Sorry this post is long and involved, but the new local plan is important and complex.
There is a shorter post here : https://kennvalley.mycouncillor.org.uk/2023/01/15/tdc-local-p`lan-short-version/
The Teignbbridge local plan is published in the agenda for full council of 12 Jan including the final list of sites chosen for inclusion.
All documents are at : https://www.teignbridge.gov.uk/planning/local-plans-and-policy/local-plan-review-2040/full-council-documents-12-january-2023/
The local plan itself is at : https://www.teignbridge.gov.uk/media/pereddfm/appendix-a-proposed-submission-local-plan-2020-2040.pdf
There is an interactive policies map which helps to see the exact locations and boundaries of these developments: https://exetercc.maps.arcgis.com/apps/webappviewer/index.html?id=104198cc3aaa472faf62cfad198ebd49
Concept plans of larger sites at https://www.teignbridge.gov.uk/media/fsxanvyc/appendix-5-draft-concept-plans.pdf
Background
The current TDC local plan is going out of date. The allocated sites are running out, and TDC is required to provide 741 houses per year, when the old plan assumed 620. This has escalating consequences for Teignbridge planning. TDC is required to show that it has a “land supply” i.e., enough sites allocated in the local plan to provide the house building numbers. If the plan is out of date, or there are not enough allocated sites, or not enough houses have been completed by developers, this can be cited as grounds for appeal, so applications will increasingly be granted disregarding the local plan policies: “Planning by appeal”. Teignbridge is now dangerously close to the 75% threshold where further penalties start to apply. Getting the new local plan will ensure local control with protection from these punitive measures. The new plan is important to avoid this in future.
Getting to this stage has included a “call for sites”, inviting landowners to put sites forward, several consultations on sites and policies. Councillors have been able to discuss and visit sites with officers and explain any local factors and community concerns, so that officers can assessed the relative merits and constraints, then write a plan with the best policies and select sites to meet the required housing numbers.
Housing numbers
For years we have been reminding people that housing numbers are imposed by government using the standard formula. The new local plan has been prepared assuming that these are required. In December just days before the local plan was put forward for the final consultation, Home secretary Michael Gove announced that the number would be ‘advisory’, so why is the plan going ahead?
Importantly Michael Gove has not changed the law. He also said that the standard formula would remain as the number expected, but that councils might be able to request reductions under certain circumstances. He did not suspend the three-year delivery test, and if we had stopped the plan, Developers would use this in appeals. He did say that if plans were in the final consultation stage that we have just reached now, appeals would be refused on 5-year land supply.
This uncertainty in the future rules makes preparing a 20-year plan very difficult. Michael Gove explicitly told the Newton Abbot MP that TDC should push ahead with the local plan, but our (Teignbridge Lib Dem group) big concern is that if we had approved the plan with government numbers, then the law changed later, it would be too late for us to look again at the numbers.
A lot of work went on behind the scenes before the council meeting on 12/1/23 to bring in “Recommendation 10”. This very important paragraph means we can submit the plan in line with current law, but it provides that if the law changes, we can review the plan, and have the option to adjust the numbers in line with genuine local need, and local constraints.
How many houses SHOULD we allow?
It’s an important question, and until December it was irrelevant. People need homes, and it is very difficult now for your people to get on the housing ladder. Average house prices are 8-10 times average salaries. Thirty years ago, they were 2-3 times salaries. We definitely do need to be building houses but we need more affordable homes. Under this government’s laws we can only do that by the council building them (which we are now) or by allowing the expensive high profit housing and requiring a ratio of affordable housing to goes with it (which we do).
The “standard formula” for required housing numbers, uses affordability. The logic runs like this. Teignbridge is an attractive place to live. People move here bring money from affluent areas, and house prices are high. Industry, and employment is limited in our rural area, and salaries are, on average, low. This imbalance means that in Teignbridge houses are less “affordable” than in other areas. The standard formula seeks to reduce house prices by increasing our required number of houses. TDC has a 41% affordability uplift over the underlying need. Some other areas do not have this uplift. CPRE (Campaign for the Protection of Rural England) estimates that Teignbridge needs 540 houses per year, not 741 as currently required.
