PLAN TEIGNBRIDGE | Strategic and environmental policies

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.

PLAN TEIGNBRIDGE | SWE1 SW Exeter urban Extension

http://www.teignbridge.gov.uk/CHttpHandler.ashx?id=35883&p=0The next stage of the Plan Teignbridge - that of receiving comments on the Proposed Submission for the Local Plan before being sent to the Secretary of Stage - closes at 5pm today.

I'd made comments at the previous stage at the end of March

Below are my comments of the policies relating to the SW Exeter Urban Extension.

SWE1 | Delivery of at least 2000 homes

Following the Proposed Options consultation carried out earlier in the year, and supported by evidence from an updated Strategic Housing Market Assessment prepared by ORS in the summer, the proposed number of new homes has been reduced from 14,800 to 12,400.

Following representations made at the Proposed Options stage, almost all areas have seen a reduction of the allocation of new homes required to be delivered under the Plan Teignbridge scheme between 2016 and 2033.

Indeed, it appears there is only one area where the allocation has not be adjusted, in SW Exeter Urban Extension.

I would hope that this figure remains around 2,000 is not a cynical response from TDC to the fact that 10.3% of the residents of Alphington [the biggest percentage response by far to the Plan Teignbridge consultation] made numerous objections to the proposals yet have no vote within Teignbridge. And analysing the diagram of where those comments come from, I would hazard a guess that most of the "Alphingon Village" made their voices heard.

Yet those voices appear to have gone unheeded. They are still faced with a development of 2,000 new homes - forming a new urban community spanning from Alphington to Exminster.

I have made strong representation over the policy S4 Land for New Homes in a separate submission.

4. What changes would you suggest should be made to the plan?

SWE1 

CHANGE the policy so that it reads a) delivery of at least 1,500 homes..

SWE1 | 10.4

10.4 refers to an approach that reduces the need to travel, yet the new development is intended as an extension to SW Exeter. Local travel in and around Exeter would be necessary but the narrative continues with the aspiration of "focussing new housing, jobs and facilities into locations with existing infrastructure to cope with the increased demand"

The existing infrastructure CANNOT cope with the existing demand, and the small increased demand to be placed upon it by the up to 500 new homes planned to be delivered within the next few years with Exeter City Council's boundaries.

I see little in the Local Plan that will ensure that the current infrastructure can and will be upgraded in a timely manner, alongside the new developments rather than after the new housing is built.

4. What changes would you suggest should be made to the plan?

ADD Improvements to the existing infrastructure must be delivered in a timely manner to cope with the increased demand.

SWE1 | 10.6

10.6 refers to " arrange of infrastructure elements of infrastructure elements that need to be delivered in a timely manner."

Already it is acknowledged that Alphington Primary School is already facing a shortage of places, the West Exe Technical College is fast reaching capacity and the nearby village of Exminster has an existing school that cannot be expanded on its existing site.

Devon County Council has recently produced a document assessing the increasing need for school places within Exeter, yet this document makes no reference to the impending need for additional places in West of Exeter, let alone the planned SW Exeter Urban Extension.

4. What changes would you suggest should be made to the plan?

ADD Devon County Council need to work closely with both local authorities that new schools can be delivered as early as possible in the new SW Exeter Urban Extension.

SWE1 | 10.9

10.9 refers to the SW Exeter Urban Extension as being on "an enhanced public transport route" There has been much talk surrounding a "High Qualilty Public Transport" system being put in place.

However, my own conversations with Devon County Council and Stagecoach seem to suggest that too many demands are being put on to the Enhanced Public Transport for the area and it might be that it might e expected to perform too many roles, namely the proposed Park and Ride rather than being NON-STOP would be a limited stop service through the new development.

This appears to serve neither type of passenger well, slowing down the direct service desired by P&R users and not enough convenient stops of the residents of the new development.

Stagecoach seems to be reluctant to move away from their preferred model of aerial routes into and out of the city centre. The does seem to be a case for the operation of orbital routes that could link the new SW Exeter development with those currently being delivered at Newcourt, Monkerton, Hill Barton, Science Park, Sky Park and Cranbrook.

4. What changes would you suggest should be made to the plan?

ADD Take a multi-agency approach to ensure that a "High Quality Public Transport System"  in keeping with the aspirations of the document "Enhancing the Public Transport System in Exeter" [Feb 2011] is delivered for the area forming the SW Exeter Urban Extension as soon as is practicable.

