Sidmouth Chamber of Commerce

President : Mr Derek Parry
Chairman: Mr Steven Kendall-Torry
Vice-Chairman: Mr Edward Willis Fleming
Treasurer: Mr Matthew Portman
Membership Secretary: Mrs Edwina Ford
Secretary : Mrs Sylvia Brownlee

Please reply to: The Secretary

Cllr M Williamson, The Chairman, Development Management Committee, EDDC

Dear Sir,

Submission by Sidmouth Chamber of Commerce
Local Plan Consultation

Employment Land

We would like to draw attention to our submission in January 2012 which dealt specifically with the allocation of employment land across the District and for Sidmouth in particular. We identified flaws in both the methodology employed and also in the calculations used.

The miscalculation, which has been admitted by the Policy team, is very serious. There can be little doubt that the compiler of the tables concerned intended to use ‘net out-commuting’ figures but used ‘out-commuting’ figures instead.

Had the correct numbers been used, the employment land allocation across the District would have been radically different. The total allocation would have been about 20 hectares less. In Sidmouth, the allocation would have been 1 hectare rather than 5. The over-provision in Sidmouth is especially high because Sidmouth enjoys an exceptionally high level of job retention and is a net in-commuter of jobs.

Members will be aware that the over-provision of employment land in Sidmouth has been hugely controversial, with a petition signed by almost 4000 in protest against the allocation. In all probability, if the allocation had been correctly calculated, the protest would have been restricted to the choice of site alone.

Our submission of January 2012 was a crucial contribution to the debate over employment land allocation and we are extremely unhappy that this document has been deleted from your web-site, and therefore not available to the general public.

These problems were compounded by a misrepresentation of the Chamber position regarding employment land provision in Sidmouth. Minutes of the Local Plan Panel indicate that Sidmouth Chamber of Commerce was in favour of employment land provision in Sidmouth of 3 hectares. This is emphatically not the case, as previous minutes and submissions (those that are still available and not deleted) confirm. We understand that this error is to be corrected, but would point out that it has existed throughout this crucial consultation period, so the general public has been seriously misinformed.

This unfortunate situation has been further distorted by a misrepresentation of Sidmouth Town Council’s position regarding employment land in Sidmouth that occurred in the last consultation document. This stated that Sidmouth Town Council supported an employment land allocation north of the A3052. We pointed out in our consultation response of January 2012 (since deleted ) that this was not the case. The Town Council’s submission during this consultation phase confirms this.

Remarkably, the Chairman of the Local Plan Panel, Councillor Mike Allen, has recently stated publicly that he was ‘misled’ by an officer as to the views of the Town Council prior to the allocation of employment land in Sidmouth and specifically with regard to the Sidford site. He has indicated that he is likely to refer the matter to the Scrutiny Committee. We can only assume that other members of the Local Plan Panel were equally misled.

We conclude that the process by which employment land allocation in Sidmouth has emerged is very seriously unsound – a shambles in fact. The wrong calculation, the wrong report of Chamber and Town Council opinion, and the wrong information to the Chairman. What, if anything at all, was right?

It is perhaps therefore not surprising that opposition to the proposals has been so strong, and that confidence in the integrity of the Local Plan process has collapsed.

We urge that the Development Management Committee look at the employment land allocation with a fresh view. Had all these mistakes not been made, we think it extremely unlikely that the employment land allocation of 5 hectares at Sidford would have been even contemplated.

There is no evidence to support such a huge allocation and the site is clearly unsuitable. Our reasons for saying this occur in previous contributions, and will be very well explained in other submissions, so we will not repeat them here. However, we will emphasise the following points that may not have been made previously:

1. In recent months, we have entered the second phase of a ‘double dip‘ recession. Economic growth has been significantly negative since, for example, the now-discarded Regional Spatial Strategy was developed in 2008. This further diminution in economic activity has not been reflected in EDDC Local Plan policy. It is, however, reflected in experience on the ground where employment sites lie vacant in considerable numbers across the District. Moreover, predictions of economic growth going forward are also significantly lower.
2. The lack of economic growth will also be reflected in reduced demand for housing. Economic growth is a key driver of housing need, so demand for housing is going to be less than anticipated. This is reflected in the first responses to the Cranbrook development, which are reported to be disappointing, and in the continued low levels of house sales in the District.
3. The inter-modal freight facility is effectively no more and has been superceded by a large Sainsburys distribution centre. The inter-modal facility was not included in employment land allocation as it was ‘a special case’. This was a highly dubious position in the first place, but must now be ripped up. The land in question should be added to the employment land allocation for the District.
4. There has been widespread concern over the role of the East Devon Business Forum in the generation of the employment land numbers, and persistent complaints from members of the public concerning the undue influence that the Forum has enjoyed over Local Plan policy. The Forum’s name is misleading. East Devon businesses are predominantly small. The membership criteria thus debar 95% of East Devon Businesses.
5. In the case of Sidmouth, we strongly support the Town Council and others in advocating the full use of the Alexandria Industrial Estate. This area of employment land is chronically under-used at present. We are very much opposed to development outside the Built-Up Area, and therefore within the AONB, whilst this land is available.
6. Throughout the development of the Local Plan thus far, EDDC has consistently exaggerated the level of unemployment in the District. This stems from a rare mistake by Roger Tym and Partners, who in other respects have produced a good report. Roger Tym used Nomis data to produce their unemployment figure, but Nomis is known to be extremely unreliable at District level due to the small sample sizes used. Nomis does not, in fact, publish District-level figures for this reason. Sidmouth Chamber challenged the unemployment figures when they first appeared in the Tym report: we knew that the figure quoted of 7% was incorrect and we doubted that unemployment was rapidly accelerating across the District as Tym indicated. Our challenge was rejected at the time, but our concerns have since been vindicated. Tym now concede that Nomis should not have been used, and we believe this is also the view of the Policy team. It is fair to say that proponents of large scale employment land provision within the authority seized on the Tym figure of 7% as justification for their position, and it became something of a ‘scare story’. The true figure for East Devon is somewhere between 2% and 3.5% depending upon the way in which unemployment is assessed. Buried in the Sustainability Assessment by LUC is the genuine figure of 2%. In Sidmouth, the figure is very low at around 1%. We wonder what the employment land allocation in East Devon would have been if the Local Plan Panel had been given the correct figures for local unemployment.

