment on aspects of the draft Local Plan 2013-2031 will be raised via a number of channels, including public notices, a press release, social media, EDDC’s website, emails and letters to all individuals and agents on the Planning Policy service’s database, and documents placed in council offices and libraries, plus Exeter Central Library.
As before, it will be possible for people to submit comments online or on forms that may be emailed or sent through the post. These will be available on the council’s website and at the various access points around East Devon. Details about the consultation are available on the New Local Plan and current consultations page.
In this final round of consultation, the council will be asking residents to comment only on revisions to the earlier version of the draft Local Plan.
The Inspector’s questions that are open for comment will be grouped together in four clusters, plus there will be a fifth section for comment on any proposed changes not covered by the Inspector’s questions.
The four specific clusters concern:

• Housing levels and development in the plan
• Gypsy and Traveller provision
• Site allocations
• Community Infrastructure Levy (CIL)

Each access point will have a package of information available, including guidance notes explaining what the Inspector wants to know and how to fill in the electronic forms or paper documents.
Comments must be received by 12 noon on Friday 12 June 2015 at the very latest. The responses received will be collated and sent on direct to the Inspector for his consideration. It is anticipated that the Inspector will be able to reconvene hearing sessions in July.
Any enquiries relating to the Examination of the two documents should be addressed to the Programme Officer, Amanda Coombes, at the Council Offices in Sidmouth, viaemail or by telephone: 01395 571682.

15 April 2015 - Public gets a chance to comment on latest revisions to planning blueprint - East Devon

Here is the East Devon Alliance take on the draft Local Plan:

Is EDDC really pushing the Local Plan forward?
And if not, why not?

Written by: Dr. Cathy Gardner, candidate for Sidmouth Town Ward.
Updated by: Dr. John Withrington, Vice-Chairman, East Devon Alliance

EDDC has been working on a Local Plan (previously a Local Development Framework) since 2008. Since the National Planning Policy Framework (NPPF) was introduced in March 2012, having a Local Plan approved by the Planning Inspectorate is essential both to avoid inappropriate developments and to get Community Infrastructure Levy (CIL) funding from developers to grow the local infrastructure to match the growth in population.

Yet after nearly seven years work and three years since introduction of the NPPF (or four, given that the NPPF was out for consultation a year beforehand), the District remains without a Local Plan in place. As if this were not bad enough, the position has been exacerbated by EDDC’s long-standing inability to prove it has a five-year housing land supply – and in those circumstances the NPPF imposes a 20% penalty, i.e. EDDC has had to prove it has six years’ worth up its sleeve. As a result, residents of East Devon, and our beautiful countryside – two-thirds of the District is designated AONB – have been put at the mercy of predatory developers. For example, Feniton has seen virtually annual assaults by developers since 2011; Newton Poppleford and particularly Clyst St. Mary have also had more than their fair share of pain.

A lack of urgency and general incompetence has been the EDDC hallmark throughout. A draft Local Plan was thrown back in August 2013 with 53 flaws highlighted. But when EDDC submitted a revised version the response by Inspector Anthony Thickett in March 2014 was a devastating indictment of EDDC’s cavalier approach[a]: the draft was not sound, there were numerous flaws, some of the data used seemed to be guesswork, unreliable figures used for migration data meant that there was “little point” in taking things further given “the shortcomings in the evidence base overall” … As a result, and with further delays as EDDC decided it needed a more up to date SHMA (see Housing Numbers tab), it has taken EDDC until March 2015 to finally get its Local Plan act together. In the meantime, our countryside has been put at risk and paid the price.

SummaryDetailed TimelineHousing Numbers

Summary

The draft local plan has been in development since at least 2008, and yet some seven years later it is still a long way from being approved by the Planning Inspectorate. Whilst it is true that the government has moved the goalposts between 2008 and 2015 with the introduction of the National Planning Policy Framework – which has also had small but significant tweaks in the interim – that is less of an excuse for the excessive time to get a Local Plan approved and more of a reason for them to ensure that it is completed quickly before the goalposts move again.

The advice and guidance on the importance of having a Local Plan under NPPF and how to achieve it has not been in short supply, for example:

• In a letter to Chief Planning Officers in March 2011[b] Local Authorities were urged to get on with getting a Local Plan in place.
• In 2012 the Planning Inspectorate[c] provided support to fast track the preparation of Local Plans so that they would only take six months.

The consequences of this delay, and not having an adopted plan are:

1. That EDDC has found it much more difficult to reject planning applications in the countryside and especially in either of the two AONBs if it believes that they are inappropriate;
2. That EDDC has been forced to fight a number of Public Inquiries in cases where developers have appealed against their proposals being turned down. EDDC has boasted that it is good at winning such appeals however, not only could this simply be an indication that EDDC is failing to refuse inappropriate planning applications that have a higher probability (though by no means certainty) of being overturned at appeal, but it also fails to recognise that in those cases where it has lost appeals (e.g. Feniton and Ottery), these towns and villages have suffered. And had EDDC got its Local Plan in place, the Council, and its rate payers, would not have had to fight these costly appeals in the first place;
3. That EDDC has missed out on getting income from the Community Infrastructure Levy, a payment from property developers to improve local services to support the extra housing but which can only be levied once the Local Plan is in place.

