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

In line with the objective of maximising sustainable transport, the city centre must be connected so people can reach it easily. We believe it is vital to improve access between the city centre and the Quay and Basin. The quayside and basin are Exeter’s top visitor attractions—a reason alone for better connectivity between them as part of a strategic policy. The main barrier is the steep hill between the quay and the city centre. We believe this is an opportunity to act on the Draft’s vision of a world-class innovative city with an international challenge to design a visually exciting, efficient and carbon-clean link that makes it easy for people of all abilities to get from one level to the other. There would need to be no immediate timetable for this. Making a tourist attraction of the link between quay and city centre would bring added economic benefits. 8.4 For comment, see Section 13: ‘Health and wellbeing’. We welcome the inclusion of ‘f’, supporting opportunities for waterborne transport’ in the Full Draft. But waterborne transport requires land also, which could be the subject of competing development proposals. We urge once again that the Full Draft should acknowledge that what happens on land close to the canal will affect the waterway’s ability to function. The principle should be laid down that developers should show they have considered the impact or its mitigation of proposed development on existing or desirable waterway uses. See also the comment on Strategic Policy H13 above.

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Transport and new developments, 8.7-8.11 8.8 The objective to maximise sustainable transport and support emergent forms and modes of mobility will not be fulfilled if the Draft ignores the development and potential of electric boats and other forms of clean waterborne propulsion for passenger ferries, and the need for boarding and disembarking facilities. We suggest these figure in paragraph 8.8. 8.10, 8.11 and STC2 The sequential prioritisation of road improvements is understandable in terms of the Plan’s overall objective to increase active travel. However, the Plan needs to clarify how it fits with item ‘g ‘of the previous strategic policy, STC1: ‘Sustainable movement’, of protecting the function of Exeter as a strategic road hub through investments in critical infrastructure – and in particular how the two policies affect the future of Exeter Ship Canal. The A379, Bridge Road, is integral to maintaining Exeter’s strategic role as a regional hub and gateway to the national transport network. The planned replacement of the A379’s moveable bridges over the canal at Countess Wear will allow the major road safety gain of pedestrians and cyclists being able to pass under the dual carriageway in safety, while the extra air draught will enable more boats to navigate the canal without the bridges being opened and the road shut. Both will improve connectivity and the environment, particularly as routine halting of traffic at the pedestrian crossings and the extra emissions, will be abolished. The increased headroom will unlock the canal’s potential for waterborne transport allowing all but the tallest craft to travel unimpeded, compared to the currently very limited opportunities when the moveable bridges are opened. It will be a game changer for the prospects of water buses and taxis, pleasure cruises, visiting craft, local commercial cargoes and the economy of the boatyard and Heritage Harbour. It will become feasible that commercial freight could once again be carried right into the heart of Exeter by sea and the canal in conjunction with such zero-emission schemes as Sail Cargo. The significance of this for the Plan as a whole is missed as the Draft makes no reference to the strategic importance of preparing fully for this major change in canal navigability and use. We recommend it is written in as an addition to paragraphs 8.10 and 8.11 together with clarity on Exeter’s scope as a transport authority as far as it extends to roads. The city should continue its co-operation with Devon County Council on the A379 road and bridges improvement. In STC2, ‘local’ road improvements should be defined. 8.9 and 8.21 We believe that daytime stopping trains at Marsh Barton should be scheduled half hourly, rather than hourly, to encourage use.

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Active travel proposals 8.15 portrays the canal as well as some roads and large junctions, as ‘significant barriers’ to walking and cycling in Exeter that need to be overcome while making the most of the river and canal in terms of active travel and waterborne transport. Towpaths and existing footbridges are already busy, at times awkwardly, with pedestrians and cyclists. It is imperative strategically to improve accessibility and safety for increasing numbers, so that pedestrians, children and pushchairs, and people with disabilities, as well as cyclists, can make safe and sustainable transport choices. Various ways have been suggested including separate ‘express’ cycleways. It is not only new development that must be taken into account but knock-on impacts of active travel on usage of existing paths. The stretch of towpath leading to Marsh Barton Station past brownfield development at Water Lane needs especially sensitive handling to retain its character because it will become a pedestrian and cycle commuter route. Any new or replacement bridges across the Ship Canal should have headroom above the water level no less than the new A379 road bridges, and should be electrically operated swing bridges designed for boater operation. Fixed bridges are no longer possible. They would require an air draught no less than that of the M5 bridge. STC3: Supporting active travel (Strategic policy): It is recommended that in ‘c.’, the words ‘or the operation of the Canal’ should be added after ‘without compromising safety’.

