Gittisham Parish Council
The New East Devon Local Plan
2006 – 2026
Representation by Gittisham Parish Council on the Proposed Submission
(Publication) November 2012
Preliminary Remarks:
The Parish Council welcomes the opportunity to contribute to the consultation
process on The New East Devon Local Plan.
The Parish Council also welcomes and endorses the views expressed in the
plan, in particular aspects of: East Devon in the Future and Our Vision ® 6.19
These are:
3.1 .[EDDC] want growth and investment with minimum damage to our
outstanding environment so that the generations that follow us will not be
compromised in their quality of life.
3.3 …to keep East Devon as an outstanding place to live, and also to make it
a place where job creation is raising average incomes and where homes will
become more affordable. Affordable homes are a top priority for this Council.
All of our residents, young and old, should prosper and younger people, in
particular, are crucial to a vibrant future. We will promote opportunities for
better education provision for our young people and residents across the
District.
3.4 Our plans for strategic allocations for housing and workspace will be sited
in the best places to create the jobs and homes. We will safeguard the rural
country and coast and historic fabric of our urban environments for the
enjoyment of residents and visitors. We will also increase expectations for
green space and recreational space in towns.
3.6 Our strategic allocations and policies will ensure that each community and
settlement in East Devon will retain its distinctive character by careful
attention to Local Plan allocations and Development Management policies.
3.7 We have a priority to identify and promote development on Brownfield
sites first, except at the West End, and to protect grade 1 and 2 farmland
wherever possible to sustain local food production. We also aim to encourage
more local jobs and jobs close to where people live, and homes close to jobs,
to cut down commuting by cars and transport and infrastructure improvements
are needed.
3.11 In delivering growth at the market and coastal towns and rural
communities the challenge will be to provide all the necessary facilities whilst
conserving East Devon’s outstanding quality of life and very special natural
and historic environment. This includes the world heritage coast, as well as
the Blackdown Hills and East Devon Areas of Outstanding Natural Beauty.
The key is to respond sensitively to the needs for more balanced communities
without damaging the environmental qualities that we cherish and recognising
that environmental, social and economic considerations are all intrinsically
inter-linked. The local distinctiveness of East Devon in both landscape and
building traditions will be supported and we will set the agenda and design
standards for future progressive development.
3.12 …Strategic Policy is now to consider the holistic, strategic needs
weighed against other land-uses with a presumption in favour of continued
use of the land for food, energy and tourism.
We also endorse the commitment made at ® 6.24
14. Town Centre and Brownfield first
Although the District has substantial green rural areas, it has no wish to
encroach on these special areas unless strategic developments like
Cranbrook are needed.
u) Town centres are essential with a key objective for enhancement
with retail and office accommodation, while suitable Brownfield sites
are the preferred areas for housing and commercial development. We
aim to avoid greenfield development on grade 1,2 or 3a land with the
exception of the West End development.
However the Parish Council specifically wishes to make detailed
representations in respect of the following :STRATEGY 1 – Spatial Strategy for Development in East Devon
The Parish Council OBJECT to the dwelling numbers and employment land
allocations as proposed in the Plan. The number of new dwellings proposed
for the plan period to 2026, and the quantity of land allocated for employment
purposes are both far in excess of that needed over the plan period.
Population/Household projections
The population projections that underlie the housing targets in the plan are out
of date and unsound. The housing targets are unachievable and are therefore
unrealistic and unsound.
EDDC appear to be relying on the ONS/DCLG 2008 population projections
which indicated a growth of 1% per annum over the period 2008 – 2026. The
prediction for 2011 was a population of 136,600 (61,300 households). The
2011 census shows that the actual population was 132,500, some 4,100 less
than that predicted in the ONS/DCLG 2008 projections. The actual population
growth rate was not the predicted 1% pa, but over the past 5 years only
0.21%. The growth rate over the past 10 years, which may be a better guide
because it covers a 10 year period, was 0.54%.
A significant factor affecting these figures has been a steady fall in inmigration figures. This is discussed at length in the Roger Tym Report (East
Devon Housing and Employment Study 2011).