Under the old Structure Plan (2001-16), EDDC was required to build 563 houses p.a. According to its own figures[c]EDDC: Audit and Governance June 2014, EDDC’s lack of urgency means that this figure has only been exceeded twice in the past eight years: the crisis facing East Devon, as developers flock to concrete the countryside, is in no small way due to EDDC not having honoured its previous obligations.

	Completions
2006/07	374
2007/08	284
2008/09	224
2009/10	393
2010/11	565
2011/12	321
2012/13	467
2013/14	824

So in 2013/14, there were more than double the number of houses built than the average of the previous seven years. The same table in the same document predicts (as at June 2014) that more than 1,100 houses will be built in 2014/15, a third more than in 2013/14 and almost triple the same average.

The Gittisham 300

The gap between EDDC rhetoric and reality and the impact of a lack of a Local Plan is clearly indicated by the following example, an application for 300 houses between Honiton and Gittisham where there were significant concerns about both the visual impact and sustainability.

In Pulman’s View from Honiton on 2 Sep 2014 page 3[d], EDDC claimed that “The majority of our settlements are adjacent to Areas of Outstanding Natural Beauty, Green Wedges and other designations that restrict development anyway and these designations still apply with equal strength whether we have a five-year land supply (part of the Local Plan) or not.” Unfortunately, later that same week the EDDC Development Management Committee approved these 300 homes adjacent to not one but two AONBs, putting the earlier EDDC statement into a more realistic light.

To put this in perspective, this single site is almost equivalent to the entire number of houses built in the whole of East Devon in 2011/12. Had there been a Local Plan in place, this development would almost certainly never have been approved. Indeed, it was only put into the Local Plan as a reserve site in the event that Honiton could not find sufficient sites to meet its allocation. In no way was it considered to be an ideal site.

Most Recently

On 6 Feb 2015, East Devon District Council wrote to the planning inspector explaining that the evidence would not be made available for review until June 2015 “because of the forthcoming local and national elections this would not appear to be a viable programme to follow with concern of risks that the process could been seen as becoming politically motivated rather than being based on the soundness of the plan.”

The inspector responded that whilst he had originally anticipated reviewing the updated evidence in late 2014, he saw no reason why it should not be made available for review by mid-April, i.e. the forthcoming elections were no reason for delay.

Many residents of East Devon will have assumed that the reason for EDDC delaying the evidence until after the elections was for political advantage, i.e. on the grounds that the number of new houses being recommended for East Devon was higher than EDDC had bargained for. As indeed has turned out to be the case.

SummaryDetailed TimelineHousing Numbers

Local Plan Timeline

Dec 2008	“Issues and Options” publication[e]
Sep 2010 to Nov 2010	“Preferred approach” publication and consultation[f]
Dec 2011 to Jan 2012	First draft Local Plan publication and consultation[g]
Nov 2012 to Jan 2013	Second consultation on the revised draft[h]
2 Aug 2013	Local Plan submitted for examination[i]
15 Aug 2013	Planning inspector writes to EDDC in response: disagrees with EDDC that proposed changes are “minor”, and lists 53 [sic] changes that require consultation[j]
Aug 2013 to Oct 2013	Back to the drawing board post-publication consultation[k]
26 Sep 2013	Planning inspector requires evidence of housing, affordable housing and employment numbers and sets date for Examination in Feb 2014[l]
31 Mar 2014	Planning Inspector rejects local plan primarily due to lack of evidence on housing numbers[m]
24 Apr 2014	EDDC DMC is informed that Strategic Housing Market Assessment (SHMA) has been contracted to David Coultie Associates (DCA) and is due June 2014[n].
26 Aug 2014	EDDC DMC is informed that SHMA is delayed[o]. According to this document there are six stages to producing the SHMA, and only two have been completed.
6 Feb 2015	EDDC write to Planning Inspector[p]to advise that SHMA will be delivered on 13 Feb, but due to upcoming election and concerns of “political motivations”, consultation will not happen until June 2015.
9 Feb 2015	Planning Inspector writes to EDDC[q] stating that he “need to see the evidence and any proposed changes [to the local plan] as soon as they have been agreed and by mid April at the latest”.
2 Mar 2015	EDDC announces[r] that Local Plan progress will be made before elections.
9 Mar 2015	EDDC issues press release on SHMA report, trumpeting that “950 new homes per year is the right amount for East Devon”. However, 950 was only one of a number of scenarios, and at this stage the scenarios/recommendations had yet to be discussed/approved by EDDC.
25 Mar 2015	Revised draft Local Plan approved by EDDC’s Development Management Committee.
31 Mar 2015	Final letter in sequence dating from 15 March sent to Inspector Thickett on the development of an approved Local Plan.

