As well as policies specifically relating to the SW Exeter Urban Extension, the Plan Teignbridge document also has several strategic and environmental policies that will affect the are to the south of Alphington
S4 | Land for New Homes - Density
2.16 states that "the capacity of the sites has been calculated based on a conservative density estimate", yet in the matter of SW Exeter Urban Extension these estimates are not qualified.
It should be hoped that the density in this area - in particular in the land north of the A379 - reflects the aspirations of Exeter City Council [set out in ECC's Core Strategy, adopted Feb 2012.
4. What changes would you suggest should be made to the plan?
In relation to housing density within the SW Exeter Urban Extension, ADD "that the development form would be expected to relate well to adjoining housing. Densities should be appropriate
to the location and it will be important to ensure that the amenity of existing residents is protected."
S4 | Land for New Homes - Housing Numbers
It is a requirement of national planning policy that Local Plans meet objectively assessed housing needs.
I acknowledge that an updated Strategic Housing Market Assessment, carried out by ORS, has reduced the housing need from 14,800 proposed in the original consultation document to the current figure of 12,400.
An independent group of Councillors, comprising the Housing Numbers Review Group, considered evidence contained within the latest data from the Office of National Statistics alongside the ORS research on household formation.
Based on their research, the Councillors recommended that the Core Strategy should reflect a figure of 10,000 new homes.
Their views were reported to the Overview and Scrutiny Committee of Teignbridge District Council on 22 May 2012 and discussed at the Executive meeting on 10 July 2012.
These meetings accurately reviewed the figures under discussion, and the final number appear to have been decided upon an unachievable delivery schedule. To achieve the required 12,800 new homes means that the Council has to deliver a significant increase of additional new homes per annum - 44% more homes than has been achieved over the previous 6 year average. It appears that the figure of 10,000 is more likely to be attained by 2033.
4. What changes would you suggest should be made to the plan?
S4 Land for New Homes
Sufficient land will be made available to increase the rate of new house building to 500 dwellings per years by 2016 and to maintain this rate thereafter to 2033 (an average of 500 per year over the plan period).
S4 | Land for New Homes - Merging settlements
It is a requirement of National Planning Policy that Local Plans "do not merge settlements".
Whilst the policies outlined in the submission do no merge existing settlements within the boundaries of Teignbridge District Council, the proposals for SWE1 West of Exeter Urban Extension could be seen to attempt to fill the the empty land between Alphington [in Exeter City Council's boundaries] and Exminster [within TDC's boundaries].
To achieve the current requirement of 2,000 new homes set out in the submission, development would need to occur both sides of the significant barrier of the busy A379.
4. What changes would you suggest should be made to the plan?
Reduce the requirement for 2,000 new homes in the South West Exeter Urban Extension to 1,500 sited to the south of the A379, thus removing the 500 proposed for the land north of the A379.
S5 | Instructure
It is acknowledged within this policy that "the provisions of new and improved infrastructure, such as education, health , transport, recreational facilities and green infrastructure will form a key issue in planning for the growth of sustainable, resilient communities."
In the specific delivery of suitable and appropriate infrastructure for the SW Exeter Urban Extension, this is NOT a case of adding to existing community infrastructure. Much of the proposed development is due to take place in an area with no current infrastructure.
And if there is current provision, the infrastructure [in terms of school places and roads] are already severely stretched and this demand come under further pressure from the proposed addition of 500 homes within Exeter City Council's boundaries.
In a series of related documents, the outline timetable of additional infrastructure seems out of line with the desire to create a sustainable, resilient community. To deliver a new secondary [or through] school in phase 4 of the development schedule seems a rather bad idea.
4. What changes would you suggest should be made to the plan?
To ensure a strong sustainable, resilient community is developed in the SW Exeter Urban Extension, essential infrastructure must be delivered at an appropriate time. In essence, this the idea time would be ahead of house- building , but if that is not feasible key infrastructure [such as community facilities, schools and transport] must be put in place as early as possible alongside house building. Under NO circumstance can it be timetabled to be in place towards the end of any house-building.
