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. Neighbouring communties must inform the master plan. Where these large sites are divided into phases a S106 agreement will be required to show remedial works to be undertaken should later phases of the development be paused for viability concerns. This would mitigate the impact of incomplete development such as thos adjacent to the courts building off Southerhay

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

Minerals and Waste planning As per our previous response to the outline draft consultation the Full Draft Plan makes no reference to the Devon Waste Plan and Devon Minerals Plan. These form part of the Development Plan, and it is considered reference to these should be made to highlight the importance of sustainable waste management and the safeguarding of waste and minerals facilities, that, where relevant, non-waste or non-minerals development will have to demonstrate. A more detailed response can be found in the attached table below but overall, the Waste Planning Authority and Minerals Planning Authority object to the Marsh Barton Reference 14 (Strategic policy) allocation because it is considered the policy is in conflict with the policies and provisions of the Devon Waste Plan (W10) and Devon Minerals Plan (M2). It is also unclear in the plan if the Local Planning Authority expects waste and mineral uses to remain in situ with sufficient safeguarding or be displaced elsewhere. If the Local Planning Authority intend for the uses to be relocated, the Waste and Mineral Planning Authority would want certainty that these facilities could viably be replaced; including a site suitable for their relocation and sufficient funding being secured for their replacement. The Waste Planning Authority has previously highlighted that Marsh Barton is strategically significant in terms of waste management for Exeter and the wider area and, therefore, it should not be constrained by non-waste development in close proximity. We would object to the loss or constraint of any waste management facility, and it would be necessary to deliver replacement sites at an alternative location to ensure the continued availability of adequate capacity to manage Devon’s waste. It is considered that the introduction of residential properties in areas near to already established waste management facilities are highly likely to be impacted upon from noise, odour, traffic, dust etc. generated by the operations at these waste sites and, therefore, it is considered a significant part of this site is not currently suitable for residential development as it is unlikely these impacts could be mitigated to an acceptable level. The County Council, as Mineral Planning Authority, has responsibility for safeguarding and maintaining delivery of minerals in Devon. The Devon Minerals Plan identifies Mineral Safeguarding Areas and Mineral Consultation Areas which surround minerals of various importance and as such reference should also be made to the ready-mix concrete plant within Marsh Barton which is a Mineral Safeguarding Area for Aggregates. The Waste Planning Authority and Minerals Planning Authority object to this allocation. It is considered the policy is in conflict with the policies and provisions of the Devon Waste Plan (W10) and Devon Minerals Plan (M2). The Waste Planning Authority again reiterates the strategic importance of Marsh Barton in terms of waste management for Exeter and the wider area. It is noted that some changes to the supporting text and policy have been made. At present, it is unclear if the Local Planning Authority expects waste and mineral uses to remain in situ with sufficient safeguarding or be displaced elsewhere. Paragraph 15.14 implies the waste management facilities will be safeguarded; however, point J of Strategic Policy 14 implies that these could be lost if contributions were made for replacement facilities elsewhere. The Exeter Energy from Waste facility, which manages Exeter’s and the surrounding district’s household waste, has 20+ years remaining on its operational contract. There are no plans to alter this. It is extremely unlikely its replacement can viably be achieved and, therefore, the site requires protection. The introduction of residential properties in areas near to waste management facilities are highly likely to be impacted upon from noise, odour, traffic, dust etc. generated by the operations at these waste sites and, therefore, it is considered a significant part of this site is not currently suitable for residential development. It is unlikely these impacts could be mitigated to an acceptable level. Should the Local Planning Authority wish to allocate residential uses within Waste Consultation Zones, it should be demonstrated, at this stage, that an appropriate level of amenity can be achieved. Without this, or any other safeguards included (such as making it clear in the policy that residential uses cannot be located in the WCZs; or the removal of the areas from policy) the Waste Planning Authority objects in principle to the allocation. If the Local Planning Authority intend for the uses to be relocated, the Waste and Mineral Planning Authority would want certainty that these facilities could viably be replaced; including a site suitable for their relocation and sufficient funding being secured for their replacement. At present, there is no inclusion of these facilities within the Infrastructure Delivery Plan, and it is noted the site has not been tested by viability appraisal. Any viability appraisal, at a minimum, should include the requirement to replace: − The Exeter Energy from Waste Facility and Transfer Station; and − Exton Road Household Waste Recycling Centre. Without these reassurances, the Waste Planning Authority objects to the inclusion of the wording to secure contributions for a replacement facility. Comments regarding the loss or constraint of the ready-mix concrete plant in relation to Policy M2: Mineral Safeguarding Area of the Devon Minerals Plan are still considered relevant. We welcome the requirement for a 70-unit extra care housing scheme at the Marsh Barton and within the site allocation policies. In particular Devon County Council needs to maximise the number of affordable units within these schemes and the nomination rights which will sit with social care so that we can ensure the schemes are able to respond to those most in need. Located in Flood zone 3. The access and egress concerns have been addressed. ‘All sources of flood risk’ has been incorporated. Requirement for detailed Flood Risk Assessment has been included. This needs to take into account recent Exe Flood defences and modelling. Point H ii. SuDS to manage surface water generated on the site and mitigate against flood risk. It is unclear when the new school site will come forward. Given the wording in the plan that MB development will likely take 20+ years to be fully completed we need to seek early delivery of a school site (IDP currently states 2025-2040). Given that this site may also support Water Lane (& given the viability issues on that site) early delivery of a new school at MB is more critical. Has Exeter identified a potential site for the new school at MB? Our comments from the previous response still stand so as part of the wider work on Marsh Barton related to deliverability, we wish to understand if you have information related to the ownership and leasing of land in the area earmarked for development at Marsh Barton and the ease and timeframes for acquiring, or developing land related to the area. This will have implications for businesses located at the site in terms of their leaseholds and/or freeholds. We request that a survey of business needs and intentions at Marsh Barton, focusing in particular on the areas where any business displacement is to be expected, but looking at the site as a whole, is carried out at the earliest possible opportunity. Findings should then state whether there will be any likely net loss or gain of business and employment within the EHOD area. They should also state what the net overall car journey impacts would be likely to be for the whole EHOD area, should businesses be displaced into Exeter’s hinterland.

