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

Section 14: Infrastructure and facilities The objective of planning for new infrastructure and facilities at the right time and in the right places flags up the use that can be made of the canal in support. Section 14 deals with a range of community facilities that might be included in developments. It does not reference other infrastructure needs in the city not associated with developments that will present themselves for attention during the course of the Plan’s life. Some of them are important strategically to forward planning: relating to the waterways, these elements include: Bridges Replacement of the A379 moveable bridges over the canal. Improving the canal’s Salmonpool Swing Bridge and the river’s Trews Weir suspension bridge because neither is wide enough for an increase in pedestrian and cycle traffic. Widening the narrow bridge over the flood relief channel at Trews Weir to enable pedestrians and cyclists to cross safely in flood conditions. Replacing the missing Mallison Bridge across the Higher Leat at Exeter Quay, because pedestrians and cyclists have to navigate a narrow alley to and from the canal basin. Weirs Ensuring the integrity of Trews Weir. If it fails, the canal is likely to lose its water. Slipways Currently there are no functioning slipways on the canal except for the smallest of craft. A review of slipway requirements is necessary for the development of most waterborne activities to proceed. Access and parking To support the use of the canal and its paths easy access for all to the water and waterside is essential, including accommodating vehicles transporting craft, whether canoes on car roofs, or boats on trailers or large cranes for boat lifting. Moorings As well as first class, carbon zero facilities for pump out, portable toilet emptying, rubbish disposal, electric charging points, fresh water, toilets and showers, it is essential that moorings should meet up-to-date specifications for disability access with sufficient space at the canal edge for organising wheelchairs, mobility scooters and guide dogs. Clean water Any danger of sewage or effluent overflow into the water from the Countess Wear sewage works or elsewhere is unacceptable. Designated authorities must ensure the sewage system is adequate and secure for the number of new dwellings and other developments that are planned for the city. IC3: Community facilities (Strategic policy) Community facilities that connect people with the water, especially at or in the vicinity of the canal basin, should have a reference in this policy as they do not fit totally into the current wording. We suggest a new line in the paragraph beginning ‘Facilities that service the city as a whole’: Facilities that use or are reliant on the waterways or canal basin should be retained in these areas.

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Children: When referring to play areas the Exeter Plan states that “We want our children to be active in a safe environment” (14.27). This is good. However, it doesn’t explicitly state that we want the whole of our built environment (and highways) to be safe enough for children to live and move independently and safely. When they were last asked, the children of Exeter responded that the dominance of cars was a major concern for them. Proposal: make explicit in the Exeter Plan that to achieve the strategic goal of higher activity levels for all, the city will seek to ensure all new and existing developments (and support DCC in ensuring that highways) are made safe enough for children to move independently in the city. This should be assessed using the Healthy Streets indicators (https://www.healthystreets.com/what-is-healthy-streets)

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Community Use of Education Sites Delivery of development, infrastructure and regeneration to meet our needs now and in the future. Making better use of existing resources contributes to sustainable development objectives by reducing the need for additional facilities and the potential loss of scarce resources such as open space. The practice of making school sports and other education facilities available to wider community use is already well established and has been government policy for many years, but there are further opportunities to extend this principle within the education sector through programmes such as Academies and to other privately owned sports facilities, to help meet the growing demand for more and better places for sport in convenient locations. Sport England promotes the wider use of existing and new sports facilities to serve more than one group of users. Sport England will encourage potential providers to consider opportunities for joint provision and dual use of facilities in appropriate locations. Sports facilities provided at school sites are an important resource, not just for the school through the delivery of the national curriculum and extra-curricular sport, but potentially for the wider community. There are also direct benefits to young people, particularly in strengthening the links between their involvement in sport during school time and continued participation in their own time. Many children will be more willing to continue in sport if opportunities to participate are offered on the school site in familiar surroundings. Many schools are already well located in terms of access on foot or by public transport to the local community and so greater use of the sports facilities outside normal school hours should not add significantly to the number of trips generated by private car. Use Our School is a resource to support schools in opening their facilities to the community and keeping them open. It provides tried and tested solutions, real life practice, tips from people making it happen, and a range of downloadable resources link here

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Planning Obligations/Community Infrastructure Levy (CIL) to Sport Sport England supports use of planning obligations (s106)/community infrastructure levy (CIL) as a way of securing the provision of new or enhanced places for sport and a contribution towards their future maintenance, to meet the needs arising from new development. This does need to be based on a robust NPPF evidence base. This includes indoor sports facilities (swimming pools, sports halls, etc) as well as playing fields and multi use games courts. All new dwellings in Exeter in the plan period should provide for new or enhance existing sport and recreation facilities to help create opportunities for physical activity whilst having a major positive impact on health and mental wellbeing. This is reflected in IC1 Delivery of Infrastructure. Circa 14000 new homes / 642 per annum, 5272 from new site allocations. In particular: • Marsh Barton – 1000 (site 14) • Water Lane – 1000 (site 15) • East Gate 850 (site 52) • Red Cow 280 (site 22) • North Gate 200 (site 42) • South Gate 170 (site 46) • Land at Old Rydon Lane 350 (site 89) • Land at Cowley Bridge Road 231 (site 143) • Exe Bridges Retail Park 230 (site 39)