S9 | Sustainable Transport
Whilst the aims and objectives outlined within this policy are to be welcomed, it is hard to support the policies when there are no concrete proposals to ensure that these objectives are met.
The submission acknowledges that it is "a strategic and management policy, not one intended to contain specific proposals" but also states "where appropriate, specific proposals included in the comments are considered within the relevant place chapters or allocations."
Within the SWE1 policy narrative, there is reference to a 'need for modal shift in transport provision", yet nowhere in the proposed submission do I see evidence of this being delivered, or it is evidenced then the timescale is too late within the proposed phasing of the development.
4. What changes would you suggest should be made to the plan?
ADD wording to strengthen the 'need for modal shift in transport provision" in SW Exeter Urban Extension.
ADD an updated outline delivery plan
S10 | Transport Networks - Devon Metro
The policy states "the function of the existing transport network and facilities will be protected." It does little or nothing to develop new and improve existing transport network and facilities.
One new and exciting proposal is the development of the Devon Metro, yet no mention is made of these proposals it this policy.
The plans for a new rail halt at Marsh Barton will to some degree assist in removing commuter traffic from the approach roads to the industrial estates of Matford and Marsh Barton, but does little or nothing to add reliable public transport facilities to the planned 2,500 homes in the SW Exeter Urban Extension.
4. What changes would you suggest should be made to the plan?
It would be useful to acknowledge that as the Devon Metro scheme is rolled out, that the currently unviable rails station at Exminster may be considered for re-opening. If this is the case, here must be ample provision for [park and ride] parking close to the station.
S10 | Transport Networks - Enhancements to A379
The policy states "the function of the existing transport network and facilities will be protected."
The submission goes on to refer to specific strategic provision and mentions the A379 as part of the "locally important road network".
It is also a matter of record that Devon County Council - as the highway authority - are considering various enhancements to the A379.
Without specific details of these enhancements it is impossible to know how the effects of these changes will impact on the SW Exeter Urban Extension, but it can only be assumed that traffic flow along this already busy link/ ring-road for Exeter will increase with the new development. Additional junctions will need to be developed and the possibility of traffic signals will interrupt current traffic flow. The increase traffic will raise the possibility of raised levels of air pollution which will need to have robust measures of mitigation on the new housing developments.
As it currently stands, the A379 appears to be a significant barrier to developing a sustainable, resilient cohesive community within TDC's boundaries
4. What changes would you suggest should be made to the plan?
SW Exeter Urban Extension development should only occur on the land south of the A379
S11 | Pollution
The strategic approach is set out within the policy. Various evidence documents have been used to ensure that the proposed policies are robust and effective. The reduction in pollution referred to in the policy can only relate to existing pollution.
Cross-referencing with the Air Quality Action Plan [March 2009, rev March 2010] highlights that little or no evidence has been collected or collated in respect of current pollution and air quality on the stretch of the A379 that would cut across the 2 development sites of the SW Exeter Urban Extension.
4. What changes would you suggest should be made to the plan?
ADD Instigate and continue to monitor Air Quality along the A379 and put into place measures to migrate the effects of increased traffic flow.
EN1 | Strategic Open Breaks
It is essential that when planning the SW Exeter Urban Extension that the Strategic Open Break between Exeter and Exminster is maintained
4. What changes would you suggest should be made to the plan?
ADD In maintaining maintaining the Strategic Open Break between Exeter and Exminster it is essential that consideration is given to green infrastructure [as addressed in policy WE11] to prevent urban sprawl.
EN6 | Air Quality
As yet there appears to be no monitoring of air quality along the A379 between the 2 proposed development sites for SW Exeter Urban Extension. This measure seems essential to deal with the aims set out in this policy.
4. What changes would you suggest should be made to the plan? I
ADD The current Air Quality Action Plan [March 2009, rev March 2010] needs urgent updating to monitor the current situation along the A379 between the 2 proposed development sites for SW Exeter Urban Extension.
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