Clearly the ONS/DCLG 2008 projections are wrong and it is unsound to base
housing targets on these projections, which are now out of date.
If 0.54% growth is adopted the estimated population in 2026 would be
145,250, an increase of 14,150, not the 25,600 based on the ONS/DCLG
2008 projections. The latest population projections from ONS, published 28
September 2012, show a projected East Devon population in 2021 to be
143,000. This is broadly consistent with the figures outlined above.
In terms of households, they will rise from 58,500 in 2006 to 68,200 in 2006
(2.13 persons/per household), an increase of 9,700. An optimistic view would
be to hope for an upturn in the economy at some point during the remaining
plan period which may stimulate the housing market (and the population
growth rate) and it would not be unreasonable on this basis to increase the
household projections to 11,000. Given that windfalls will also come forward
during the plan period then any figures higher than 11,000 are going to be
unsound.
Deliverability
The predicted completion rates in the plan indicate a significant increase over
the next 5 years to around 1,400 per year. In the first 5 years of the plan
period (2006 – 2011) there have been 1,829 completions or 365 per year
(Technical Paper April 2012). To meet the household projections as proposed
within the plan an annual rate of 878 dwellings would be required. Based on
the last 5 years this is clearly unrealistic and unsound. Even a reduced target
of 11,000 households over the plan period requires 9,171 homes to be built
between 2011 – 2026, an average of 611 per year. This in itself would present
a challenge and require a significant increase in housing completion rates but
is considered to be deliverable.
Summary
There is ample evidence that the housing market generally, and the likely
level of in-migration to East Devon in particular, are likely to remain at
relatively subdued levels in the near future. This will inevitably impact on the
numbers of houses neede in East Devon over the plan period. The target
household figures within the plan are out of date and unrealistic. The
proposed dwelling numbers should be reduced significantly and a figure of
11,000 for the plan period is considered to be both realistic and achievable.
Employment Land
The amount of employment land proposed in the plan is vastly in excess of
that realistically needed for the planned provision of new housing, and an
even greater overprovision if it is accepted that the level of housing proposed
is itself more than is realistically likely to be built or needed within the plan
period.
This can be shown by adopting the rough yardstick given in the plan at para
6.10 (p.33) – 250 homes would typically generate a need for 1 ha of
employment land. On this basis the 150.55ha of employment land allocated
across the whole district could support 37,640 dwellings. This is 2.5 times the
number of houses proposed. Even taking out the 85ha of committed or
allocated land in the West End, the balance of employment land for the
remainder of the district is excessive. On the same basis
that area of employment land could support16,390 dwellings, whereas the
number of dwellings proposed by the plan for the rest of the District is 7,545. –
again a significant overprovision of employment land. This overprovision is
even greater if it is accepted that the amount of housing that the Plan
proposes is itself too high.
A further factor pointing towards avoiding over-provision of employment land
is that relating to deliverability. The Roger Tym Report 2011 cautions in
several places that over-provision will not provide the conditions whereby
there will be a financially viable case to develop sites. In short over-provision,
in increasing supply, will act to depress market rental rates and deter
developers from making the investment in developing such land.
Assuming that the number of dwellings required is the 15,000 proposed in the
Plan then on the basis of the rough yardstick referred to above, then in East
Devon as a whole only 60ha of employment land is required. In relation to the
housing proposed for the Rest of Devon, 7545, only some 30ha of
employment land is needed to accommodate the employment needs of the
residents occupying those new dwellings. These figures would drop
significantly if it is accepted that the amount of housing that the Plan proposes
is itself too high.
Strategy 23 – Development at Honiton
The Parish Council has serious reservations concerning the detail of the plan,
particularly as it affects Honiton town and Gittisham Parish. The Gittisham
Parish Council OBJECT to The New East Devon Local Plan in regard to the
proposed land allocations for residential and employment developments west
of Hayne Lane. The Gittisham Parish Council has had a long-standing
opposition to proposed developments west of Hayne Lane. This opposition
has been formed through representations from and consultations with
parishioners.