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Protection of Sport & Recreation including playing fields Sport England acknowledges that the NPPF is promoting “sustainable development” to avoid delays in the planning process (linked to economic growth). Thatsaid, the NPPF also says that for open space, sport & recreation land & buildings (including playing fields): 103. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or b) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or c) the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use. Sport England would be very concerned if any existing sport & recreation land & buildings including playing pitches would be affected by these proposals without adequate replacement in terms of quality, quantity, accessibility, management & maintenance and prior to the loss of the existing facility. This includes playing fields used by education (public and private) and playing fields in private ownership (e.g. Middlemoor police site, St Leonards playing fields/Deaf Academy) in Exeter. Sport England considers proposals affecting playing fields in light of the National Planning Policy Framework (NPPF) (in particular Para. 103) and against its own playing fields policy, which states: ‘Sport England will oppose the granting of planning permission for any development which would lead to the loss of, or would prejudice the use of: • all or any part of a playing field, or • land which has been used as a playing field and remains undeveloped, or • land allocated for use as a playing field unless, in the judgement of Sport England, the development as a whole meets with one or more of five specific exceptions.’ Sport England’s Playing Fields Policy and Guidance document can be viewed via the link here We OBJECT to policy IC3 if for sport and recreation including playing pitches fields the local policy deviates from para 103 of the NPPF and Sport England Playing Fields Policy and creates loopholes. As written the scope of IC3 facility types are very wide and could be confusing to the reader/implementation with developers mixing ‘marketing a site’ when this is not applicable to playing fields / leisure buildings. Greater clarity needed that Exeter Policy IC3 is in line with the NPPF para 103 regarding sport and recreation including playing fields. Perhaps IC3 needs to be split into two where marketing/viability is more relevant to pubs etc?

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Standards for playing fields Para 14.26 encourage the use of standards for playing pitches / outdoor sport but there are limitations with using standards of provision. Standards are sometimes used to help quantify the need that may be generated from a development. However, as set out below there are some risks and weaknesses with their use that should be highlighted: i. The NPPF does not advocate the use of local standards for assessing the needs or providing for sporting provision (unlike PPG17 (2002) which it replaced). It terms of planning for sport and recreation it advises that specific evidence of the need for provision should be provided along with clarity of what provision is required (NPPF para 102). The Government’s Planning Practice Guidance (PPG) points to Sport England’s guidance on assessing needs for sporting provision. Rather than advocating the development of standards Sport England takes the requirements of paragraph 102 of the NPPF and helps the user develop this more specific evidence. ii. The existence of a local standard in a Local Plan, or other development plan document, does not necessarily in itself justify the requirement to seek provision for a specific facility type from an individual development. It would need to be underpinned by a robust assessment of need and developed further to provide a specific local requirement (e.g. an identified project or contribution to an identified project) informed by appropriate feasibility studies, costings etc. iii. If the underlying evidence base, and how the standard has been developed, is not robust and up to date then it may be difficult to justify their use. iv. Standards propose a certain amount of new provision for a given population. This level of new provision may not be necessary and may not relate to identified needs and actions as set out in a supporting evidence base document. For example, improving the quality or accessibility of existing provision to increase its capacity may be a more appropriate way to meet the need generated by a development. v. Standards do not provide details of the needs that may be generated for the actual use of a facility. Standards therefore have limitations when seeking to improve existing provision to increase its capacity. vi. Standards can be too generic with a single standard covering a number of facility or pitch types (e.g. X hectares for outdoor sport as opposed to a local assessment that may identify a shortfall of cricket and youth football pitches but adequate provision of adult football pitches). Such standards do not reflect the range of needs for different facility types that fall under a generic heading, or provide any certainty as to what specific needs will be generated from a development and therefore what provision is necessary; vii. Applying a standard without robust evidence that existing provision, within a reasonable catchment of the individual development and in its current condition, is unable to meet the additional need will fail to demonstrate that the provision sought is necessary. viii. The standard for playing pitch here specified is for the quantum only. Not the quality or accessibility. Again, this weakens its use in implementation. Sport England raises concerns with the use of a ‘quantum’ standard for playing pitch in para 14.26. The evidence base as mentioned in (1) above should inform the Infrastructure Delivery Plan (IDP) and / or CIL and site allocations for future housing in the City.

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor