ECS submitted Response to ‘Draft Water Lane Development Framework and Design Code’

On 5 Dec 2023, Exeter Civic Society submitted its response to the 'Draft Water Lane Development Framework and Design Code'. We were glad to see that our 'Prospectus for the Wider Water Lane Area' had been taken as the first stepping stone in the development of what ultimately will have supplementary planning document status. We are, however, concerned about some of the fundamentals of the draft document and specifics such as density and height of buildings, bicycle path provision and vehicular access to the Water Lane area. Follow up our fundamental concerns and the specifics for each chapter by reading the full news.

Whilst there is much to be happy about with this document, there are elements where we believe further work and amendments are needed, but we also believe there is an opportunity here to turn the short Development Framework into a master plan. The provision of a master plan is set out in the current local plan, and that plan is likely to be in place for a few more years until the Exeter Plan is adopted. There are elements of the design code that are prescriptive so would be much better included in a master plan because they set an outline of how the area will be shaped and connected to the wider area.

We argued for the need for Chapter 3 – Development Framework, to be expanded significantly to be the overriding driver for future development as a master plan. Each of the design code sections has a good plan setting out ideas which are prescriptive and would sit better in this section rather than in the coding, which is more about the detail and nuances.

Exeter Civic Society would like to see more recognition of the character of different parts of the development area: the term ‘urban’ seems to be more suitable for the north western parts, whereas the southeast end clearly marks a boundary with the Riverside Valley Park and its semi-rural character where lower buildings should be positioned. The reason why this is important can be seen in L03 ‘Building heights’ where the building heights coding plan envisages the tallest buildings in the south eastern tip of the development (6 up to 9 storeys in the ‘southern zone’, p. 68). Though we acknowledge the effort to divide the area ‘into five built form zones which respond to the site context’ (pp.64, 69-71), this cityscape/landscape change has not been made fundamental in the argument for the suggested density and heights. Especially for what later is called ‘Southern Zone’ we object to the suggestions of height and density.

The document needs SMART objectives which are specific, measurable, achievable, realistic, and timely. There is a lot of woolly aspirational wording, which would make it very easy for developers to say they have met the objectives. Heights, distances, materials, use etc need to be specified clearly so that the developers’ proposals can be tested against specific requirements.

The document needs to be clear what is policy and what is explanation that is not binding. The current document is not at all clear. Is it only the coloured panels that have to be followed? In its current state, the coloured panels are often very generic and not specific enough.  The specific information is mostly in the text in the white areas, so if these are removed then the detail that is needed will be excluded.

These are some of our more general points. For a chapter by chapter analysis see our response document.