The problem with this is that the link from requiring more site allocations to actually having more affordable houses is extremely tenuous, and the damage inflicted by the uplifted numbers is real and urgent. Having more sites allocated does not mean developers are required to bring them forward. There are no constraint or penalties on developers delivering houses quickly. Developers may want to keep prices high, and some claim they slow their delivery to maintain prices. Teignbridge has no control over that but faces consequences if developers do not deliver.
Once houses are built, they may be bought by local people, or they may become second homes, holiday or short-term rental accommodation. Government policies do not address this, but TDC are seeking policies such as escalated council tax for empty properties to counter this. I do not believe that the 41% uplift is effective. I would scrap it and seek other methods to ensure houses are available and affordable for genuine local need. Recommendation 10 should enable us to do this in future.
Policies
There are also many very good policies in the new local plan. We have achieved a phased approach to carbon neutral housing, in a much shorter timescale than building regulations or government legislation. There has been push-back from developers on this.
We have specific policies to encourage renewable energy provision. In effect there is a chapter on climate change measures where the old plan had a policy.
There are improved policies on environment and biodiversity. Policies encourage publicly available green space, wildlife corridors and inter connections to future sites. The concept plans for sites show these features too.
I am pleased to have argued successfully for a cut and fill policy. Development generally results in export of surplus soils and DCC try to meet demand for such waste. There have been 3 large applications for inert waste landfill in our ward in 3 years. This is a major issue for our communities. For the first time the local plan states (in GP1 sections 12 and 14) that developers must minimise the export by accommodating surplus soil and inert building waste on site as much as possible. This means it would be a valid planning reason to object to an application if it would generate excessive unnecessary exported material.
CIL
Where development occurs, the developer pays “Community infrastructure levy” CIL which funds the provision of the services needed for the new population. If development is within a parish a proportion goes to the parish council to use to benefit the community as they choose.
It is difficult to calculate CIL payments in advance. The CIL is calculated based on the net increase in floor area of new housing (we don’t know how big they will be) at a rate determined and varying year by year (we don’t know what the rate will be when the payments come due) And depending on the zoning, with higher rates for rural development than urban. When houses are built on greenfield, the land is clearly rural before, and urban after, but the payment will be different if it is calculated before or after the reclassification. If the Parish council has a neighbourhood plan, as Ide does, the Parish keeps 25% of the CIL. The other parishes which do not have local plans will keep 15%. These rules may change in the coming years. In comparison to parish council budgets, CIL payments are often very large.
Sites
In preparing the plan Teignbridge have taken a view that new housing should be close to the facilities, employment and transport networks of Newton Abbot and Exeter. While I support the excellent new policies and emphasis in the plan, and I understand the urgent need to Teignbridge to have an updated plan, I do not agree with the target numbers and supporting the plan does not indicate that I support every allocation in it.
Where we or the community have concerns about a site, we have represented these to officers in the hope of persuading them another site is more appropriate, but also so that if the site is allocated the outcome is the best it can be for the existing and future communities. I have drawn out key features from the site proposals and summarised here.
EE1 Markhams farm
This site attracted strong objections. The land is part of the county farms estate, and is very high quality agricultural land. There are constraints on the vehicle routes especially Alphington road. A petition to save the county farms started by Cllr Alison Foden attracted over 2000 signatures but DCC have not withdrawn the site.
900 homes providing a housing mix which delivers a minimum of 20% affordable.
A minimum of 20% affordable housing and a wide range of housing needs, including a 50-bed extra care housing scheme
The policy includes a central square, village green or similar public space, and community building. A new convenience store of no more than 280sqm net floorspace closely related to the neighbourhood hub.
A new 2 form entry primary school including early years, on a 2.3-hectare site with the potential to expand to 4 form entry in the future, closely related to the neighbourhood hub.
At least 12 hectares of public open space across the 74 hectare site (for comparison northern fields is 7 hectares)
It will avoid development of the upper slopes and ridges of the site.
Linked green spaces and corridors through the site up to West Exe Countryside Park, which shall be located to the south of Markham Lane
36 full sized or 72 half sized allotment plots.
Extension of existing bus services
vehicular access to the site to be taken from the Shillingford end of Markham Lane, and from Ide Village Road with a new access road emerging at the old Springwell Nursery.
