ECS Hands in Response to Full Draft of the Exeter Plan

On Monday, 15 Jan 2024, Exeter Civic Society handed in their response to the Full Draft of the Exeter Plan. We are keen that the council produces a plan that has policies that are clearly explained, written in a manner that supports the intention of the policy without ambiguity or confusion, and that will not allow an alternative and unintended interpretation of policies that will result in challenge at planning application stage. Throughout the Full Draft Plan, there still is much inconsistency in the writing of policies and how they are numbered. Our response is detailed to help iron these shortcomings out further.

Some Details from our Response

We welcome the widespread appreciation of masterplans, which cater for the needs of the wider area and how new sites will correspond to the existing infrastructure. But masterplans must be developed by the planning authority with consultation with the local community, statutory authorities, and interest groups, and well before individual planning applications are submitted.

ECS welcomes most of the substantial additions to the ‘Climate Change’ chapter. We hope that some of the policies can be further strengthened in the next phase, as national lead on this important issue seems to have weakened over the last year and goals do not look guaranteed at all in the longer future, despite climate change being the most vital challenge to our future on this planet. In this changing political landscape setting its own standards is of strategic importance for ECC. We therefore suggest that all new homes and other developments should be required to be carbon neutral.

ECS shares the vision and the objective of the ‘Homes’ chapter. We welcome the way this chapter has been made much more substantial compared to the Outline Draft Plan, especially that it now has details and a policy on ‘Affordable housing’, and different types of housing. Our comments on the Outline Draft Plan have been widely addressed. We are surprised, given the central importance of density for the brownfield developments, how short and vague Policy H13 on Housing density and size mix is. It does not refer or link to the ‘Exeter Density Study’ from July 2021. It does not say anything about the height of buildings related to their local neighbourhood, plot ratio and street ratio (compared to, for example, the ‘Water Lane Development Framework and Design Guide’, pp.63-67). Given that the increased density will mean flatted homes, should the policy not include external space requirements? The term ‘high density’ is often replaced by ‘optimal density’, but without really explaining what is implied by this term.

Although ECS welcomes the additions to the chapter on ‘Economy and Jobs’, we think it is still too one-dimensional on the knowledge economy and education as ‘transformational sectors’, though it now refers to creative industries as well. It is the necessary transformation of existing sectors which will underpin Exeter’s future economy as much as newer transformational sectors, but this is still not addressed.

We welcome the expansions and clarifications in the ‘Sustainable Transport and Communications’ chapter, compared to the Outline Draft version. Striking the right balance between transport policies that support net zero and a healthier and people-centred environment on the one hand and, on the other, the strong desires of many (and for some, the necessity) of being able to drive a private car is challenging. It leads at times to ambiguity in the Draft Plan. We ask here for a new policy on ‘Last Mile Delivery Hubs’.

ECS is pleased to see a fuller chapter on ‘Natural Environment’ with 3 more policies, but at the same time we are disappointed to see some of our previous comments not making it into the revised plan. In the Vision part of this chapter, the newly added section of ‘City of Culture’ reads oddly: seeing protecting the hills surrounding the city and the Valley Parks as retainment of Exeter’s cultural identity, works with a very wide concept of culture, which we do not find helpful. We would like to bind the tree canopy uplift to the number of new homes instead to the number of trees pre redevelopment.

The chapter and policies on ‘History and Heritage’ do greater justice to Exeter’s heritage. It should, however, be made clear that loss, either in whole or in part, of a designated asset must be avoided and that any development which would result in this will not be permitted. The recent Heritage Harbour designation for the Quay and canal basin should be reflected in the text and the policies.

In the previous consultation for the outline draft plan, we highlighted the need to mention the government’s National Model Design Code, and whilst in the chapter on ‘High Quality Places and Design’ mention of design codes is now included rather than the Tool Kit, we are disappointed that there is not more recognition of the Nation Model Design Code process and principles. We believe that this chapter should be expanded to give more examples of what may be included in a design code, even though we expect the council to produce these. We also believe that engagement with local communities, interest groups and stakeholders should have greater emphasis. The NPPF clearly states that local authorities and communities decide what good quality design looks like.

In the crucial chapter on ‘Infrastructure and Facilities’, we suggest clarifying the role of the plan as follows: ‘The Exeter Plan will provide the essential framework within which decisions can be taken about what infrastructure we need, and about ensuring it is provided in the right way, at the right time and in the right place.’ Either in the plan itself or in supplementary guidance, we suggest that a timetable for delivery should be required as a condition of consent.

The increased detail of information in the chapter on ‘Site  Allocations’ compared to the Outline Draft follows a template which is adapted to the specifics of each individual site. This approach safeguards standards, but currently does not allow for enough site specifics to be included to discuss their own identity. A more site-specific approach has to be added. The chapter should also include specifics for the new employment allocations sites mentioned in Policy EJ6

For the full text of our 30 pages see our response document under: https://exetercivicsociety.org.uk/wp-content/uploads/2024/01/ECS-ExePlanComments-V3.pdf