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West Manley Lane Conservation Group Response Area B 24 July 2017

TIVERTON EASTERN URBAN EXTENSION (TEUE) AREA B CONSULTATION EVENT

WEST MANLEY LANE CONSERVATION GROUP (WMLCG) RESPONSE:  24 July 2017

Although we are not convinced that the entire TEUE development is warranted and that the resulting problems of traffic flow, employment, civil engineering and infrastructure needs remain unresolved, nevertheless, WMLCG must accept the premise that, at some stage in the foreseeable future, TEUE Area B will commence and we would wish to make sure that the end result is both acceptable and sustainable. A lot of time, effort and money have gone into its design, environmental protection and human requirement; we would hope that by co-operation and contribution, the finished development is a credit to all concerned and not simply a piecemeal response to government pressure, where only landowners and developers are winners.

As we have previously stated, as a group we will concentrate on those matters that are germane to West Manley Lane (WML) and its environs and where decisions on the development will have a direct effect on the future of the lane.

Where possible, we have followed, but not been constrained by, the consultation question summary. However, there are additional matters that have not been addressed in the Masterplan document that we wish to bring to the officers’ attention.

1. What areas of land should be developed?

  1. a.      This depends on the definition of ‘developed’. How much of the land should be built on for housing is dependent on take up of new homes in Area A and the future perceived needs for the town as the scheme progresses. This in turn should govern how much further land is built on in Area B: reason enough to finish Area B before staring on Area B. When commenced, sufficient land must be set aside for public spaces, non-vehicular tracks, play areas, allotments, recreational facilities and the proposed “landscape community hubs”.

2. How much development should be allowed (number of dwellings)?

  1. a.      The outline figure of 500 new homes has been quoted for Area B. Our concern is that for various reasons (financial requirements for Area A, more ‘New Homes Bonus’ payments [UK Gov 2016], easy availability of land) there will be a push for more. In the absence of a constructive narrative, this should be resisted.
  2. b.      Density and design of new homes must be along the guidelines set out for Area   A,    with an appropriate scaling down of density as it approaches the designated parkland and Green Infrastructure as  outlined in MDDC Design Guide June 2016.
  3. c.       MDDC should have the final say in both density and design of housing stock. This must include size, height and internal dimensions of new homes, and must have regard to adequate garage size. It was obvious during Design Guide visits that small garages simply encouraged off road parking and did not take account of the number of cars per household.
  4. d.      The percentage of ‘affordable housing’ incorporated in the plan must reflect the community needs and not be subject to the financial constraints of the developers.
  5. e.      Within the current outline plan, the proposed location of ‘sports and recreation areas’ detached from suitable vehicular access and housing would seem inappropriate.
  6. f.        Once again we bring to the attention of the officers the unresolved matter of building south of WML outlined in Area A. In spite of the democratic vote by MDDC Council and the withdrawal by Chettiscombe Trust of the land involved (letter to MDDC from PCL Ltd 10.04.2015) it remains on the masterplan for reasons beyond rational explanation. Therefore, we are concerned about the robustness of any decisions forthcoming on the Area B masterplan.
  7. g.      Will any potential upcoming building applications for Area B ahead of the adoption of this masterplan be influenced by its terms and MDDC’s Design Guide?
  8. h.      Does MDDC have the authority to insist that a percentage of new homes are only available to local residents?

3. How should the site be accessed?

  1. a.      We are totally against the suggestion that, in order to facilitate the rapid development of TEUE, the carefully planned transition from a completed Area A to a masterplanned Area B is hijacked to serve the orders of central government and the apparent convenience of land owners, speculators and developers. Along with many residents of Tiverton, we are firmly of the belief that no development should begin in Area B until that of Area A has been satisfactorily completed and the access from A to B can progress smoothly as originally outlined.
  2. b.      With reference to vehicular flow in WML we trust that Devon County Council Highways (DCCH) will apply the same constraints to Area B as they did for Area A, based as it was on its surface water drainage, width and vision and no access from the northern part of the development. The same problems would apply to Area B ahead of its development and so would require the same resolution.
  3. c.       Further, it is recommended by DCCH that there should be no access to Area B from Manley Lane (ML) because of the steepness of the exit/entry on Post Hill and the width and visual problems further down ML. (DCCH pers comm June 2017).
  4. d.      In view of the significant increase in non-vehicular traffic usage of WML for recreation, sport and tourism, we ask that consideration be given to the “shared lane” concept previously trialled by Government in other parts of Devon. In addition, a realistic speed restriction should be introduced along the length of WML.
  5. e.      The Drovers Track’s present northerly route peters out shortly before Mayfair; its proximity to new housing will ensure its popularity. That so, it must be retained in its rural state, with a restriction on vehicular use and its protection as a natural corridor. Without adequate safeguards, its exit onto WML at a right-angle bend (GR 983126) suggests a pedestrian/vehicular collision risk.

