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

This section should make the connections between land development and water use. There should be guidance that decisions on planning applications to develop sites adjacent to, or which have an impact on, the canal and basin should not compromise future multiple beneficial uses of the waterway, including new carbon reducing waterborne and water-related commercial uses, and the benefits of Heritage Harbour status. An additional clause is suggested in S1: Spatial Strategy (Strategic Policy): • Enabling development and delivery of the full capacity of Exeter Ship Canal and Basin and the Heritage Harbour designation to support Exeter’s needs

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

Liveable Exeter principles (3.10-3.18) 3.16 A multi-functioning canal and basin is not in conflict with any of the Liveable Exeter principles and can be accommodated in delivering planned, mixed use quality development of brownfield land. 3.17 A waterway masterplan by the City Council, developed in conjunction with the Harbour Board/Port of Exeter, that underpins and clarifies this innovative approach is recommended. It requires a necessary holistic approach, not one left to piecemeal approaches by developers. S2 Liveable Exeter principles (Strategic policy) Exeter can add to its vision and Plan for 2040 a valuable and highly enviable element as a forward looking waterway city that connects centuries-old maritime background to its principles and vision of a liveable city. This needs to be signposted as a specific planning element in the strategy because the composite contributions of Exeter’s maritime assets are not automatically obvious. In S2, Liveable Exeter principles (Strategic policy) the following are suggested: Principle 1: Memorable places – Bullet point 2: substitute ‘waterways’ for ‘watercourses’. Principle 2: Outstanding quality – Bullet point 2: add ‘waterway use’ to the list. Principle 5: Active streets – Bullet point 2: insert a comma after ‘key destinations’ and add: ‘maximising connectivity with the canal and basin wherever possible’. Principle 6: Spaces for people and wildlife – First bullet point: reorder after ‘including the’ to read, ‘Green Circle and blue-green corridors of the Valley Parks and Ship Canal.’ Principle 7: Connected Culture – Final bullet point: insert the words ‘maritime assets’ after ‘rich heritage’ so it reads: ‘Harness Exeter’s rich heritage,

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

See comments submitted on behalf of Broom

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

See comments submitted on behalf of Broom

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

Please see the comments submitted on behalf of Broom

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

Please see the comments submitted on behalf of Broom

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

See comments on behalf of Broom.

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

See comments on behalf of Broom.

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

1. For the plan to be sound the Council should plan to build significantly more houses than 642 per annum, helping to meet ECC’s development needs and creating Plan / delivery resilience over time (in terms of e.g., housing land supply and affordable homes) 2. The Exeter Employment Study suggests that 84ha of employment land is required to meet demand over the plan period. This Plan refers only to ‘transformational sectors’ and is silent on other employment uses. The needs of these other employment use, particularly industrial uses need to be addressed. 3. The strategy for house building in Exeter relies heavily on the redevelopment of existing employment sites to provide mixed use developments. Many of these sites include longstanding successful industrial areas and uses. Such uses which will be displaced as a result of this housing strategy. The plan is silent on the displacement of these employment uses and needs to confirm how employment land demand will be met. If the Plan is found to be sound in its current form, housing will be delivered on existing employment land and the displaced employment relocated. If the Plan is found to be unsound, additional land will need to be found for housing. In both scenarios it is reasonable to conclude that greenfield land will need to be released for development. Further, the Plan does not show how uses sit alongside residential dwellings without conflict by means of noise, air quality, odour, impact on residential amenity and highway safety. 4. To expect most of the development to be sited on brownfield sites is unrealistic. Brownfield sites often have abnormal costs associated with them. The effect of such costs must be fully considered in terms of viability and whether there is a realistic prospect of such sites coming forward where these exist. Further consideration must be given to the implications of a largely brownfield housing strategy for the provision of affordable housing. 5. Noted and supported. It is however noted that this version of the plan as reduced the number of greenfield sites proposed since the publication of the Outline Draft Plan last year. Greenfield sites will be required to supplement brownfield projects and the plan needs to recognise that this goes beyond a consideration of modest greenfield sites only. Moreover, where greenfield sites represent sustainable options for development, this should weigh heavily in its favour. 6. Noted, and whilst largely supported, other forms of sustainable transport provision exist and should be acknowledged within the Plan. Further, if the Plan continues to pursue strategy which focuses on brownfield land, it must also acknowledge that brownfield sites in rural areas can also contribute to housing numbers noting the provisions of para.109 which recognises that sustainable transport solutions will vary between urban and rural areas. 7. The removal of reference to the sensitive hills ‘to the north and north west of the city’, presumably in light of recent appeal decisions, is noted. However, as with previous comments, land to the north of Exeter must not be arbitrarily protected, all sustainable and deliverable land must be considered. 8. Noted and supported. 9. Noted and whilst supported, Exeter is experiencing a significant shortage of both housing and employment land, such that it is important that this aim does not unnecessarily stifle development when impacts can be satisfactorily mitigated. 10. Noted and supported. 11. Noted and supported. 12. Noted and whilst supported, the term ‘optimal’ must be clarified. Further clarification is also needed to explain how this aim will sit alongside other requirements for adaptable dwellings (which typically require larger floor areas and ground floor accommodation) and home offices (requiring a larger floor area). 13. Noted and supported. 14. Consideration needs to be given as to how this may affect viability, particularly in light of the focus on brownfield sites.

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

To expect most of the development to be sited on large, strategic brownfield sites is unrealistic, and greenfield land both within and adjacent to Exeter will have to supplement these brownfield projects if the plan is to be found sound. Principle 1 and 2: The aim of making efficient use of land is noted and supported. This appears to correlate with the point about “optimal densities” and clarification will be required as to how this sits alongside the requirement for adaptable dwellings (which typically require larger floor areas and ground floor accommodation) and home offices (requiring a larger floor area). In addition, more space will be required for shared road networks, streets with street furniture. All of which will add to the land take of development and potentially prevent a ‘compact’ development. Principle 3: The aim to provide a variety of high-quality homes and local jobs is noted and supported. However, the strategy for house building in Exeter relies heavily on the redevelopment of existing employment sites to provide mixed use developments. Many of which include successful industrial uses. The Plan is silent on industrial employment uses, particularly those that already exist in Exeter. The Plan does not show how such uses will sit alongside residential dwellings without conflict by means of noise, air quality, odour, impact on residential amenity and highway safety. The Plan does not show how quality homes will be provided alongside noise and odour generating B2 and B8 uses. Whilst policy HW2, which states that development proposals will only be permitted where they ‘will not place unreasonable restrictions on the future operation of existing businesses’, is noted, the implementation of this policy is likely to have implications for housing delivery on mixed use allocations. As such, these figures cannot be relied upon while, at this stage, the impacts on the future operation of existing businesses are unknown. This must be addressed through the allocation of additional sites to ensure the housing requirement for Exeter is met. Further, with a strong focus on the redevelopment of brownfield land for housing, it is unclear how this will impact the delivery of affordable housing in Exeter. Brownfield land is typically associated with abnormal costs, which will inevitably impact the viability of such land coming forward for housing development. Where viability implications exist this is likely to affect the delivery of affordable housing. Principle 4: The provision of homes that are dual aspect will be more difficult for higher density developments such as flats/apartment blocks. It will be important to clarify which matter will take priority, higher density developments or dual aspect accommodation. Principle 5: Matters like cycle parking, storage, electric vehicle infrastructure, areas for play, food growing etc will need to be quantified and consideration given to how the provision of all these matters will affect the viability of developments.