Do you have any comments to make on any of the other evidence documents?

Local Plan & Evidence Base The National Planning Policy Framework (2023) states: 102. Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities, and can deliver wider benefits for nature and support efforts to address climate change. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate. Sport England’s view is that, in order to meet the requirements of the National Planning Policy Framework (NPPF), this should include a strategy (supply and demand analysis with qualitative issues included) covering the need for indoor and outdoor sports facilities, including playing pitches. We note the Council’s 2022 completed Playing Pitch Strategy (PPS) which covers pitch sports and tennis. No regular delivery meetings of the PPS have yet been held since completion. There is no up to date current assessment for swimming pools, sports halls, golf courses, bowls, athletics tracks, cycling, equestrian, motor sports etc which the Council. Discussions have started regarding this sporting assessment to provide evidence for the development plan. The Playing Pitch Strategy for ‘in date’ the data in studies should not be more than 3 years old (from the date of the data and not the adoption date). The Built Sport Facility Strategy for ‘in date’ the data in studies should not be more than 5 years old (from the date of the data and not the adoption date).

Do you have any comments to make on any of the other evidence documents?

Landscape Sensitivity Assessment We welcome the publication of this document, however query why some sites are not included in this study. This includes, but may not be limited to, the omission of sites 140, 89, 94, 136, 80, 144, 125, 18. This highlights the inconsistences between the various evidence sources and documents as to whether some of these sites are allocations, previous allocations or just not mentioned. For example sites 140 and 89 are in the Plan and on the Policies Map as site allocations, however are not mentioned on the site allocations map, nor in the Landscape Sensitivity Assessment. This could be confusing for the reader. It is beneficial to include sizeable sites which already have planning permission, or that have been previously allocated to give the reader a full picture of development – however this should be made clear to avoid confusion.

Do you have any comments to make on the sustainability appraisal?

Site Allocations We understand that some of the site allocations may have been previously allocated in the Exeter Core Strategy – this should be highlighted in the Sustainability Assessment to inform the reader, especially if the sites are not undergoing current/further assessment. Whether there is a need for further assessment of these sites (including for cumulative impacts) should be considered. Where the HELAA identifies that a site triggers a SSSI Impact Risk Zone (IRZ), it will be necessary to assess (through the SA/SEA) whether there is a potential impact pathway between the development and the site, and if there is, identify the likelihood of being able to mitigate those impacts and recommend the measures necessary. The Local Plan policy/proposal will then need to secure those necessary measures. Natural England is unable to confirm whether this process has been followed for all allocated sites (residential and employment) because the detailed SA assessment tables in Annex 1 only recognise distance to protected sites, and the SA findings only discuss the 6 strategic sites at this stage. When further allocation policies are included in the next iteration of the Plan, it is expected that the SA will be updated to discuss these more thoroughly, including mitigation recommendations for development on B&MV soils. Water Lane – Reference 15 (Strategic Policy) We would expect that this discussion would mention the potential for a direct pollution pathway into the Exe Estuary SPA, due to the location of the site. This site includes areas of Priority Habitat (coastal and floodplain grazing marsh) and Open Mosaic Habitat. These should be discussed with any recommendations for mitigation required. SA Objective 10: To conserve and enhance biodiversity and geodiversity Natural England agrees that negative effects on biodiversity, geodiversity and landscape are currently uncertain as these will depend on factors such as design of the development. However, if specific mitigation is required to gain further certainty, this should be included as recommendations for policy text. The LPA should have reasonable confidence that evidence is available to demonstrate mitigation will be possible and adequate to address impacts on ecological assets. Flood Risk and Coastal Change We would welcome discussion of the approach to coastal management within the Plan area, as set out in the Durlston Head to Rame Head SMP2 and the sources of baseline data already identified in the Sustainability Appraisal Report.

Do you have any comments to make on any of the other evidence documents?