4.    Which areas should be developed first- the phasing of the development?

  1. a.      The timetable for development is in many respect tied up with the necessary infrastructure that will be required, particularly the siting and construction of civil engineering works to deliver sewage and flood protection. These will have to be positioned far enough down into the Ailsa Brook valley to protect the brook upstream of its entry to the Tiverton Lane Fen SSSI, (TLFSSSI), must incorporate the required number of attenuation ponds and SuDS, be able to link up with the similar model built for Area A and, not least, be able to deal with the private sewage disposal systems of the current houses in WML. The proposed development at Waddeton Park will take the current Tiverton sewage system over capacity.
  2. b.      Further, any such system will have to mitigate against the inevitable increase in surface water flooding consequent on development north of WML Area B, and have regard to the alluvial flooding associated with Ailsa Brook upstream of the TLFSSSI. With regard to this, we draw officers’ attention to pictures of flooding in the Area B segment of WML on WMLCG website (www.westmanleylanecg.org see ‘our gallery-see more’)   
  3. c.       Having satisfied the requirements outlined above, the seemingly obvious direction of development for  Area B would be to grow progressively east from  Blundells Road though Area A (TEUE Masterplan SPD timetable (p101) incorporating the scheduled roads, tracks and Green Infrastructure en route, provided that the framework  keeps meaningful pace with house building: school places, doctors’ surgery and neighbourhood facilities must be available to new residents early on and not as the  last piece of the jigsaw.
  4. d.      Separate staggered pockets of development at Waddeton Park followed by Area A then Area B and the growing threat at Hartnoll Farm risks a disjointed and piecemeal pattern of the sort previously noted at Moorhayes Park by senior planning officers.  Clearly this must be avoided, and is justification for a robust masterplan.

5. Green Infrastructure location, usage and management

  1. a.      Whilst the WYG Ecological Appraisal Report (April 2016) is specifically aimed at Area B, there is much overlapping data from earlier reports viz. Engain Ecological Appraisal (Dec 2013), PCL Planning Ltd in Mixed Use Development off the A361 Tiverton Chapter 6 Biodiversity (May 2014), Natural England (Priority Habitats in WML, pers comm), Devon Biodiversity Records Centre (various), Devon Wildlife Consultants for WMLCG (WML Hedgerow Assessment 2009 and Drovers Track Assessment 2013). All of these flag up both the local and national importance of the fauna and flora within Area B particularly in respect of WML.
  2. b.      We stress that any development within the plan must take due diligence of the findings and recommendations of these reports and, again, suggest officers consult our website for further data.
  3. c.       In particular, WYG p 8 under “important and Devon hedgerows”: “the majority of species rich hedgerows and trees will be retained, protected and enhanced”. Significant damage has already been done to ancient Oak (Quercus robur), broad-leaved woodland and scrub outlined by WYG and Natural England’s Priority Habitat within the curtilage of WML. Again, we would point out that there is sufficient data to recognise those species that need on-going protection from a linear TPO for Area B and ask that consideration be given to its implementation.
  4. d.      All the ecological reports make much of protection, retention, enhancement, replanting and management with reference to woodland, hedgerow and scrub and their role in the well-being of wildlife in the area. It must be made clear as to who will be responsible both for the initiation of these tasks and their long-term maintenance and at what cost.
  5. e.      Any development along WML in Area B must take into account the prehistoric importance of Manley Field, the MDDC listed Heritage Register sites at Copplestone and Prowses Farms and its adjacent Blundells Conservation Area.(www.westmanleylanecg.org see ‘past and present-historical interest) 
  6. f.        Green Infrastructure (GI) means different things to different people. However, what it clearly suggests in the context of this masterplan is a range of various environmentally suitable spaces each with a capacity to allow residents and visitors to find relaxation, recreation or recognition.
    1.                                   i.            The ‘Landscape Community Hubs’ could host children’s play areas and entertainment meeting points.
    2.                                 ii.             Allotments and community orchards should be located within walking distance of the housing units.
    3.                               iii.             Woodland areas as designated should be planted with native broad –leaved species.
    4.                               iv.            All extant hedgerows should be enhanced to provide wildlife connectivity and provide screening for the housing units.
    5.                                 v.             ‘Wetland habitat areas’ should be located and developed around both the attenuation ponds and the present riparian and designated marshland areas.
    6.                               vi.            GI areas will inevitably encourage increasing dog usage. Officers may wish to consider that some of those (play areas, environmental sensitive plots, adjoining farming fields) be protected under Clean Neighbourhoods and Environment Act 2005.
    7.                             vii.            It must be emphasised that, although any environmental plot should be ‘managed’, this does not necessarily equate to the quick-fix concept of ‘neat and tidy’. There is room for scrub and wasteland: in the right place, weeds are wild flowers. Fields in the southern reaches of both Areas A and B could play an important role in both nature conservation and education; consideration should also be given to keeping them in agricultural usage.
    8.                           viii.            GI areas must reflect the need for tourism, education, health and ecology.

We would recommend that any prospective developer for Area B takes note of the house builder’s Barratt Development partnership with RSPB, summed up by quoting their then Group Chief Executive, “working with the RSPB we can make the built environment and shared areas of our development as nature-friendly as possible, and at the same time the developments will become more attractive places to live”.  Further "Our aim is that by 2020 we can demonstrate that we will have a net positive impact on ecology and biodiversity across our development portfolio” (Mark Clare, Feb 2015).

We believe that, with its sensitive inclusion, the importance of WML and its surrounding environment, coupled with its proximity to the proposed development of both Areas A and B, could play a pivotal role in  the ecological, recreational and educational success of TEUE and we look forward to contributing to its evolution.

Dr R W Whittlesey,

For and on behalf of West Manley Lane Conservation Group

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