This report sets the scene for future local plan production work.
Minutes:
The report presented by the Assistant Director Planning Strategy and Development Manager provided the Committee with feedback on the first stage of the Regulation 19 Consultation and provided an update on the timetable for the production of the Local Plan taking into account any consequential changes.
Out of the 3,510 comments received on the consultations from individuals and organisations the key issues included:
Ø 1,100 responses had been received for site Exmo_20 raising concerns on biodiversity, flood risk, infrastructure and procedural fairness.
Ø Concerns had been raised by the housing development industry about the Council’s Housing Strategy
Ø Concerns about under-classification of Feniton and Whimple.
Ø Concerns about the under representation of Exmouth’s strategic role
Ø Concerns raised about infrastructure delivery, in particular, healthcare, education and utilities.
Some other key issues raised by statutory consultees included:
Ø Concerns about site allocations within a national landscape.
Ø Potential impact of wind turbines on heritage assets.
Ø There is a need for transport evidence for the West of East Devon.
Ø Concerns raised about the absence of some detail for proposals for the new community.
Ø Lack of capacity in primary health care in the West of East Devon.
Ø There is a need for additional evidence on water quality to understand the potential impact of additional housing.
Ø Impact to heritage assets needs to be addressed prior to any potential development.
Ø The requirement of a Level 2 Strategic Flood Risk Assessment.
The Assistant Director – Planning Strategy and Development Manager drew the Committees attention to paragraph 4.2 of the report that provided clarification on the implications of two stage Regulation 19 process taking into account the new version of the NPPF. The Committee noted there was a need to be mindful about minimising any significant changes to the Local Plan to help keep within the transitional arrangements as this could have an impact on the housing numbers which could then be increased by a further 25%.
The Committee’s attention was also drawn to paragraph 6 of the report which addressed the ongoing evidence work. The Assistant Director – Planning Strategy and Development Manager advised that he was confident that the outstanding evidence documents would be completed in time to support the Local Plan consultation and referred to the revised timetable to help get the submission of the Local Plan to examination.
These key steps included:
Ø Ongoing study and assessment work to be done throughout the summer.
Ø Committee to receive the first redraft of Local Plan in September/October 2025. (The Committee noted that an additional meeting would be required).
Ø The second round of Regulation 19 consultation to take into account the second new community and the outstanding evidence work to run from October to November 2025.
The Chair invited questions from Councillors which included:
· Can more details be added to the agenda paper to help identify who is making the comments that had been received during the consultation? The Assistant Director – Planning Strategy and Development Manager advised that officers would be publishing all the comments, but these were still being worked on and gave reassurance that this would be clearer in the summary report.
· Clarification was sought about whether the council would be contacting the local MPs to address the high housing target figures. Although the Chair reassured Councillors that the MPs were already well aware of the council’s views and advised that he would send an email to remind them.
· Clarification was sought from the Assistant Director – Planning Strategy and Development Manager about whether it was a surprise to receive negative comments from the statutory bodies. In response he advised that some comments were a surprise and gave an example that the Environment Agency had objected to the lack of a Water Cycle Study when it was not a requirement.
· Clarification was sought on when the Committee would receive the draft final version of the Local Plan. The Committee were advised that the final version would be brought back to Committee late September/early October to be able to begin the consultation in October.
· A question was raised about the lack of coverage for the consultation as 3,510 comments was not good for the East Devon area. The Committee was reminded that the consultation was undertaken in accordance with the instructions made by the Committee and in accordance with the published statement of community involvement.
· Clarification was sought on whether the Committee would be considering any brownfield sites for allocation of development. The Assistant Director – Planning Strategy and Development Manager advised that both greenfield and brownfield sites had been considered but there were very few available brownfield sites in the district.
· It was questioned whether the particular sites in Exmouth, Honiton, Feniton and Whimple that had received higher than average comments in the consultation should be revisited. The Assistant Director – Planning Strategy and Development Manager raised concerns about the consequences of revisiting those sites in terms of changing those decisions as the Committee did not have all the information to make informed decisions at the meeting and that a further report would be needed.
· It was questioned whether it would still be possible to meet the deadline taking into account the amount of work that still needs to be done on the Local Plan. In response a concern was raised about the amount of work, but reassurance was given that there was a lot of work progressing by officers to meet the achievable deadline.
· Clarification was sought on the comments received for the under representation of Exmouth’s strategic role. The Committee was advised that although Exmouth is the biggest town in East Devon it has environmental and other constraints that would not allow any further development.
· From the comments received in the consultation it was questioned whether there was a need to look to review 3 specific areas around the definition of employment, the settlement boundary and the coastal change management areas (CCMAs). The Assistant Director – Planning Strategy and Development Manager reminded the Committee that all comments would be taken into consideration and sought further guidance from the Committee about whether these areas should be addressed.
