Gittisham Parish Council
The New East Devon Local Plan
2006 – 2026
Representation by Gittisham Parish Council on the Proposed Submission (Publication) November 2012
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
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 ® 6.36; ® 6.40; ® 6.38. 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.
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 longer period, was 0.54%.
A significant factor affecting these figures has been a steady fall in in-migration 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.
The predicted completion rates in the plan indicate a significant increase over the next 5 years to around 1,400 per year ® 6.42. 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.
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 needed 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.
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 ® 6.37– 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 support 16,390 dwellings, whereas the number of dwellings proposed by the plan for the rest of the District is 7,545; 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 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 ® 6.110
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 ® 6.113. 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 EDDC 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 ® 6.113. 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 ® 6.112, we continue to object. Our reasons are as follows :-
The reservations and objections can be summarized under the following headings:
- The process undertaken and the scope and detail of the New Local Plan;
- 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 in 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 of any section 106 monies in the relevant parishes.
With regard to the specific proposals for housing development:
In general :
- The existing community, health and education infrastructures 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 :
- 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 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, therefore, visually intrusive and detrimental to the setting of both of the adjoining AONB;
- The reserve allocation of housing land is on the fields immediately adjacent 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 :
- 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 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 additional to the undeveloped employment land within the existing development boundary for Honiton.
- 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;
- This proposed allocation is significantly greater than the “local need” requirement and will draw employees from a wide area contrary to sustainability objectives;
- 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 Parish 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.