SWE1 |10.10 - Traffic congestion

10.10 acknowledges that Exeter experiences "traffic congestion along its main arterial routes" and that the SW Exeter Urban Extension needs to encourage "greater use of sustainable forms of transport".

To enable the this to happen, a step change in the provision and use of public transport is needed to remove some traffic. The policy suggests that this is to free up a sufficient capacity to support the development.

That modal shift needs to happen whether the development of the full TDC plans for SW Urban Extension happen or not

Investment in the infrastructure to facilitate this step change is necessary from the outset and all authorities must work tirelessly to ensure that this can be delivered ahead of commencement of the development.

4. What changes would you suggest should be made to the plan?

ADD Take a multi-agency approach to ensure that plans to ensure a "greater use of sustainable forms of transport" are implemented as soon as is practicable.

SWE1 | 10.10 - Park and Ride

10.10 also talks about a replacement park and ride facility within the new development, located to the south of the A379 at the intersection with the A30 and A379.

This site could prove unattractive to drivers approaching from the Dawlish direction.

The new site could prove useful for commuter traffic travelling along A38 from the west, but other sites - such as the employment land adjacent to Peamore - may prove equally suitable.

And the reference to the intersection with the A30 is disingenuous, as there is no direct access to the A379 from the A30 at this point so would not serve any traffic from that direction. If that could be provided, or a another suitable site proposed within the confines of the new development that might serve to reduce the propel for a new P&R site at the Aphington/Ide interchange.

4. What changes would you suggest should be made to the plan?

CHANGE reference from 'replacement' Park and Ride facility to 'additional' 

LOOK AT alternative sites for location P&R facility that might prove more suitable

SWE1 | 10.11 - A379

10.11 acknowledges that at present the A379 could be seen as a barrier which could "divide and prevent a well- connected and sustainable place"

The narrative goes on to suggest that it will be necessary to change the nature of the road so that "it can integrate with and become a functioning part of the development"

But is this actually feasible? The policy admits that the A379 will maintain its "current function and capacity" as an entrance to Marsh Barton and Matford industrial estates and an outer ring-road for Exeter.

The suggestions about speed reduction and pedestrian crossings appear promising but seem to have done little to improve the integration of communities that border the new development around the Countess Wear roundabout, and that's without the added disadvantage of a downward hill on the approach to the Devon Hotel roundabout.

The policy references the SW Exeter Masterplan yet refuses to acknowledge the view in that document that "the development will need to change the nature of the A379"

4. What changes would you suggest should be made to the plan?

ADD The nature of the A379 will need to be fundamentally changed so that it can become a usable space for pedestrians and cyclists, transforming it into a functioning part of the walking and cycling network and a stimulus rather than a barrier to well-connected growth.

SWE1 | 10.13

10.13 suggest that there is a "need for a mix of housing types and sizes" within the development area.

The ECC Local Plan ensures that in the area South of Alphington that "the development form would be expected to relate well to adjoining houses. Densities should be appropriate to the location and it will be important to ensure that the amenity of existing residents is protected."

4. What changes would you suggest should be made to the plan?

ADD The development form would be expected to relate well to adjoining houses. Densities should be appropriate to the location and it will be important to ensure that the amenity of existing residents is protected

SWE1 | 10.16

10.16 highlights that present school provision within the proposed SW Exeter Urban Extension has little or no scope for growth.

The recent report by Devon County Council on the requirement of new schools places for Exeter has no mention of additional spaces in SW Exeter Urban Extension

4. What changes would you suggest should be made to the plan?

ADD The provision of new school places must be investigated with utmost urgency and the delivery of new school places must be delivered alongside new house-building.

SWE1 | 10.23

The timely delivery of the major insfrastructure facilities is seen as an important factor in achieving a sustainable and integrated new community.

Yet the phasing of that infrastructure outlined in this policy appears to work against that successful achievement of a sustainable and integrated new community.

4. What changes would you suggest should be made to the plan?

ALTER the SW Masterplan phasing so that: 

a) remains the same 

b) 500 dwellings with a primary school, Chudleigh Road upgrade, part of Matford Valley Park, public transport improvements, pedestrian enhancement of A379 

c) 1000 dwellings with the remainder of the required infrastructure 

d) 500 dwellings

SWE1 | 10.26

The policy suggests that the TDC development should come towards the latter part of the plan period, suggesting nearer to 2033 than 2016. This means that the ECC phase of the development would not be supported by any new infrastructure pals for many years.

4. What changes would you suggest should be made to the plan?

ADD It would be hoped that phase b) in policy 10.23 above could commence as soon as delivering the required infrastructure can allow.