Why do you feel this way and do you have any other comments?

We do not understand how the proposed policy of requiring developers to produce a masterplan will work on large sites in multiple ownership unless all land ownership parties are included. That type of masterplanning needs to be undertaken by a publicly accountable body. Therefore any development applications for less than say 80% of these strategic sites must be considered premature. The road junctions must be improved.

Why do you feel this way and do you have any other comments?

East Gate (52) presents very significant issues in terms of impacts (known or potential) on archaeology and designated heritage assets. Inclusion of these proposals, with the level of detail/expectation of housing numbers, etc. is inappropriate without prior assessment and evaluation to inform the nature and scale of development that might be possible. Any development in these locations has to be heritage- led. In these cases, weight seems to be being placed on S1.3 (brownfield sites close to the city centre) and the density aspects of Principle 2, rather than S1.9, S1.12, S2 Principle 1, S2 Principle 2 (gateway sites), Polies HH1-3.

Why do you feel this way and do you have any other comments?

In relation to policies associated with specific allocations, SWW support the inclusion of wording reflecting that proposed and supported above. Additionally, SWW would welcome more ambitious policies, like those seen within the Water Lane DPD, including the requirement of on-site rainwater storage for the purposes of green and blue infrastructure within proposals. Further comments on particular draft allocations relating to infrastructure requirements and impacts are stated below. Water Network: Further hydraulic assessment is required to determine the network impact of these developments and identify the necessary reinforcements. The likely interventions will take circa 18 months to design and construct. In relation to the above sites, we welcome the opportunity to have early discussions with Exeter City Council about masterplans and development forecasts as the sites come forward so that any investment needed can be timed appropriately. All other proposed allocations are unlikely to require significant network reinforcement but will be assessed as they come forward to determine whether there is a localised impact on the network which needs to be mitigated. Where network reinforcement is required, this is funded through the Infrastructure Charge that SWW receives from developers. Wastewater Network: Although initially there should be no immediate impact on the performance at overflows in the downstream network, the development information will be used when assessing future overflow performance with a view to meeting the storm overflow discharge performance targets which SWW has committed to meeting under Defra’s Storm Overflow Discharge Reduction Plan.

Why do you feel this way and do you have any other comments?

We support the inclusion of this area in the list of strategic development sites. We agree that much more work needs to be done to develop specific proposals (para 15.39). At this stage we have the following points. The apparent loss (to home-building) of the present Triangle car park site is sensible: It is in line with the need to reduce car parking opportunities in the city centre. However, it will be important to ensure that the height and mass of any development there does not overwhelm the adjacent housing in Clifton Road and Codrington Street. Development proposals have been submitted for the old police station site (21/1564/OUT) and are being worked up for the Clarendon House site. Both of these include purpose-built student accommodation (PBSA). Policy H8(b) of the Draft Plan states that a condition of planning permission for PBSA developments is that they “do not contribute towards an excessive concentration of purpose built student accommodation in the locality”. Given the existence of PBSA already within the strategic site area (the Depot, the Barn, Central Living, Printworks, Kingfisher) and close by (James Owen Court, Trust House) there is a strong case for including a ban on any further PBSA in the policy statement for the Eastgate site. The Paris Street/Heavitree Road/Western Way roundabout detracts from a liveable environment. While recognising its importance in the city’s current highway network, we suggest that the policy wording explicitly states that proposals to improve the overall environment particularly relating to policy sections C, D and E should not be constrained by the present traffic infrastructure.

Why do you feel this way and do you have any other comments?

The proposed strategic allocation at East Gate is a large, complex and somewhat disjointed group of sites. Some of these are relatively high rise, while others are low rise, or are undeveloped but within the context of low rise housing. Many buildings within the site appear to be in active use, while some appear to be empty and one is a car park. Consequently, we query whether it may be preferable to identify and consider for allocation at least 5 distinct sites/areas within the proposed East Gate allocation, while maintaining a strategic/masterplanning approach insofar as this may add value? The non-strategic residential allocation of 12-31 Sidwell Street, and the employment allocation at St Luke’s Health Campus are also very close to the East Gate group of sites and may benefit from a linked approach to evidence and/or masterplanning. While not as sensitive as North Gate and South Gate, parts of East Gate are located within conservation areas, are archaeologically sensitive, and there are heritage assets in close proximity. We therefore welcome policy criteria H(i) and (ii). However, as elsewhere we do consider that insensitive development in this location – in particular tall buildings – may have the potential for more far reaching impacts on the city skyline and views of or from key heritage assets including Exeter Cathedral and the Castle complex. It would also therefore be beneficial for additional policy criteria for this site (such as maximum building heights) to be informed by a strategic evidence base relating to key views and settings.