Habitats Regulations Assessment of the Exeter Plan (Full Draft Plan) – Footprint Ecology – 22nd October 2023 Paragraph 2.4 We would be cautious with the statement here that ‘Impacts such as fragmentation or loss of supporting habitat associated with European sites can therefore also be ruled out at an early stage.’ Natural England has particular concern about loss of potential functionally linked land (i.e., habitat supporting SPA birds), where proposed greenfield site allocations (e.g., sites at Newcourt Road) are near to nature conservation sites with bird interests (e.g., the Exe Estuary SSSI/SPA/Ramsar). The likelihood of the potential for this loss should be assessed through the HRA and, if necessary, the conclusions supported by appropriate survey data. Policy STC1: Sustainable Movement (Strategic Policy) We note the inclusion of ‘supporting opportunities for sustainable water-borne transport’ in this policy and would expect to see this discussed in the HRA due to the Exe Estuary’s status as a SPA and RAMSAR site. Natural England agrees with the findings of the interim HRA that further evidence is required to determine that there will be no adverse effects on the integrity of the European sites. This should include the areas of recreation, hydrological issues and air quality.

Do you have any comments to make on the sustainability appraisal?

While we do not wish to comment on the Sustainability Appraisal in detail, we note that the methodology used for SA Objective 12 (to conserve and enhance the historic environment including the setting of heritage) has used a purely distance based approach ‘due to the lack of heritage assessment available’. This highlights a key gap in the evidence base informing this local plan. Unfortunately, the site appraisals contained in Annex 1 therefore do not follow the advice contained in our guidance on Strategic Environmental Assessment and Sustainability Appraisal. These appraisals say nothing about which assets may be affected, their significance, the nature of potential impacts or how these impacts could be mitigated. We believe that there are a number of sites which, if delivered well, could result in positive effects on the historic environment. We therefore hope that the Regulation 19 version of the Local Plan will secure this through appropriate policy and evidence and a robust Sustainability Appraisal in relation to the historic environment. Historic England recommends proportionate HIA of potential site allocations following the 5 step process contained in our Historic England Advice Note 3: The Historic Environment and Site Allocations in Local Plans. This can be used to assess the likely heritage impacts of proposals and to advise on design parameters and policy criteria to minimise or mitigate impacts and secure enhancements. However, in relation to key strategic sites which already benefit from a number of policy criteria (e.g. in relation to archaeology and the settings of heritage assets), it may be sufficient for the Council to prepare a strategic evidence base relating to key views and settings in order to inform specific design parameters such as protected views and/or appropriate building heights. This could then inform policy criteria in the plan as well as subsequent development proposals and planning decisions.

Do you have any comments to make on any of the other evidence documents?

Infrastructure Delivery Plan Historic England very much welcomes the identification of Exeter City Wall repairs within the draft Infrastructure Delivery Plan as a target for £1.5 million of infrastructure spending as part of wider green infrastructure provision. The walls are a key aspect of Exeter’s unique cultural heritage and an asset to be enjoyed by residents and visitors to the city. We look forward to working with the Council as a delivery partner to assist with the identification of potential projects, funding needs and sources.

Do you have any comments to make on the sustainability appraisal?

We have no significant comments to make regarding the Plan’s performance against the sustainability appraisal objectives. The sustainability appraisal acknowledges the conflicts associated with proposed housing allocations within proximity to flood zones 2 and 3 around the city. It is inevitable that housing allocations will present an overall negative effect when examined against SA Objective 13. It will be a matter for the council to determine housing allocation applications against relevant policy that aims to mitigate the effects of development in areas at risk of flooding to ensure the subsequent development can be considered sustainable. Alternatives on housing allocations are limited, with this in mind the need to ensure adequate mitigation techniques, along with water infrastructure financing and delivery become critical for successful implementation of the plan. It is important too that the appraisal acknowledges the impact of additional development combined with climate change, upon the combined sewer network and that ECC is content that the Plan adequately ensures mitigation of the effects of this impact upon water quality and consequently amenity, ecology and the economy.

Do you have any comments to make on any of the other evidence documents?

Thankyou for the opportunity to comment on this Plan. We acknowledge that this is a draft consultation but consider there is still work to be progressed on the evidence base to direct plan preparation to ensure the plan meets the tests of soundness in relation to flood risk and water quality. We will be pleased to continue to work with you on this. We note that the SFRA level 1 has been undertaken and we now look forward to reviewing the Level 2 SFRA evidence in due course which will inform the listed potential sites going forward.