The Parish Council has already made submissions to EDDC concerning the
initial Local Development Core Strategy and to the EDDE panel charged with
the construction of the Local Plan. These submissions were based upon two
parish council questionnaires, a well-attended public meeting and detailed
consideration by the council. At its meeting on 3rd August 2011, the Parish
Council agreed to resubmit its evidence for consideration by the EDDC panel
in its deliberations on the Honiton Town plan. The council also agreed that it
wished to act in concert with Honiton Town Council and to that end the Chair
has met with the Clerk to the Town Council.
We have noted that the New East Devon Local Plan has modified the
proposals regarding the strategic allocation of housing land in the Honiton
area by specifying land West of Hayne Lane, and in Gittisham Parish, as a
reserve allocation of a development of up to 300 housing units , . We would
maintain that our views on this housing proposal remain valid and we wish to
object to any consideration of this site for development.
In regard to the proposal to identify 15 hectares of employment land west of
Hayne Lane and in Gittisham Parish, we continue to object. Our reasons are
as follows :The reservations and objections can be summarized under the following
headings:
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The process undertaken and the scope and detail of the LDF;
The need for and effect of the preferred option for housing
development in Honiton/Gittisham;
The need for and effect of the preferred option for employment land
development in Honiton/Gittisham.
The process undertaken and the scope and detail of the New Local Plan:
It is the contention of the Parish Council that the Plan has, throughout its
gestation, paid little attention to the views and aspirations of the communities
of the district, especially those expressed in the parish plans. As an example
of this, the Gittisham Parish Plan aspires to some limited development within
the parish but none on the area contiguous with Gittisham Vale, west of
Hayne Lane. The reasons are cogent and in line with community aspirations.
The Core Strategy, however, proposes no development in ‘Gittisham’ but
places 300 houses and 15 hectares of employment land in precisely that area
rejected by the parish plan. The Honiton position during consultation,
likewise, preferred development of Honiton to the east, not west of the town.
The plan ignores the impact on the social and political landscape of the
proposed housing on Gittisham Parish. The addition of up to 300 dwellings,
with an assumed occupancy rate of 2.2, more than doubles the population of
a small rural parish, some half of whose residents are already living in a
suburban development. The health and education facilities for Gittisham are
already overstretched.
The need for and affect of the preferred option for housing development
in Honiton/Gittisham;
We believe that the historic market town of Honiton is one of the attractions of
the district, county and region, and deserves to be protected from any transfer
of resources from the Honiton to Cranbrook. We note that any monies arising
from section 106 agreements do not have to be spent in the area in which
the development occurs, merely within the boundary of the planning authority.
If there were development within the parishes of Gittisham, or Honiton, we
would strongly argue that EDDC should make a commitment to spend all the
section 106 monies in the relevant parishes.
With regard to the specific proposals for housing development:
In general :
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The existing community, health and education infrastructure serving
the residents of Gittisham Parish is insufficient to meet existing
demand and further significant growth should not be accommodated
until existing deficiencies are addressed;
The preferred direction of growth, if found to be necessary, should be
to the east of Honiton;
In sustainability terms it is preferable to re-use existing land and
premises to maximise the most efficient use of resources rather than
allocate green field land for development;
New homes allocation (Reserved Site) west of Hayne Lane :
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300 dwellings west of Hayne Lane will require significant improvements
to existing transportation infrastructure which together with the need to
meet affordable housing targets, will result in a development offering
very little to addressing the existing infrastructure deficiencies
elsewhere in Honiton. The development will only exacerbate the
pressures currently apparent in Honiton – the proposed development
lacks for viability and sustainability;
Feniton primary and King’s School, Ottery, catchment areas include the
proposed development land. These schools are over-subscribed and,
in the case of the King’s School, expansion on the site is impractical.
Included in the necessary changes to transport infrastructure will be the
opening of Old Elm Road to through traffic. This road is the spine road
to the Heathfield estate. Making it a through route to serve the
proposed housing land will turn a quiet access road into a busy
thoroughfare with a consequent negative impact on the residents of
Heathfield and settlements further afield. The Heathfield residents
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were assured that this road would remain ‘access only’ at the time of
the development of the estate. There are no other viable solutions to
the access problem of the proposed housing.