· Clarification was sought on what would constitute a ‘substantive review’ detailed in paragraph 5.5. The Assistant Director – Planning Strategy and Development Manager clarified that it would depend on the size of the site and whether this would have a consequence on the headroom of housing numbers. He sought guidance from the Committee for a steer on any particular sites of concern so that a further report could be brought back addressing these concerns.
· Point of Information - Lymp_01, Whim_08a, Whim_11, Feni_08, Otry_20, Exmo_17 had received above average comments and Exmo_20 had received significantly above average comments.
The Chair moved the meeting into debate and a statement was read out on behalf of Councillor Matt Hall which addressed the public perception that Local Plans focus too much on housing targets at the expense of community needs. The statement also believed that although Local Plans were essential for managing development and meeting housing needs it was crucial to ensure they are developed in a way that respect and understands the community character and needs, while making sure that local people believe that they have a stake in and a proper role in this important decision-making process.
Further comments included:
· There is a need to look at the Local Plan as a district and not just individual sites. If site Exmo_20 is removed, those houses will need to be located elsewhere.
· Ward Member for Exmo_20 thanked the public speakers for attending the meeting and supported all their comments.
· Support was expressed for Councillor Hall’s comments about respecting community character and it was suggested that Exmouth did not need Exmo_20 and could instead provide houses in existing locations.
· There is a need to listen to the public speakers. Increase the density of existing sites.
· Further study of the CCMAs was needed
· Water quality still needs to be addressed with South West Water.
· Reference was made about the duty to co-operate with other councils and it was stated that this council’s performance was 13% compared to other councils of 6%.
· It was suggested to remove wind energy and to focus solely on solar energy.
· There was a need to consider the high level of objections received for Exmo_20 and a suggestion was made to review Exmo_20. In response the Chair stated that Exmouth had currently allocated 1,455 homes in the Local Plan which was a growth rate of 10% and if Exmo_20 (700 homes) was taken out Exmouth’s growth rate would fall to 5% which was less than every settlement in the settlement hierarchy. The Chair advised that it would not be a sound decision to only review Exmo_20 and there was a need to review the sites that had received a higher number of objections that was listed earlier in the meeting.
· A direct quote made by Angela Raynor was mentioned by Councillor Paul Hayward that ‘there will be no excuses not to deliver 1.5million new homes’. Nobody wants to cover East Devon in houses, but we have no choice – they must be built somewhere!
Councillor Ledger proposed an amendment to the second recommendation, seconded by Councillor Brian Bailey to read as follows:
That Members noted the changes to the Planning Practice Guidance regarding two stage Regulation 19 consultations and identify any areas where they would like officer advice on potential changes to the plan that are not already being considered in the work programme set out in this report. These are to be addressed in a report to a future meeting prior to the second Regulation 19 consultation with materials being presented to the Committee. These areas are as follows:
Ø Water Cycle Study
Ø CCMA’s
Ø Duty to Co-operate
Ø Wind energy areas
Ø Sites Lymp_01, Whim_08a, Whim_11, Feni_08, Otry_20, Exmo_17, Exmo_20 and any further sites that officers feel should be brought back
Councillor Ledger advised that due to government reorganisation this was going to be East Devon District Council’s last Local Plan and that this Committee had a duty to get it right now as the next one could be done by people outside of East Devon.
Further comments included:
· There is a need to look at alternative sites if these sites are taken out of the Local Plan. The Assistant Director – Planning Strategy and Development Manager confirmed that the report would consider all the implications of removing a site allocation which included the housing numbers and alternative site provisions.
· The Council is in a difficult position as nobody wants to see this level of development, but we have no choice otherwise the government will end up doing this for us.
· There is a need to put some thought into providing higher density developments. In response, the Assistant Director – Planning Strategy and Development Manager addressed the difficulties in terms of the limited demand but acknowledged that this could be looked at for the second new community.
· There was a suggestion to reconsider villages and towns where communities wanted development, but permissions had been refused.
RESOLVED:
1. That Strategic Planning Committee endorse the proposed new local plan making timetable and work plan, including studies to be completed.
2. That Members noted the changes to the Planning Practice Guidance regarding two stage Regulation 19 consultations and identify any areas where they would like officer advice on potential changes to the plan that are not already being considered in the work programme set out in this report. These to be addressed in a report to a future meeting prior to the second Regulation 19 consultation materials being presented to the Committee.
These areas are as follows:
Ø Water Cycle Study
Ø CCMA’s
Ø Duty to Co-operate
Ø Wind energy areas
Ø Sites Lymp_01, Whim_08a, Whim_11, Feni_08, Otry_20, Exmo_17, Exmo_20 and any further sites that officers feel should be brought back
Supporting documents: