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. The Council homes of watergate, southgate and St James Court must be excluded. The City Wall mediaeval, Exe Bridge and St Edmund's Church must not be considered as brownfield site or as part of this development and must be enhanced. The whole of the Western way should be included to reduce to one lane to improve traffic flow and make space for protected cycle lanes and make it more pleasant for pedestrians. The Quaker meeting house and Dissenters graveyard isn’t mentioned and should be explicitly recognised as important local heritage assets.

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

South Gate (46) 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?

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 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?

There is very little to disagree with in the opening chapters but the issues are in what will be proposed. The society was invited to respond to a pre-application planning application earlier in 2023 that proposed a scheme which would block views between Holloway Street to South Street, and therefore not establish ‘an impressive and memorable city centre gateway’ that is called for in the list of criteria. We also expressed concerns about the proposed road layout which deviated from the existing and historical street pattern, which we considered unnecessary. We would question the following: The provision of custom and self-build plots seems unlikely on this city centre site. The provision of public realm space for community and cultural activities is probably unnecessary – the proposals should focus on providing amenity space for its residents. In the transport section (D) we would contest that whilst it is desirable to have active travel links from this site, issues such as the busy nature of the roads in the area, and the lack of any nearby cycle routes to connect to would need to be addressed. There is also a suggestion for a new pedestrian / active travel route from the city to the quay. In our response to the pre-application we made the point that this is not the primary route from the city centre for residents and tourists, and that an improved route via Coombe Street would be better (as in the Council’s South Street study). We also pointed out that a route via Friars Gate is not very attractive with a steep path running parallel to the city wall, or steps alongside the Prospect Inn. The provision of a mobility hub (D.iv) is probably unnecessary because of the proximity of local bus stops, and the probability that the flats will have cycle storage, as is a financial contribution to public transport for the same reasons. We support item (H.ii) which requires development to enhance the character and appearance of the Southernhay & The Friars conservation area. (H.iii) suggests that the development should make a contribution towards the repair, maintenance and enhancement of the city wall where appropriate. As the site is only partially adjacent to the wall which is properly maintained in this section, this must be looked into again, as it seems an unnecessary tax on the development.

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

As at North Gate, the South Gate has significant opportunities and constraints relating to the historic environment. We again consider this should be emphasised more strongly in the supporting text, including the presence of part of the City Walls at the northern part of the site, numerous listed buildings around the site, the location within Southernhay and The Friars Conservation Area and the Area of Archaeological Importance, and an HER record relating to a possible Roman cemetery. We welcome the reference at paragraph 15.31 to the dominating character of the transport gyratory, as traffic movement and noise are also a major detractor from the historic environment and thus a potential area for enhancement. As at North Gate, there is an opportunity to reinstate a finer grain of development 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). We welcome the criteria to conserve and enhance the historic environment contained in Part I(i), (ii) and (iii) although we again consider that Exeter Cathedral needs to be identified in Part I(ii) as there is a clear view of the towers when approaching the site (and historic walled city) via Topsham Road / Holloway street. More generally, a better understanding is needed of how development of the site may affect the city skyline in key views such as those of and from the Cathedral, City Walls and Castle battlements. We therefore recommend that design parameters (such as protected 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.