Are there any other comments you would like to make on the Exeter Plan?

Happy-I was told that the policy has moved away from building on greenfield sites and towards brownfield sites. I think this is a far more sensible approach to building. The reasons are: 1 People will not be upset by having their green spaces removed or their trees cut down. 2 There are ugly post-industrial areas in Exeter which it would be good to replace with modern housing. 3 These new buildings will be nearer the city centre and so cause fewer transport problems than building on the outskirts of the city.

Are there any other comments you would like to make on the Exeter Plan?

The following comments on the History and Heritage section of the Local Plan are from the Devon Buildings Group. The objects of the Devon Buildings Group are:  To promote the study, wider understanding and appreciation of the historic buildings of Devon.  To liaise between local and national groups and other interested bodies concerned with Devon's historic buildings.  To afford advice to owners and public authorities in regard to the conservation and repair of historic buildings in Devon.  To take an active part in the preservation of historic buildings or groups of buildings in Devon, especially through casework on buildings or groups of buildings under threat. Our general response is that the statements and policies in this section of the Local Plan are perfectly sound as they stand. However, except for the City Walls, most, and particularly the ‘strategic policies’, are applicable to any historic city or town and we are disappointed that there is little to show how they might relate in practice to the future of Exeter’s distinctive heritage. What we find most troubling is the mismatch between the aspirations set out and the realities of conservation and recent and current planning.

Are there any other comments you would like to make on the Exeter Plan?

Introduction Shopland Gray Developments Limited (SGD) are the owners of land and buildings at Victoria Street in the St James’ area of the city. The site’s sustainable location close to the city centre and its brownfield character makes it eminently suitable for redevelopment to provide some form of residential use. Following discussions with the City Council, SGD consider that their site would be suitable to accommodate a co-living use for which there is considerable need in the area. As a result, a planning application (reference 23/0949/FUL) for a co-living scheme has been submitted to the Council and is awaiting determination. SGD are therefore committed to bringing forward a co-living scheme on their land which, if approved, will assist the Council with the provision of new homes in a sustainable city centre location. Within this context, and having reviewed the draft local plan, SGD has a number of observations on the Council’s draft co-living policy (Policy H5) which is now proposed and their comments are therefore outlined below. In parallel with these representations, SGD have made a submission to the Council’s current ‘call for sites’ in which they have identified the Victoria Street site as being suitable to accommodate a co-living scheme.

Are there any other comments you would like to make on the Exeter Plan?