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Public transport 8.19-8.23 & STC4: Supporting public transport (Strategic policy) Compatibly with the City Council’s working with other authorities and stakeholders to support inclusive, direct, frequent and reliable public transport, we propose a new paragraph after 8.22 to reflect the following points: Innovative combined bus and ferry tickets from city destinations to hop-on, hop-off points at the Basin and along the canal would be a low-carbon impact service for passengers, daily dog walkers and shoppers, and an active attraction for locals and visitors. A modal interchange at Marsh Barton rail station would also provide for travel by waterbus and water taxi services to destinations along the waterway, including the canal basin which is more accessible for active access to the city centre than either St Thomas or St David’s train stations. While the above is covered by the reference in STC4 to supporting multi-modal travel, integrated ticketing of this innovative sort would require forward planning and collaboration with operators and so the possibility should be spotlighted in the early stages of developing active transport. STC4: Supporting public transport (Strategic policy) To the opening sentence beginning ‘The City Council will work …’, we also suggest adding a comma after ‘frequent’ and inserting ‘affordable’ before the words ‘and reliable public transport’. Under ‘The City Council will support multi-modal travel’, insert a new paragraph, ‘d’: ‘Through encouragement of integrated tickets for bus and water ferry services along the canal’.

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STC4: Supporting public transport (Strategic policy) To the opening sentence beginning ‘The City Council will work …’, we also suggest adding a comma after ‘frequent’ and inserting ‘affordable’ before the words ‘and reliable public transport’. Under ‘The City Council will support multi-modal travel’, insert a new paragraph, ‘d’: ‘Through encouragement of integrated tickets for bus and water ferry services along the canal’.

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ST7: Safeguarding transport infrastructure (Strategic policy) Paragraph 8.30 The Exeter Ship Canal and Basin are part of Exeter’s transport infrastructure that supports the delivery of the 2040 Exeter Plan. This is inexplicably omitted from ST7. Paragraph ‘g’ gives a false impression that it is merely a question of land for an ‘additional active travel crossing’ (a bridge) in order to get across the canal. As already made clear in our commentary above, new bridges must not impede navigation and fixed bridges are impossible.

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

Working with neighbouring districts. The Local Plan commits to “working with our partners at East Devon, Mid Devon and Teignbridge District Councils and Devon County Council to prepare a joint strategy for the wider area”. The plan would be improved by a stronger commitment to when this joint strategy will be delivered. We are concerned that our neighbouring District Councils’ Local Plans are not fully aligned with Exeter’s Local Plan to minimise inducing additional private car use. These councils are likely to continue building on their boundary with Exeter and thereby induce additional car journeys, as evidenced by the recent decision by East Devon District Council for a new town south of Exeter airport. Furthermore, the “coordinated transport strategy” (8.2) for the whole Exeter catchment area is an imperative to enable the strategy underpinning the Exeter Plan. Proposal: commit to a timetable for the development of joint planning and transport strategies with neighbouring councils and seek agreements with these councils not to undermine each others’ core strategies. Meaningful targets for active travel: We would again challenge how meaningful is the ambition underpinning the goal of getting to 50% of intra-city journeys by foot or bicycle (para 8.5). It is good to have ambitious targets, but we are concerned that this target doesn’t address the nearly 29000 cars commuting into the city every day (2011 census figures) from outside Exeter. We are also uncertain how the councils will be able to measure progress in achieving this target. Proposal: make clear which types of journey are included in this target, how it will be assessed and what the current level is.

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

Prioritising active travel routes in new developments: New housing developments create the opportunity to shape and change travel habits of new residents. However, this opportunity is often eroded by active travel routes and connections being developed after a new development has been built and occupied. Similarly, the delay in adoption of the highways by DCC in new developments means that poor travel and parking habits become ingrained, making it harder to subsequently achieve modal shift to active and public transport. The Local Plan should explicitly support a default ban on pavement parking. Proposal: create an expectation in the Exeter Plan that active travel routes will be built and opened before occupation of residences in new developments. Set an expectation that highways in new housing developments will be quickly adopted by DCC and so prevent pavement parking and harmful travel habits. Create a policy that states a default ban on pavement parking in new developments. Home-delivery parking: New housing developments should assume and make provision for last-mile deliveries to be made by electric cargo bike or small electric vans. Incentives or licensing should encourage electric last-mile delivery and disincentivise multiple diesel-based deliveries. Allocated parking for home-delivery vans should be considered as part of new housing developments so that pavement parking from delivery vans can be discouraged. Proposal: consider licensing for home deliveries in the city which incentivises no/low carbon delivery vehicles. Develop a policy to encourage Developers to make space for parking for home delivery vans in new developments.