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. Infrastructure-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 overflow performance at Tan Lane Sewage Pumping Station, further assessment is required to determine the need for upgrades in the medium to long term.

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

The vision for this site enlists more details than in the previous version. It says now 1,000 homes by 2040, but leaves open what is planned for beyond. ECS welcomes the phased delivery of the site as a redevelopment from predominantly low density employment area to a higher density mixed use for employment and housing. 15.14 confirms future openness of the approach. We are in favour of the master-planning exercise to deliver the redevelopment, but want to point out that this must be done at a much earlier stage than in comparable recent developments that did not leave time for master planning. We want to see the development of a masterplan written into the actual policy of Reference 14. A master plan is crucial if, as is stated, the area is in multiple ownerships because it cannot be expected that individual site owners will have the capability of considering the total needs of the area which, according to the Liveable Exeter website, expects 5,500 homes to be built in the area. It will clearly be beneficial to have a co-ordinated approach to development rather to be sporadic which may not result in the development of a new community environment. (C.iii) should not allow the alternative to a new surgery: delete ‘or contributions to GP provision’. (C.vi) and (D.iii) are the same; delete one. Of crucial importance for the redevelopment are: (C.vii) an all through school, (Diii) the safeguarding of the disused railway line, and (E.iv) on site provision of allotments. We do not understand what is meant by ‘adverse effect on the European Sites’ in (E.v).

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

While we broadly welcome the requirement at Part A of the policy that optimal densities for housing will be informed by the local context and Exeter Density Study, it is not clear what this will mean in terms of building heights and how this will affect the relationship between the historic city, views of and from key heritage assets, and the landscape setting (for example the view from Colleton Crescent). We welcome Part I(i) of the policy which requires layout to be informed by archaeological and heritage assessment. In Part I(ii), the word ‘nearby’ needs to be removed, to be consistent with the NPPF and Policy HH1, and to recognise that there are likely to be long views across the site of or from heritage assets such as the Cathedral, City Walls and conservation areas. We consider that a strategic evidence base is needed in relation to key settings and views in order to inform policy criteria (such as general or maximum building heights), subsequent development proposals and planning decisions for Marsh Barton and other strategic site allocations. Other design considerations such as building and roofing materials could have a significant influence on the relationship between Exeter and its landscape setting, providing an opportunity for enhancement.