We are grateful for the opportunity to respond to the full draft of the Exeter Plan, October 2023. Introduction and explanation of our response 1. The purpose of this response is to pull together the case for Exeter Ship Canal and Basin figuring more prominently in the Full Draft Plan. 2. We urge the City Council to recognise two points: ¬– the Canal and Basin will contribute to the objectives of the Full Draft Plan – the full range of opportunities this offers the Plan’s delivery will be lost unless the nature of the Canal and Basin is recognised for inclusion and consideration in the Plan. 3. The Canal and its Basin are under the direct control of the City Council. They give an opportunity for generations of people living in Exeter to enjoy benefits, that are widely recognised today, that a waterway can bring to improving people’s lives. These include improved health and wellbeing; new interests and skills; training and the economy; achievement of net zero; active and connected communities; and new ways to connect with heritage and culture. Exeter has the opportunity to be among the leaders in future inland waterway management in these respects. 4. The Full Draft Plan, with its full set of planning policies, should also recognise that the body of water that forms the Exeter Ship Canal is dependent in terms of its character and use on the uses of the land bordering it. What happens on this land indelibly affects the waterway’s ability to function to full capacity. This vital point is often missed. 5. At the high level of strategy of the Full Draft Plan, we are not over-egging the importance of the Canal and Basin. It can help shape and deliver the Plan but obviously only as one constituent of all that will make the city a ‘liveable’ place now and for the future. We ask that omissions in the Draft are redressed to give the wide-ranging contributions of the Canal and Basin status among considerations of the city’s future. This will ensure that developments take account of them, as they must of other factors. The multiple contributions of the waterway can only be realised if the future of the canal and basin network is well planned. 6. Key contributions of the Canal and Basin map onto the content of the Full Draft Plan. We are not suggesting that the Canal and Basin should be referenced by name at all these points but indicating that the waterway’s place as a shaping factor in Exeter’s future should be planned for. It will not involve major rewording of the Draft, and where we believe a specific reference to the Canal and Basin will be helpful we generally suggest a draft. 7. The extent of Exeter’s waterway covers the Port of Exeter as a whole, from the coast and Exe Estuary including the port of Topsham, through Turf Lock and along the 5.2 miles of the Ship Canal to the City Basin, and the canalside buildings. The Ship Canal and the Basin at its head are therefore integral to a connected and functional network. We urge the Council to consider and accept the strategic case for including the Canal and Basin among the drivers that will achieve the Exeter Vision. Sections1 & 2: Explaining the Exeter Plan and This is our city, this is our future Paragraphs 1.1 and 1.2 As the main planning policy document for Exeter for the next 20 years, to be used to make decisions on planning applications (1.2), the Plan should acknowledge the special case of the vulnerability of the Canal and Basin to planning applications for nearby land. Given the contributions the working waterway and basin make to the Plan’s objectives in shaping Exeter’s future over the same period, it is vital this point is not missed. It is now widely accepted that waterways today can bring: Economic Benefits: contributing to local economies, encouraging new business growth and investment, increasing spend in local communities, and reducing pressures on social care and the NHS. Protecting and Enhancing Natural and Built Environment: a blue-green corridor for wildlife and biodiversity; accessible heritage everyone can understand and use; new life and protection for the waterfronts and their history; planning for sustainability and net zero through new research and waterborne transport modes and minimising carbon emissions. Inclusive Communities: contributing to great places to live, work, be active and take leisure; opportunities open to people of all abilities for new connections with the water, new interests and acquiring new skills. Access to understanding and learning: an outdoor ‘classroom’ for natural and social history for school-aged children and intergenerational groups; innovative opportunities for employment, training and apprenticeships for jobs from boat building and related crafts to water environment and boat design; a laboratory and test-bed for academic research into water and biodiversity management and clean energy for propulsion. Making lives better: fantastic range of affordable activities encouraging people of all abilities and ages to be active afloat and along the waterside; boost to long-term physical and mental health from access and connection with a working waterway. City and waterway culture: Exeter Ship Canal and Basin are part of the historic Port of Exeter and maritime background; the city’s blue route from the sea to the city centre; a rich artistic and cultural offering; and a social and industrial heritage of national importance. The designation of Heritage Harbour reinvigorates the cultural contribution for the future. Exeter would not be Exeter without the working canal. All the foregoing map directly onto the Exeter Vision 2040 and the outcomes that drive the Exeter Plan. General conclusion This response deals with the contents of the Full Draft relating the canal and basin. We hope the case for stronger recognition in the Exeter Plan of the strategic importance and contribution of the canal and basin has been made. The Canal and Basin can be a flagship innovation hub in their own right if strategically managed with that end in view. We would wish to have the opportunity to offer comments on revisions to the Draft and we are always keen to discuss any aspect.

Are there any other comments you would like to make on the Exeter Plan?