Low traffic neighbourhood built with full site permeability. modal filtering will prevent through journeys.
Markham Lane and Polehouse Lane downgraded and to be restricted to access for farm vehicles only.
New and/or improved safe and attractive pedestrian/cycle links with safe road crossing points through the site. This will include improvements for pedestrians and cyclists at the Alphington roundabout and Crabbe Lane. Also improved connections to Shillingford Abbot; A377 to east of A30 roundabout, Waybrook Lane and Sustainable Travel Route E15, West Exe Countryside Park.
EE2: Peamore and West Exe
99 hectares in total. Land west of A377 is Shillingford parish, East is Exminster parish.
- Peamore – A 75 hectare area that will include approximately 750 residential units
- West Exe Business Park – a 24 hectare area that will include approximately 150 live/work and/or essential worker dwellings and about 20 hectares of employment land.
50 bed extra care.
A convenience store and other retail units.
A new 2-form entry primary school including early years, on a 2.3 hectare site with the potential to expand to 4-form entry in the future, closely related to the neighbourhood hub on land to the east of the A379.
At least 11 hectares of public open space across the site.
at least 17 hectares of SANGS to be provided on site and/or within the area allocated as West Exe Countryside Park, to create a series of linked green spaces.
A low traffic neighbourhood built with full site permeability by foot and bicycle.
A segregated pedestrian and cycle route along the A379 connecting to existing routes to Kennford and Marsh Barton.
Cycle links to: To Matford Brook Academy; either side of the A379; the Shillingford St George Bridleway on site SANGS, Waybrook Lane; Ridgetop Park.
Additional passing points along Days Pottles Lane from the eastern edge of the site to Exminster at various points along its route.
9.16 The site lies within Exminster Parish – but in fact the A379 is the boundary between Shillingford and Exminster parishes
EE3: West Exe Countryside Park SANGS Opportunity Area.
SANGS is Suitable Alternative Natural Green Space. Where development occurs within 10 miles of the Exe Estuary protected habitat, this places extra load on the habitat, so SANGS sites are provided to draw the extra recreational users away from the sensitive habitat, to mitigate the extra population.
This will initially serve developments at Markham Village and Peamore. The SANGS has good design criteria, a mix of formal and informal paths, secluded areas, ridgetop access.
EE4: Attwells Farm
This is a site that attracted strong opposition from the community in Whitestone.
The main concerns as I understand it are loss of green space, and vehicles accessing the Whitestone roads.
The proposed policy for Atwell’s farm is a development on 15 hectares within a wider site of 39 hectares. It will be approximately 300 homes.
There will be provision of land within the development adjoining Exwick Heights Primary School for uses associated with the school.
At least 4 hectares of public open space across the site. The site is currently used as public green space but as I understand it, no access rights exist. Only part of the site is to be developed leaving most as public green space WITH access rights.
At least 6 hectares of SANGS to be provided on site including linked green spaces and corridors through the site to connect with Whitycombe Way Valley Park and Kinnerton Way County Wildlife Site.
Low traffic neighbourhood (no through traffic).
New vehicular access taken from Kinnerton Way. No vehicle connections to be provided onto Rowhorne Lane, with the exception of an access for emergency vehicle use only. No vehicles will be accessing the Whitestone road. All vehicles will access the site from Exwick via Kinnerton lane.
Walking and cycling routes to Kinnerton Way, Exwick Lane and Exwick Heights Primary School; Rowhorne Lane, extending the active travel network of Exeter into and through the new development.
Extension of existing bus services.
Part of the site lies within the boundary of Exeter City Council. Whitestone parish will only be entitled to CIL Payments for houses that are in the parish, and we don’t know exactly where the houses will be.
The final consultation
The plan now has one final stage of consultation. Feedback from this final stage will be sent with the plan to the secretary of state for the final decision. It is important to submit your views, and comment on any aspects, good or bad. The consultation will end at 12 noon on Monday 13th March 2023. Please make your views known by then. At the time of writing the consultation is not yet open and the link to post feedback is not yet available.
Please feel free to email us and respond to the consultation. Thank you.
Andy Swain, Alison Foden, Charles Nuttall and Alan Connett
