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

Thank you for consulting us on The Exeter Plan: Outline Plan Consultation. This email forms for the basis of our response and is submitted in respect of draft site allocation Red Cow / St David’s (Site ref. 22). Network Rail is a statutory undertaker responsible for maintaining and operating the country’s railway infrastructure and associated estate. Network Rail owns, operates, maintains and develops the main rail network. This includes the railway tracks, stations, signalling systems, bridges, tunnels, level crossings and viaducts. The preparation of development plan policy is important in relation to the protection and enhancement of Network Rail’s infrastructure. Network Rail, in partnership with Blocwork LLP, are looking to take forward a high density residential led mixed used scheme, including station enhancements, and parking in the form of a multi storey car park which we believe to be appropriate to meet passenger needs on the allocated site adjacent to Exeter St David’s. Network Rail and our partners are working up proposals for the redevelopment on part of the subject site with baseline technical evidence gathering and master planning work currently underway. Pre-application engagement commenced in early 2023; are envisaged to re-engage in 2024. We support the emerging local plan allocation at Red Cow / St David’s (Site ref. 22), however, we would emphasise the policy wording should also acknowledge the critical role the station operations (notably the essential role of car parking) play and that any proposals will need to be financially viable, if they are to be successfully delivered.

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. A multi storey car park must be prohibited in front of the St Davids train station. The community must be involved in the master planning process.

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

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 G ii. SuDS to manage surface water generated on the site and mitigate against flood risk.

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

The site area has been extended to the south to include the student accommodation of Brunel Close which is designed at a residential scale in terraces and up to 3 storeys, and probably built in the 1980s. Perhaps not surprising, because most modern student blocks are multi floor blocks, and such a proposal here would increase the number of student rooms – we cannot see that the site owners would give this up for other residential use. To the north the site now takes in all the railway land alongside Cowley Bridge Rd to its junction with New North Road. We have the following comments for the requirements of the site. Is it realistic to require land for custom and self-build homes between the road and railway? In section D- Transport & Infrastructure, there is no mention of reviewing the current highway congestion created as a result of traffic queuing for the level crossing towards Exwick. It is important to alleviate this congestion to enable public transport to move more efficiently. Item iii of the transport section mentions contributions to active travel and cycling in the LCWIP, but it would be useful to be more specific such as identifying the proposed route from the station to Cowley Bridge alongside the rail line. We support the proposals in section H for a built form that enhances the character and appearance of St David’s Conservation Area and retains sight lines of locally listed St David’s station. We emphasise a need to maintain views of St David’s station from Bonhay Road and for the development of the forecourt to establish an improved sense of arrival.

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

This strategic site offers a huge opportunity to improve a strategic transport gateway into the city. We support policy criteria H(i) and (ii) although it would be beneficial to highlight the presence of other nearby conservation areas that could also be impacted (e.g. in the case of tall buildings). As with other strategic sites, additional evidence and policy criteria to identify any key views and to inform appropriate building heights would be beneficial for this area.