Local Plan – EDDC’s justification for employment land

17 Oct

Following on from the criticism by the Planning Inspector of the poor quality (and content) of the draft Local Plan (see below) we decided to look at just one part of the Local Plan to which he had referred – that of how much employment land should be in the Plan, where and why.    One of the reports in the Plan is headed “Report Setting Out Justification for Employment Provision in the Draft Local Plan 2011 – Report by East Devon District Council – 2011”.  This, of course, exercises our minds because of the way that Sidford Fields was slipped in at the last minute (with no consultation or background information or justification).

The report is brief – 9 pages.  The first two pages consist of statistics of employment in EDDC’s major towns:  how many people are in active employment, whether they commute in or out to jobs etc.  The next 7 pages consist of a record of the Local Development Framework Panel of Tuesday 1 November 2011 concerning employment land provision and sites.  Oddly, it mentions the Tym report – which the Panel actually refused to debate in public and which it subsequently ignored in order to go with recommendations from the East Devon Business Forum – which is not mentioned at all in this paper.  The fact that the East Devon Business Forum actually decided on how much employment land there should be is never mentioned at all.

Several pages are devoted to trying to match up housing to employment land.  This is, of course, now redundant, as the lack of 5 year land supply is resulting in houses being built in areas which were not anticipated by EDDC at the time of this report and other employment and housing changes that have since happened.  For example, Axminister lost many jobs when the carpet factory downsized, Seaton lost all the affordable homes on the Tesco site (where housing numbers were reduced), Feniton has had growth well beyond its needs, Ottery’s regeneration has stalled, etc.

There are some weird paragraphs:  for example

“2.7  The above assessment is, however, purely numeric in nature.  It does not take into account “objectives” and “vision” for different towns, neither does it address commercially credible potential job creation and new employment centres/provisions, in simple terms where the market can and might want/be able to provide jobs”.

Er, sorry – you haven’t matched employment need to towns on the basis of objectives and vision?  You haven’t factored in known employment opportunities that are almost certain to come forward?  Why not?

It goes on to say EDDC has had problems working out how much employment land the district needs (see paragraph 2.11).  And the report does not include windfalls (2.12).  It admits that Honiton is seen as the best place to attract employment (2.13) but says that because Exmouth NEEDS employment then more land ought to be made available there.  But if everyone prefers to go to Honiton, then surely that land will remain empty?  How do you make a silk purse out of a sow’s ear when all your silk is in Honiton and all your sow’s ears are in Exmouth?

In Section 3 (very brief) it addresses the possibility of windfalls in rural areas but Section 3.2 is a hoot and is written below EXACTLY as it appears in the report:

“3.2  In villages and rural areas windfall developments will account for a part of new employment provision.  Development management policies in the new Local Plan will require, land and buildings, on the site of new residential sites, specifically on sites where 10 or more dwellings are proposed.  Also policy of the plan allows for other sites to come forward for employment use”.


The report ends with two paragraphs on “West End Employment provision” where a differing approach is proposed (though it does not spell out exactly how it differs).  Unfortunately, it relies heavily on the inter-modal freight facility – you know, the one that doesn’t now exist because Sainsbury’s pulled out of building its warehousing leaving an ENORMOUS amount of prime employment land available.

And there you have it – EDDC’s justification for its employment land.  No wonder the Inspector highlighted the need for a new position paper on it (and on housing and affordable housing)!

Midnight oil at Knowle …. all paid for by us, of course.  Though as officer time is not computed per job, we will never know exactly how much the midnight oil has cost us.

The document in full is HERE.



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