ECC Planning Committee approved Outline Planning for Water Lane South

At a 3.5 hours long meeting, ECC Planning Committee voted unanimously to approve the Outline Planning Application the developer WL DMC had handed in, after one amendment was made to safeguard the operation of Gabriel's Wharf during the construction process. ECC's Director of Place, Ian Collinson, sees this as a crucial step in bringing this key site in Exeter close to being developed. At the meeting, the local councillors and ECS made the point that the Officer's Report recommends to go ahead with no affordable housing and social rent guaranteed secured at this Outline stage, thereby potentially not meeting ECC's statutory duty to provide affordable homes. Ian Collinson as well as the officers pointed out the review mechanism being put in place by the conditions would be sufficient to do both, prove ECC's commitment to affordable homes and over time deliver these on site. The developer's spoke person highlighted that this reviewing of affordable housing at each Reserved Matters application has been successful on other brownfield sites. Richard Clark in an article in 'Express and Echo' last week said his company was in contact with Homes England and Cornerstone to investigate potential solutions and he repeated something along these lines today in a BBC South West interview screened in the local TV news. Exeter Civic Society voiced some doubts in a written joint representation (together with the Haven Banks Residents' Group and the Friends of the Exeter Ship Canal) to ECC on 24 January, which was sent directly to all members of the ECC Planning Committee.

The representation reads:

‘The Officer’s Report reduces affordable homes from the current expectation of 35% (Core Strategy Policy 7), not to a minimum of 15% as the emerging Exeter Plan suggests for brownfield land (H4), but 0%. It justifies this by its review of the developer’s Financial Viability Appraisal (FVA) and ECC’s independent assessment, which classes the ‘development as considered unviable’ and concludes: “Affordable housing cannot be required to be secured through planning agreement” (p.80). With the aim to safe some affordable housing, the report suggests that the conditions should “include a mechanism to review the viability of the development at the Reserved Matters application stages and other key milestones” (p.73). The actual process needs to be made unambiguous: Affordable housing should be defined as a Reserved Matters issue, and not in any case be waived at OUT stage.‘

Exeter Civic Society pointed out that, the ‘Exeter Local Housing Needs Assessment’ from Dec 2024 calculates for the period 2021-2041 that 18% households will be unable to afford housing costs, which relates to 862 per annum or 16,092 for the whole period (5.24, 5.34, 5.50). This proves a substantial and sustained need for affordable housing in Exeter.

The Officer’s Report recommending the approval of the Outline Application made the case on the basis that the project was financially not viable at the current state and that the five-year land supply need, currently not met, urgently needs a new large site coming forward.

Gert Vonhoff, representing Exeter Civic Society and the two other organisations as ‘Objector’ at the Planning Committee meeting, raised some doubts in the validity of this argument. He thinks the Financial Viability Assessment does not prove without doubt that the development is only viable without any affordable homes obligation. He says, ‘the first two scenarios in the FVA seem to indicate a difference of about £41 mio between running the models with and without 35% affordable housing. The deficit is shown as -£142 mio in the profit analysis, compared to -£101 mio in the scenario with nil affordable housing.  A third scenario labelled as ‘Sensitive Alternative’ with nil affordable housing and a value inflation approach surprisingly reports a profit of £36 mio. One would expect there to be a fourth scenario running the approach of the third scenario but with 35% affordable housing, and thus making the figures provided fully comparable. But the assessment does not provide this.’ Based on a lay understanding of these matters Mr Vonhoff said at the meeting: ‘I think a fourth scenario could have shown that the deficit for a delivery with 35% affordable homes could be as little as £5 mio’, a drop in the ocean with the overall costs of up to £400 mio.

When the Officer’s Report was made available for the public on 18 January, neither the Financial Viability Assessment carried out for the developer nor the independent assessment commissioned by ECC was accessible through the planning application web portal. In preparation for a meeting of ECS. Haven Banks Residents’ Group and FESC with the local councillors on 21 January this was discussed and Cllr Diana Moore then requested the publication of these reports. The FVA was made available and later in the week appeared on the web portal, the independent assessment is still not accessible through there. Despite Cllr Moore sending the file of the FVA to all members on the Planning Committee last week, this was probably too late for many struggling to read through the enormous amount of documents accompanying the Water Lane South application. When Mr Vonhoff tried to raise this point in the 3 minutes provided for the ‘Opposer’ speaker, it was not picked up in the discussions afterwards.

To make it absolutely clear, the local councillors and our three organisations all supported the recommendation to approve the Outline Application, we just wanted to raise significant reservations about the Officer’s Report and its recommended conditions.

The article will be continued with comments on other issues like the transport infrastructure in the wider Haven Banks and Water Lane area, and the importance of scrutiny for the future Reserved Matters applications. Critical analysis then will have to translate now allowed maximum heights (blue form in the illustration) into the actual massing on the site (represented as illustration only by the orange form) with the help of the approved Water Lane SPD design codes. Exeter Civic Society can promise to remain a critical friend in all of this.