Forward View

After years of unnecessary waiting, we may get a Local Plan adopted by end 2015 / early 2016. According to formal questions and answers from full Council in February 2015[s], the current timetable is as follows:

Early March 2015	Publication of the SHMA
End March 2015	DMC and full council meeting to consider revisions to the Local Plan including proposed housing numbers
Early Apr 2015	Revisions to draft Local Plan Resubmission to Inspector Inspectors questions seeking views through consultation
Mid-Apr to end-May 2015	Consultation
Aug / Sep 2015	Oral examination sessions reconvene
End 2015	Local Plan adopted.

So, with luck and a following wind, we may have an adopted Local Plan by the end of 2015, hopefully bringing to an end the development free-for-all we have seen for the past two years. But then again, so far at least, time-scales for the adoption of the Local Plan have not exactly gone to … um … plan.

SummaryDetailed TimelineHousing Numbers

There is no more complicated or more emotive issue than the number of new houses needed for East Devon. Key points are:

• Under the old Structure Plan for 2001-16, EDDC was required to build 563 houses p.a. Historic under-provision – this figure was exceeded only twice between 2006/07 and 2013/14 – has meant that EDDC has potentially faced a huge backlog for a number of years.
• The National Policy Planning Framework (NPPF) was introduced in March 2012. Designed to sweep away red tape, its new presumption in favour of sustainable [sic] development represented an open invitation for developers to build anywhere they wanted. Open countryside always being cheaper than brownfield sites.
• Land Supply. Councils needed to prove a five year land supply for housing stock. Under the NPPF, Councils guilty of persistent failure suffered a 20% penalty, i.e. a requirement to provide six years’ worth. EDDC fell into this category, and the lack of a sufficient land supply was a key factor in developers winning Public Inquiries for building in Feniton and Ottery St Mary. (At the Ottery Inquiry in 2012, EDDC calculated that it had a supply of 5.7 years, whereas the developer claimed it to be only 3.6 years district-wide. A major failing of EDDC was to rely on a policy of ‘disaggregation’, i.e. splitting the district into segments as opposed to looking district-wide, a policy found wanting.)

An approved Local Plan would have provided a coherent and defensible position about where development was appropriate, how many houses the district would need, and where the priority for development lay. EDDC’s inability to get round to doing this in the course of many years has led to a policy vacuum, a situation exploited to the full by developers after the NPPF. It’s also meant a bill of unknown proportions for EDDC, which has risked the wrath of residents should it not defend communities against inappropriate development, but which equally has been forced to dip into its coffers to pay for costly appeals which might not have been necessary in the first place.

A key omission in this process has been EDDC’s extraordinary inability to provide reliable data about how many houses the district actually needs. The most shocking example came in March 2014, when Planning Inspector Anthony Thickett wrote to EDDC[t] to comment on the latest draft Local Plan, saying that he did “not consider that the 15,000 housing target is justified by the evidence submitted to the examination”. A key defect in EDDC’s approach was that the NPPF required authorities to have a reliable Strategic Housing Market Assessment (SHMA) in place: Inspector Thickett’s conclusion was that this was not the case for East Devon. A new SHMA was required.

Further delays ensued when EDDC decided that its SHMA would have to take into account housing needs alongside those of East Devon, Mid Devon, Exeter and Teignbridge. The SHMA report[u], finally released in March 2015, was supplemented by two independent reports: by Edge Analytics[v] looking at housing growth need, and Ash Futures[w] looking at likely job creation. Significantly, EDDC required its own ‘gung-ho’ scenario to run alongside their standard models – ‘jobs-led policy-on’ – which was predicated upon a highly optimistic view of the East Devon economy in the run up to 2033. While both consultants were careful to hedge their projections with numerous caveats, and while the Edge Analytics had one scenario projecting just 584 new houses needed p.a. for East Devon in the planned period, EDDC seized upon the highest figure possible – 950 new houses per year, i.e. a 63% increase over the 584 figure – and immediately issued a press release, implying that the whole matter was now resolved. While the figure of 950 more houses p.a. was considerably higher than the 750 EDDC had envisaged, even higher than the previous 563 target and massively higher than the 375 average number of houses built p.a. between 2006 and 2013, Leader Paul Diviani nevertheless described the increase as “relatively modest”.

As of writing, EDDC is now convinced that it is able to demonstrate a five-year land supply, the Housing Monitoring Update of March 2015[x] estimating that, working on an SHMA of 17,100 houses between 2013-31, EDDC is able now to demonstrate a supply of 5.45 years. According to an earlier Housing Monitoring Update[y], With the adoption of the Local Plan as proposed, this would rise to 6.08 years.

Local Plan | East Devon Alliance
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