January 4 Public Meeting slides.

Upottery Parish Council

Public Meeting on the East Devon Local Plan 2020 to 2040

7pm, January 4, 2023

What the Local Plan is, how it has been written and what it means for Upottery.

How we can all respond to the consultation. Question and answer.

What’s the purpose of a Local Plan?

To determine where new housing, employment and open space should be allowed/encouraged for the next 20 years.

Who uses a Local Plan?

- EDDC (our Local Planning Authority), when deciding planning applications.

- DCC when planning road improvements, road gritting and other services.

- Department for Education when planning their school investment strategy.

- Bus companies when deciding which routes to cut and which routes to improve.

- Private retail/hospitality businesses when planning future investment.

- Etc. Etc. Etc.

EDDC Settlement Hierarchy

Sustainable Tier 1: Principle Centre (e.g. Exmouth)

Sustainable Tier 2: Main Centre (e.g. Honiton, Cranbrook, Ottery St Mary)

Sustainable Tier 3: Local Centre (e.g. Broadclyst, Colyton)

Sustainable Tier 4: Service Village (e.g. Dunkeswell, Broadhembury, Chardstock)

“Strategic Planning Committee were presented with the option of expanding the list of settlements included in Tier 4 of the Settlement Hierarchy to include Colyford, Rockbeare, Upottery and Woodbury Salterton back in March. This was on the basis that if the settlement hierarchy were to be expanded and essentially we were to lower the threshold in terms of the level of services and facilities to justify inclusion in Tier 4 then these 4 settlements are considered to be similar in terms of what is available and so according to the evidence all 4 should be included. To include 1 and not the others would leave a major inconsistency in our approach and would not follow the evidence and hence my concern in simply including Upottery.” Ed Freeman, October 19, 2022.

EDDC did consider including Upottery in Tier 4 but rejected the idea “because it would mean adding 3 other settlements to Tier 4”

The Upottery HELAA development site (Upot_01) identified by EDDC in 2017

Rockbeare (bordering Exeter Airport)

2017 & 2021 HELAA Sites

“

Colyford (part of Colyton)

Woodbury Salterton (part of Woodbury)

Extract from EDDC “The Role and Functions

of Settlements”

report, V3, Oct 2021, page 48.

4.29 Based upon evidence on the availability of community services and facilities, the following hierarchy of settlements are suggested:

Tier one: Exmouth (1)

Tier two: Axminster, Cranbrook, Honiton, Ottery St Mary, Seaton, Sidmouth (6)

Tier three: Broadclyst, Budleigh Salterton, Colyton, Lympstone, Woodbury (5)

Tier four: Clyst St Mary,Uplyme, Beer, West Hill, Newton Poppleford, Feniton, Whimple, Kilmington, Otterton, East Budleigh, Stoke Canon, Tipton St John, Musbury, Sidbury, Chardstock, Broadhembury, Payhembury, Branscombe, Plymtree, Dunkeswell, Hawkchurch, Exton, Westclyst (22)

Settlements not listed above are considered to be ‘open countryside’ for the purposes ofthe Local Plan, where more restrictive planning policies apply. (from LocalPlan Page 13, para 3.6)

Development and Settlement Boundaries in locations outside of the defined settlement boundaries, development will not generally be supported, except where it is in accordance with a specific Local or Neighbourhood Plan policy that explicitly permits such development and where it would not harm the distinctive landscape, amenity and environmental qualities of the area within which it is located. (from Local Plan Page 41, Strategic Policy 7)

Upottery

Identifying sustainable settlements

For Tiers 1, 2 & 3: Availability of “Strategic Facilities and Services” determine which Tier a settlement is in:

Supermarket

Secondary School

Hospital

Leisure Centre

Swimming Pool

Emergency Services Facility

Train Station

Hourly bus service

Identifying sustainable settlements

Tier 4 settlements need to have a minimum of seven “Local Services” otherwise the settlement is deemed to be unsustainable:

Less than hourly bus service

Primary School

Convenience shop / store

Post Office (included in shop)

GP surgery

Community Hall

Library

Pub

Open space/ allotments

Children’s play area

Identifying sustainable settlements

Tier 4 settlementsneed to have a minimum of seven “Local Services” otherwise the settlement is deemed to be unsustainable:

Less than hourly bus service

PrimarySchool

Convenience shop /store Post Office (includedin shop)

GP surgery Community Hall Library Pub

Allotment Sports Playing Pitch Children’s play area

In October 2021, the one criteria “Open space/allotment” was split into two criteria: “Allotment” and “Sports Playing Pitch”

Identifying sustainable settlements

Tier 4 settlements need to have a minimum ofseven “Local Services” otherwise the settlement is deemed to be unsustainable

Less than hourly bus service

Primary School

Convenience shop / store

Post Office (included in shop)

GP surgery Community Hall Library Pub

Allotment

Sports Playing Pitch Children’s play area

So a busservice once a week scores the same as a primary school in making that settlement sustainable?

