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WMLCG response to Area B Masterplan April 2020

MID DEVON DISTRICT COUNCIL: Growth, Economy and Delivery, Phoenix House, EX16 6PP

For attention of Christie McCombe

 West Manley Lane Conservation Group response on TEUE Area B Masterplan consultation.

Representatives of WMLCG were able to attend the initial public exhibition before the SARS-CoV-19 pandemic forced its subsequent cancellation. Although the Group continues to have significant doubts as to the concept of the TEUE, nonetheless it accepts  its long term inevitability and is pleased to note that many of the concerns that we have previously raised have been incorporated into the outline Masterplan.


  •  In formulating our response, we have chosen not to be restricted by the questionnaire and to concentrate primarily on those elements of the plan which directly affect the area of West Manley Lane, a policy to which we have adhered from the beginning. In so doing, we fully endorse the sentiments expressed in the Area B Masterplan document (SPD.B) at 4.1, page 61. It is, therefore, most unfortunate that one of those “pockets of mature woodlands”, previously designated as a (Biodiversity Action Plan) Priority Habitat situated at NGR SS 985124 has recently been decimated. With this questionable activity, coupled with other examples of recent tree and hedgerow destruction within the boundary of Area B, we can but hope that MDDC seriously considers apportioning suitable protection to those remaining “rich hedgerows and areas of mature trees”, currently in private ownership, ahead of the implementation of its Green Infrastructure (GI) project. We bring to the attention of both officers and planners that in accordance with the criteria of the Hedgerow Regulations 1997 the hedgerows of West Manley Lane are all defined as ‘important’ based on wildlife and landscape. As such they are afforded protection under that said regulation and any proposed removal of the hedgerows would require a hedgerow removal notice issued from the Local Planning Authority prior to any such works.

(Devon Wildlife Consultants, Hedgerow Assessment Report No: 09/085 Date: September 2009 Client: West Manley Lane Conservation Group (WMLCG) Andrew Charles MSc MIEEM).


Whilst it is not strictly within the overall setting of the SPD.B, we feel that the outcome of the recent Planning Inspectorate’s dismissal of the appeal at NGR SS984 125 (APP/Y1138/W/19/3239009). must be considered here, as the inspector clearly feels that the site in question is open to “mixed use development”. That being the case, he seems to be taking a contrary view to the “no development south of West Manley Lane unless in association with green infrastructure” decision taken earlier by MDDC. This suggests that all areas outlined in yellow within TEUE Area B could be similarly designated should further planning applications be submitted by relevant landowners. (Appeal decision para 25). That said, it is important that from the outset of this Masterplan:


  • Both the MDDC and planners should define what is meant by “mixed use development”.
  • They should indicate which sites in TEUE Area B might be scheduled for any such development as defined above and which might be considered as contributing ultimately to the GI plan.
  • That the “landowner collaboration” set out on SPD.B p117 is in place from the outset and is sufficiently robust.


South of West Manley Lane:  Countryside Park.

  • In the formulation of the masterplan for Area A, it was confirmed that there would be no vehicular exit from developments north of and onto West Manley Lane (WML), existing gaps would be infilled, and no new ones created. With the publication of SPD.B there are two extant vehicular exits (at Sweet Meadow and Prowses Farm) and one footpath (Drovers Track) north of and onto WML. Can we safely assume that as with Area A, no further northern exits will be created and the existing field gaps similarly infilled?
  • The SPD.B seems to be leaving an option open to access Manley Lane (ML) through Hartnoll Farm complex. This option could cause further traffic issues in ML and so potentially into WML. This issue should be addressed before the finalisation of SPD.B
  • It is imperative that to maintain the nature of WML, the southern barrier of the designated sports area remains as the current ancient hedgerow, enhanced were necessary, and  that no gaps are permitted  for use by traffic, vehicular or pedestrian, intent on attending these sports fields. 
  • It is assumed that the purpose of creating the Country Park (CP) within the GI is to attract, more visitors, and that these will access the CP through the network of indicative green routes, which would including WML. Current tractor and van movements leave no safe room for pedestrians over long stretches of WML. Therefore, it is imperative that this increase of non-vehicular traffic (e.g. walkers, joggers, cyclists and horse riders) confronting even the present level of vehicular traffic will require adequate provision of refuges using the existing outlines of the lane, without resorting to hedgerow destruction.
  • In particular, the indicative plan to use Drovers’ Track as a green corridor from the northern housing development towards the southern CP will access WML at a blind right -angle bend in the road. An appropriately designed gateway should be provided at this point of exit to safeguard the user. See below:
  • Regarding these green routes, it is essential that they are appropriately designated ((footpath, bridleway, restricted or public byway) which will dictate non-vehicular usage, thereby safeguarding the user and protecting the environment. Consideration should be given to nominate WML as a “shared lane” a concept previously trialled in other parts of Devon (see Powderham Lane project DCC 2011)
  • Whilst it is realised that these illustrated pathways linking housing with the green infrastructure are ‘indicative’ and not ‘definitive’, it appears that the table- top exercise has not taken note of the particular topography south of WML:


  1. 1.       To gain access to the “orchard and natural play area”(DN564794) and then on to the Railway Walk (RW) and Grand Western Canal(GWC) (shown on SPD.B map p 116 but inexplicably not on pp 100,102) would require breaching up to 12 feet of the existing hedge bank contrary to the planners stated “every effort should be made to retain existing hedgerows…”.
  2. 2.       This indicative footpath would require a newly constructed bridge to cross the Ailsa Brook somewhere before reaching the RW; the route as illustrated, would also require a degree of repair of the associated culvert to ensure safety.
  3. 3.       Rather than creating new pathways (as illustrated above) use could be made of the existing tracks and associated bridges situated at Pool Anthony and Black Bridges.
  4. 4.       Consideration should be given to suitable screening of those houses backing on to the proposed ‘natural play’, orchard and picnic areas as set out on  pp100,102 Further, siting a bird hide on the edge of the picnic area would seem tenuous: perhaps this field could be left to agriculture, as at present. A flock of sheep is just as in keeping with the concept of green infrastructure, rough pasture attracts much needed invertebrates. Alternatively, the field could simply be planted with appropriate native trees and shrubs to attract wildlife.


  • Whilst WMLCG is satisfied with the inclusion of long-term management and maintenance (p118), nonetheless the plan envisaged is far from conclusive and we would hope that a definitive structure is permanently in place before work within the CP is underway.
  • The approach to development phasing incorporating Areas A&B (e.g. p112) seems far from settled and as such suggests that any piecemeal development could adversely affect the overall impact on the CP
  • Understandably at this stage, there is little reference to the required civil engineering works involving land and properties around WML. Presumably, SuDS, mains drainage and water supply will have to be incorporated into this area and will need to have been agreed between developers and current residents on both sides of the lane.


Given the apparent need for this venture with its diverse requirements, WMLCG is satisfied with the overall balance of development versus ecology and the expression of importance for environmental protection. In our opinion a significant amount of the indicative planning within the proposed Countryside Park needs refinement and clarification, as we have set out above. However, we would be happy to contribute further and to be involved in its evolution.


Dr R W Whittlesey,

For and on behalf of West Manley Lane Conservation Group.

EX16 4NH

6th April 2020

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