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

This must be a mixed use site - not co-living only which would be an excessive concentration. 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 Community must be involved in shaping the masterplan

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

North Gate (42) 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?

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 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?

Our main criticism of the “North Gate” section of the Exeter Plan is the lack of detail - where it would appear that the detail is known by the authors. Specific points ECS wants to raise are: Assuming the development site is only the yellow area on the plan, it would be helpful if an additional plan could be included identifying which areas (a) will not be developed, (b) could be developed, and (c) definitely are open to being developed. Paragraph 15.30 refers to the need for further work and consultations which is quite understood, however it would be very helpful to understand the assumptions behind the figures in the Strategic policy. Where is it thought that the ‘200 homes’ could go? Are there any overriding assumptions regarding the ‘blocking’ or height of new buildings? It would be helpful to know what the perceived priorities are between the various requirements listed in paragraphs A to I. Is the priority housing or is it employment provision or is it the education needs listed?

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

The North Gate proposed strategic allocation is in an area of extremely high historic and archaeological significance. We believe that this should be more clearly identified in the supporting text (e.g. paragraph 15.29), including references to the close proximity of the Cathedral, the presence of numerous listed buildings within the site and of archaeology associated with the Roman town and fortress. The site is also within the Area of Archaeological Importance and the Central Conservation Area. In addition to the opportunities referred to in paragraph 15.28, the site presents an opportunity to enhance the historic environment and townscape, reinstating a finer grain of development and including streets and spaces of a more human scale that respond to the historic context. We would like to see these opportunities referred to in the supporting text and translated into high level design principles for the site (e.g. within Part H of the policy). Bearing in mind the reference to ‘retention and improvement’ of the Guildhall Shopping Centre (Part C), we recommend further policy criteria requiring developers to carefully consider ways to increase the permeability of the site for pedestrians on North Street and Paul Street, as well as adjacent Bartholomew Street East, and to animate these frontages which currently present a blank and hostile elevation to vehicles and pedestrians approaching the historic city centre. We welcome the criteria to conserve and enhance the historic environment contained in Part I(i), (ii) and (iii) although we consider that Exeter Cathedral needs to be specifically identified in Part I(ii). As the site is very close to the Cathedral, development has the potential to significantly detract from this exceptional heritage asset in views both of and from the asset and its surroundings (including long views). We therefore recommend that design parameters (such as key views and maximum building heights) are incorporated into the policy, informed by a strategic evidence base relating to key views and settings, which can also inform future development proposals and planning decisions. Finally, we query whether the Harlequins shopping centre could also form part of this strategic site, bearing in mind its relationship with the site to the south and the City Wall to the north?