We advise that you take note of any relevant policies within the South Marine Plan documents in regard to areas within the local plan consultation that may impact upon the marine environment. We recommend inclusion of the South Marine Plan when discussing any themes with coastal or marine elements, such as in the Natural Environment Section and recommend that you follow a whole-plan approach when considering the marine plan policies, please see attached for more detail. As the marine planning authority for England, the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent the Marine Plan boundaries extend up to the level of the mean high water spring tides mark (which includes the tidal extent of any rivers), there will be an overlap with terrestrial plans which generally extend to the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. Planning documents for areas with a coastal influence may wish to make reference to the MMO’s licensing requirements and any relevant marine plans to ensure the necessary considerations are included. In the case of the document stated above, the South Inshore and Offshore Marine Plan is of relevance. The South Marine Plan covers the area from the river Dart in Devon to Folkestone in Kent, including the tidal extent of any rivers within this area. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act 2009 and any relevant adopted Marine Plan, in this case the South Inshore and Offshore Marine Plan, and the UK Marine Policy Statement (MPS) unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our Online Guidance, Explore Marine Plans and the Planning Advisory Service soundness self-assessment checklist. Marine Licensing The Marine and Coastal Access Act 2009 states that a marine licence is required for certain activities carried out within the UK marine area. The MMO is responsible for marine licensing in English waters and for Northern Ireland offshore waters. The marine licensing team are responsible for consenting and regulating any activity that occurs “below mean high water springs” level that would require a marine licence. These activities can range from mooring private jetties to nuclear power plants and offshore windfarms. Summary notes Please see below suggested policies from the South Inshore and Offshore Marine Plan that we believe are most relevant to your local plan. These suggested policies have been identified based on the activities and content within the document entitled above. They are provided only as a recommendation, and we would suggest your own interpretation of the South Marine Plan is completed: • Co-existence S-CO-1: Proposals will minimise their use of space and consider opportunities for co-existence with other activities. • Oil and Gas S-OG-1: Proposals in areas where a licence for oil and gas has been granted or formally applied for should not be authorised unless it is demonstrated that the other development or activity is compatible with the oil and gas activity. • Dredging and Disposal S-DD-1: Proposals within or adjacent to licenced dredging and disposal areas should demonstrate that they will, in order of preference: a) avoid b) minimise c) mitigate significant adverse impacts on licenced dredging and disposal areas d) if it is not possible to mitigate significant adverse impacts, proposals should state the case for proceeding. • Infrastructure S-INF-1: Appropriate land-based infrastructure which facilitates marine activity (and vice versa) should be supported. • Social S-SOC-1: Proposals that enhance or promote social benefits will be supported. Proposals must demonstrate that they will, in order of preference: a) avoid b) minimise c) mitigate significant adverse impacts which result in the displacement of other existing or authorised (but yet to be implemented) activities that generate social benefits. • Access S-ACC-2: Proposals demonstrating enhanced public access to and within the marine area will be supported. • Marine Protected Areas S-MPA-1: Proposals that support the objectives of marine protected areas and the ecological coherence of the marine protected area network will be supported. Proposals that may have adverse impacts on the objectives of marine protected areas and the ecological coherence of the marine protected area network must demonstrate that they will, in order of preference: a) avoid b) minimise c) mitigate adverse impacts, with due regard given to statutory advice on an ecologically coherent network. • Marine Protected Areas S-MPA-2: Proposals that enhance a marine protected area’s ability to adapt to climate change and so enhance the resilience of the marine protected area network will be supported. Proposals that may have adverse impacts on an individual marine protected area’s ability to adapt to the effects of climate change and so reduce the resilience of the marine protected area network, must demonstrate that they will, in order of preference: a) avoid b) minimise c) mitigate adverse impacts. • Marine Protected Areas S-MPA-3: Where statutory advice states that a marine protected area site condition is deteriorating, or that features are moving or changing due to climate change, a suitable boundary change to ensure continued protection of the site and coherence of the overall network should be considered. • Marine Litter S-ML-2: The introduction of litter as a result of proposals should be avoided or minimised where practicable and activities that help reduce marine litter will be supported. Further points to note: You do not currently refer to the MMO and the Marine Policy Statement. We would also recommend you mention the South Marine Plan. Under the Marine and Coastal Access Act, any authorisation or enforcement decisions must be made in accordance with the marine plan. Any other decisions which may impact the marine area must have regard to the marine plan. There are several themes within the draft plan that fall in line with our South Marine Plan policies. For example, we have policies on Climate Change, Renewable Energy and Water Quality that you could signpost within your Climate Change section. Our Biodiversity and Disturbance policies could fit within the Natural Environment section, while our Tourism and Recreation policies are relevant to your Culture and Tourism section. The South Marine Plan also has a Heritage policy that would apply to your History and Heritage section. These, however, are just suggestions so please make your own interpretation of the South Marine Plan and its policies. Please let me know if you have any questions regarding implementation of the South Marine Plan. As previously stated, these are recommendations, and we suggest that your own interpretation of the South Marine Plans is completed. We would also recommend you consult the following references for further information: South Inshore and Offshore Marine Plan and Explore Marine Plans. To stay up to date with the latest Marine Planning news, you can sign up to the MMO’s marine planning newsletter here.