Not one single Tier 4 settlement has a library! Digital connectivityis not included as a local service. (Ultrafast in Upottery, Superfast in Dunkeswell & Broadhembury.)

EDDC categorised all East Devon settlements in this way during 2021 but has never discussed this with EDDC settlements/Parish Councils.

Extract from “Role & Functionsof Settlements Report V2”, August 2021 Showing how settlements were scored

Settlements scoring 7 or more are considered “sustainable” where development will be encouraged. Settlements scoring less than 7 are considered “unsustainable where development will not be allowed.

Extract from “Role & Functionsof Settlements Report V3”, October 2021 Showing how settlements were re-scored

NB:

Upottery Primary School has the largest catchment area of any primary school in East Devon

CLA Report: “Sustainable CommunitiesThe Role of Housing in Strengthening the Rural Economy”, March

2022. Five recommendations:

1 The National Planning Policy Framework (NPPF) mustreturn to a policy which promotes organic incremental growth in settlements of fewer than 3,000 inhabitants, which would lead to a small number of houses in a larger number of villages.

2 Local authority sustainability assessments should be reformed, to place greater emphasis on digital connectivity in recognition of the services that can be accessed online; and to assess which services could be supported if development were enabled.

3 Local planning authorities should be mandated to undertake ahousing needs assessment across all rural settlements without a housing allocation so that identified local need can be met at a local level.

4 Permitted development rights should be introduced for new-build affordable housing for discounted rent on rural exception sites.

5 Conditional exemption from inheritance tax should be expanded to affordable rented housing for the period the homes remain let as such.

Freeman, Service Lead, Planning Strategy and Development Management, EDDC. November 24, 2022.

“The Local Plan has a bearing on the lives of everyone in East Devon”

Ed

And that applies to everyone living in “unsustainable settlements” allowed no growth, just as much as it applies to those living in “sustainable settlements”, where EDDC have decided they want all new development to be focussed.

What are the issues with the plan?

Parishes have not been consulted whilst the plan was being written on how sustainability has been determined. 

The “settlement hierarchy” is too simplistic, based on a tick-box count of how many selected facilities/services a settlement has such that a count of 7=sustainable, a count of 6=unsustainable. 

No weighting is applied which makes a once a week bus service as significant as a primary school when determining sustainability but a Post Office operating two hours a week is not considered a Post Office. 

Digital connectivity is not included as a facility/service in the settlement hierarchy as the CLA says it should. (But a library is!) 

No accommodation is made for organic growth in small settlements as recommended by the CLA.

The consultation only shares selected information:

The Consultation website map only shows EDDC’s preferred development sites in “sustainable settlements”.

The HELAA map (elsewhere on EDDC’s main website) shows all potential development sites. Most peoplewill not be aware of this.

And there are other problems with the Commonplace consultation:

Questions are only asked about development in EDDC preferred sustainable settlements. Most people submitting responses will never know there are hundreds of other HELAA development sites that EDDC has removed from the consultation.

Comments on development sites not in the Commonplace map can only be made by sending in a separate email/letter. (Confirmed by Ed Freeman)

The consultation is a huge questionnaire: Questionnaires tell you two things: A lot about those who designed the questions and if you’re lucky a little about those who answer the questions.

EDDC will get the answer they want… “We don’t like growing existing towns/large villages to this extent and building another new town but we know we have no choice”.

The consultation isn’t valid because it’s assumptive and only provides selected information, which is as bad as asking someone “Have you stopped beating your wife?”

The Commonplace website does not provide those answering questions with a record of the responses they have made.

For more information and links to the EDDC consultation website go to: www.upottery.com

Why it’s important to send a separate email/letter

GL Question: The Commonplace consultation website only shows the sites proposed/considered for development in the plan in what is termed “sustainable settlements”, but it does not tell peopleabout all theother submitted sites (through the HELAA process) that arelisted on the EDDC website. Can people comment on those sites, if they think they should beincluded in theplan as sites for development?

EF Answer: The Commonplace softwareincludes all the sites that went through the initial sifting from the HELAA process and by officers and progressed to the moredetailed assessment stage. Other sites are not presented as options where we considered that there are fairly fundamental reasons why they would notmove forwardas allocations through the Local Plan (i.e. not suitable/deliverable/achievable).We are trying tofocus the consultation on what weconsider to be genuine options and ifwe were consulting on every site that came through the HELAA process, it would be unwieldy and difficult to engage with, but that additionaldetail is availableshouldpeople wish to comment. People arewelcometo comment on anything that is on the websitein terms of evidence and we will be happy to consider views on sites that arenot specifically identified on the Commonplace software. Whilst there isno specific route to do that through Commonplace other than the general comments boxes, you could do this byemailing or writing to us.

- EDDC Local Plan Webinar Nov 24, 2022