The opening of Old Elm Road to through traffic will generate many
additional journeys through roads that cannot adequately service the
volumes that could obtain, for example: under the narrow railway
bridge on Hayne Lane; through Turks Head to Exeter; through Weston
and Buckerell to the A373 and the M5.
Development west of Hayne Lane will jut prominently into open
countryside beyond Honiton leading to a perceived threat of
coalescence between Honiton and settlements to the west of Honiton;
Developments west of Hayne Lane will be on rising land and visually
intrusive and detrimental to the setting of both of the adjoining AONB;
The reserve allocation of housing land is on the fields right next to an
active dairy farm and farm shop. If housing is built there it will be
subject to nuisance from necessary farming activities. The loss of
valuable farming land could also threaten this thriving business.
The need for and affect of the preferred option for employment land
development in Honiton/Gittisham.
Employment and Commercial allocation west of Hayne Lane :
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The proposed employment allocation extends west of Hayne Lane for
800 metres and will, if developed, result in a highly visible and
unacceptable ribbon development;
Development west of Hayne Lane will jut prominently into open
countryside beyond Honiton leading to a perceived threat of
coalescence between Honiton and settlements to the west of Honiton;
Developments west of Hayne Lane will be on rising land and visually
intrusive and detrimental to the setting of both of the adjoining AONB;
Although the Otter Valley west of Honiton is not in itself in an ANOB, it
is of great landscape value and contributes significantly to Honiton’s
attractive setting: the proposed ribbon development will have a
significant and detrimental impact on this precious asset;
The Employment and Commercial allocation west of Hayne Lane is
significantly in excess of the requirement to “ serve the needs and the
needs of the surrounding area”. A 15 ha allocation is, based on the
EDDC formula of 1 ha for 250 dwellings, sufficient to serve a
population growth in excess of 8,000 ( 3,750 dwellings ). The “local
need” to serve an additional 450 dwellings at Honiton would require an
allocation on the basis of this formula of 1.8 ha. There is no statistical
evidence of a need for 15 ha.
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This proposed allocation is significantly greater than the “local need”
requirement and will draw employees from a wide area contrary to
sustainability objectives;
The “local need” for employment and commercial land can be found on
existing vacant land and opportunities for redevelopment and
regeneration at both Heathpark and Ottery Moor Lane;
Other Concerns:
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Developments west of Hayne Lane will result in the unnecessary loss
of high quality agricultural land;
Both proposed residential and employment allocations will result in
developments that will adversely impact on existing Gittisham Vale
residents from traffic generated noise, reductions in air quality and loss
of privacy;
Local highways infrastructure is inadequate to serve the proposed
allocations for residential, employment and commercial uses;
The proposed developments west of Hayne Lane will have a
detrimental visual impact on both short and long distance views within
the Otter valley;
Localised flooding, particularly along the Gittisham link, is known to
occur south of A30 dual carriageway as a result of surface water
discharging from rising land. Developments west of Hayne Lane will
increase the risk of localised flooding.
Quite rightly, the Plan shows concern about the proportion of the population
who are economically inactive. The Parish Council also has concerns that the
demographic is that of an aging population with, in most years, more annual
deaths than births. In our perception, there is a negative brain drain, with
talented young people moving out of the region from existing towns and
villages. Affordable housing is inextricably linked with the level of wages:
Honiton does not need further low-waged employment.
The plans for Honiton, as expressed in the Local Plan, do nothing to avert the
probability that the area will evolve into a combination of retirement homes,
holiday park and dormitory. Growth in Honiton is limited by its geography and
that which has taken place over the last 30 years has pushed it to its limit.
There is an urgent need for a fresh look at plans for the future that will allow
the current town footprint, with limited development to the East, bounded by
an eventual Eastern by-pass, to be exploited to provide a diversity of high
quality employment and cultural opportunities for the next generations of its
inhabitants