Housing

We will not repeat points previously made, but would reiterate our call that Members be made aware of ALL submissions made previously. If documents cannot be recovered, we can supply copies, but we are not sure how many other papers have been lost from other submissions.

As with employment land, the housing allocation is clearly too large and is not justified by evidence. Specifically, relying upon the Regional Spatial Strategy of 2008, discarded and now hopelessly out-of-date, is not appropriate. If the Regional Spatial Strategy were to be re-created today under the same terms as used in 2008, but using current economic data, the housing recommendation for East Devon would be less than 13000 rather than 17000.

With regard to Sidmouth, we feel that the allocation of a further 150 houses is reasonable, and we agree that these should be incorporated within the existing Built-Up Area. We think that the opportunities for ‘windfall’ sites have been underestimated and we anticipate that these will come forward regularly throughout the Plan period. We are prepared, reluctantly, to accept the Manstone Depot allocation.

Knowle

The debate over the proposed relocation of EDDC from Knowle is not the remit of the Local Plan, but we take the opportunity to point out that the relocation is fraught with problems, and is highly unlikely to be financially deliverable in the short to medium term. However, we acknowledge that if the property market improves significantly over the next few years, a move may perhaps be possible towards the end of the Plan period.

Parking

However, we strongly object to the boundaries drawn by the Policy team with respect to the redevelopment of the Port Royal and Knowle sites. In both cases, they involve the loss of substantial car parking, which is of vital importance to the vitality of the town centre. Parking is of major importance to the economic future of Sidmouth and it is completely unacceptable to have a Local Plan which commits to its reduction. When the vitality of Sidmouth’s town centre was discussed at a recent meeting of the TAFF created by the Scrutiny Committee specifically to consider town centre vitality, the issue of parking was the major subject. Everyone present agreed that Sidmouth’s biggest problem was parking provision. A Local Plan which exacerbates the problem is inconceivable.

We recall that the Chamber of Commerce participated in an EDDC-organised group charged with considering the redevelopment of Port Royal. This group received only one instruction from Ms. Kate Little, Chief Planner: ‘on no account must a single parking space on the Ham be lost during the redevelopment process‘. We suggest that nothing has changed since that instruction was issued.

We therefore strongly urge that the boundaries of these two sites on the Inset Map be changed so as not to include vital car parking capacity. We would like to point out that car parks in Sidmouth are ‘cash cows’ for EDDC and that reducing car park capacity is therefore counter-productive to the delivery of the two sites, as well as having an adverse effect upon town centre viability.

Tourism

We note that EDDC are proposing to employ three Communications Officers to promote the image of the District Council, but continue to refuse to employ anyone to promote the District as a whole. This reflects a depressing attitude within the authority towards tourism which is a major employer in the District. This argument is well-rehearsed and again we will not repeat things said in previous submissions. However, we take the opportunity to remind the Committee that South West Tourism reported East Devon as ‘going downmarket’ faster than any other West Country District. We see this as an alarming trend, which the Local Plan should seek to correct.

We can only urge the Development Committee not to listen to those who have previously held sway and demean tourism.

Supermarkets

It has become clear that the employment land allocation proposal for Sidford has arisen from an approach to Fords and other Alexandria landowners from Morrisons. The Sidford site is being proposed in order to facilitate a new large scale supermarket at Alexandria.

There is no justification for another supermarket in Sidmouth. We already have Waitrose and Lidl, and also the Co-Operative and Tesco in the town centre. We also have a good range of independent providers of groceries and basic essentials. In the past twelve months we have seen Sainsburys open in Ottery St. Mary, Tescos in Seaton, Lidl in Exmouth and Waitrose in Exeter. We therefore strongly endorse the recommendation of Grimleys, consultants to EDDC, that another supermarket would adversely affect the viability of the town centre. We have consistently opposed any further out-of-town retail provision for this reason.

Moreover, the Alexandria location is not suited to a new supermarket for highways reasons. Many of the users of the supermarket, i.e. residents of Sidmouth, will inevitably access the facility via the already heavily congested Alexandria Road. We think a new supermarket, even with a new access off Bulverton Road, is unlikely to obtain consent on highways and viability grounds. We face the prospect of a very unpopular employment land allocation at Sidford in order to accommodate an unwanted supermarket proposal that has little chance of coming to fruition.

If EDDC are minded to promote a Morrisons when their own consultants advise against, and when the townspeople are opposed, we ask: ‘What is to prevent it all happening again with another supermarket operator on the site at Sidford?’ Nothing, apparently. We understand from the Policy team that there would be no technical restriction upon retail uses at Sidford. We predict that this would be the inevitable outcome, as it has at Liverton Business Park at Exmouth, now the home of McDonalds, and Heath Park at Honiton, where retail is taking over.

Yours faithfully,

Steven Kendall-Torry
Chairman

The Secretary, Sidmouth Chamber of Commerce
3 Fortfield Chambers, Sidmouth, Devon, EX10 8NY
Tel: 01395 514011
E-mail: sidmouthchamco@tiscali.co.uk
www.sidmouthchamber.co.uk