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

Giving LCWIP a strong status as a mandated planning document as advised by central government: The Local Plan states that the City Council will support a comprehensive active travel network and references the Exeter LCWIP. It also states that the City Council will work with other councils and bodies to ensure the LCWIP and other strategies “are consistent”. Furthermore, the Exeter Plan commits to “early phases of [major] development are as close as possible to existing active travel routes and make walking and cycling improvements”. To achieve these aspirations the Exeter Plan needs to mandate that the LCWIP is given a strong status as a planning document. We are disappointed therefore that the Exeter Plan stops short of following central government guidance in making the LCWIP a planning SPD (or equivalent). The Local Plan would benefit from giving this clarity of policy so that Developers take the LCWIP seriously in their planning applications. Proposal: give the LCWIP SPD (or equivalent) status so that it can be meaningfully leveraged when considering Developer Planning Applications. Master design policy for cycling infrastructure: There is now a national design standard for cycle infrastructure (LTN 1/20). However, the Exeter Plan makes only one reference to LTN 1/20 (para 8.16) and appears to reference older transport policies which have different/lower design standards (e.g. 5.53 stipulates “the Sustainable Transport SPD provides the standards used to determine an appropriate level of car and cycle parking”). Proposal: make more explicit that the LTN 1/20 design standard for cycle infrastructure is the master design standard for developments in Exeter and supersedes existing transport policies where there is a conflict. Commit to a timetable for updating existing transport policies (such as those contained in the 2012 ‘Sustainable Transport Supplementary Planning Document’) so they remain relevant and aligned with modern standards and council strategies. As an example of best practice the current draft Oxford local plan notes that within locations accessible by public transport / active travel planning permission is to be granted only to low car schemes, with a maximum of 1 car parking space per house elsewhere. Ransom strips: Ransom strips have blighted many recent developments in the city, inhibiting active travel. Ransom strips undermine much of what the Exeter Plan is seeking to achieve. Proposal: add a policy to the Exeter Plan making it clear that planning applications which contain (or imply) a ransom strip at the edge of a development, which could block future active travel connections, will not be given planning consent. How will existing neighbourhoods be improved by the Exeter Plan?: This Exeter Plan makes no explicit reference to how existing residential neighbourhoods will be improved. The aspirations for building low-car neighbourhoods where active travel is safe and enabled needs to be extended to existing residential areas so that walking or cycling becomes the most convenient travel mode. As such, the Exeter Plan needs to commit to work with Devon County Council to create more ‘liveable neighbourhoods’ (such as are currently being trialled in Heavitree) across the city, school streets and bike hangers. Proposal: improve the Exeter Plan by outlining how existing residential neighbourhoods will be improved. Outline how funding streams for example from developer contributions and grants can enable these changes. Commit to supporting further measures to enable residents in existing neighbourhoods to more safely access local services by foot, scooter or bike with liveable neighbourhoods, school streets and bike hangers. Removing barriers: We welcome the stated intention (8.15) to remove barriers to active travel. With the wording used in 8.15 (“improvements will be needed…”) it is not clear what actual actions are proposed and how these will be delivered. Proposal: clarify the proposed actions (and actors) that will be undertaken to “remove significant barriers”. Cycle parking: Policy STC3 notes ‘When provided centrally within a development, parking for active travel must be located in easily accessible locations with natural surveillance and high quality access to active travel routes.’ These requirements should apply to all active travel parking, not just those located centrally. Proposal: amend wording of STC3 to make clear that requirements for active travel parking apply universally.

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

The importance of Public Transport: To achieve the reduction of the dominance of private vehicles and achieve modal shift, public transport plays a vital role. Many journeys by public transport also include active travel and this should be facilitated, e.g. by provision of cycle parking and cycle hire. We support the aspiration to have “a reliable, low-carbon, frequent and attractive…public transport in the city” (STC 1d) however more specific actions are needed to describe how ECC will work with DCC to improve a service which has reduced in frequency by 41% since 2010 1. Proposal: commit to working with Devon County Council to develop a plan for improved public transport, including integration with active travel.

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It is noted that Policy ST3: Active Travel Proposals provides the only reference to the Clyst Valley Trail or the Killerton Estate in the Exeter Plan, and there are no further references to the Clyst Valley Regional Park. For the reasons set out above, the National Trust consider that the Exeter plan should include recognition of the value and importance of the Killerton Estate and the Clyst Valley Regional Park as significant green infrastructure serving the residents of Exeter City as an important recreational, heritage, and landscape asset, and visitor destination. Policy ST3: Active Travel Proposals (1.a.), of the Exeter Plan relates to the Clyst Valley Trail, which connects the Killerton Estate with the Exe Estuary. The National Trust support the principle of this policy and the identification of the need to safeguard the Exeter sections and future links to this long-distance strategic trail (along with other long distance strategic trails). The policy states that Exeter City Council will work with partners to prioritise and improve the active travel network. The National Trust would like to understand how partnership working will ensure the active travel network will be delivered and what mechanisms are in place to secure the enhancements required for the delivery of the Exeter sections of the long-distance strategic trails. It is considered that this should be set out in the policy, including the requirement for commensurate developer contributions where this is needed for delivery of any enhancements. The National Trust also consider that this policy should include the commitment for Exeter sections of the long-distance strategic trails to meet high quality design standards in line with Local Transport Note (LTN) 1/20: Cycle Infrastructure Design. Policy ST3: Active Travel Proposals, also includes a list of important routes within Exeter city as set out in the emerging Local Cycling and Walking Infrastructure Plan (LCWIP), which is being prepared by Devon County Council. National guidance states that Local Planning Authorities should consider incorporating LCWIPs into Supplementary Planning Documents (SPDs), which would enable Exeter to secure appropriate contributions to cycling and walking infrastructure (through inclusion in Regulation 123 lists or developer contributions). Therefore. the National Trust consider that the emerging LCWIP should be included as an SPD.

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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

See comments submitted on behalf of Bloor

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?

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?

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?

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?

Please see the comments submitted on behalf of Broom