Rockbeare Neighbourhood Plan Evidence Report - the Strategic Framework

Content:

Section page: Introduction 2 Natural Environment 6 Built Environment 22 Cranbrook and Exeter Growth Point 31 Housing 41 Community Services and Facilities 56 Transport and Accessibility 71 Employment 78 Renewable Energy 87 Minerals and Waste 95 Appendix – Source Documents 104

Compiled with the help of Paul Weston, Community Consultant

Rockbeare Strategic Framework

Introduction Planning policy and proposals need to be based on a proper understanding of the place to where they relate, if they are to be relevant, realistic and address local issues effectively. It is important that the neighbourhood plan is based on robust information and analysis of the local area; this is called the ‘evidence base’. Unless policy is based on firm evidence and proper community engagement, then it is more likely to reflect the assumptions and prejudices of those writing it than to reflect the needs and aspirations of the wider area and community.

We are advised that “the evidence base needs to be proportionate to the size of the neighbourhood area and scope and detail of the Neighbourhood Plan. Other factors such as the status of the current and emerging Local Plan policies will influence the depth and breadth of evidence needed. It is important to remember that the evidence base needs to reflect the fact that the plan being produced here will have statutory status and be used to decide planning applications in the neighbourhood area. It is necessary to develop a clear understanding of the neighbourhood area and policy issues covered; but not to review every piece of research and data in existence – careful selection is needed.”1

This particular report sets out that part of the evidence base that can be described as the ‘strategic context’ i.e. those strategies and policies that currently prevail and will need to be acknowledged throughout the neighbourhood planning process. To meet the basic conditions laid down by the neighbourhood planning legislation, the Neighbourhood Plan will need to conform to conform to several of these strategies.

We have extracted the relevant national and area-wide policies from the key documents that provide the context for the Neighbourhood Plan. These include:  the Government’s National Planning Policy Framework (NPPF) and National Planning Practice Guidance (NPPG)  the ‘strategic’ planning policies being produced by East Devon District Council (EDDC) through its Local Plan (covering the whole District) and the Villages Development Plan Document (Villages DPD)  the strategies of statutory bodies, other agencies and service delivery organisations

These all provide valuable background and context that needs to be understood before the Neighbourhood Plan can be prepared. Other key documents are ‘signposted’ and should be considered if necessary to help to fill gaps in understanding the context within which we plan, following completion of local research.

This report provides a synopsis of the ‘strategic’ evidence base for our Neighbourhood Plan. It is important to recognise that this report provides a snapshot in time of available documented evidence. There may well be other written reports and strategy documents that become available in due course, which do not currently feature in this report but may need to be taken into account as the Neighbourhood Plan develops.

The more local information relating to Rockbeare parish and that gathered through consultation with the community through events, discussion and the community surveys is documented in other reports. All of this ‘evidence’ will be considered together in due course to help identify the key themes, the vision, aims and objectives and subsequently the policies for the draft Rockbeare Neighbourhood Plan.

1 Neighbourhood Planning Roadmap, Locality, 2013 - http://locality.org.uk/resources/neighbourhood-planning-roadmap-guide/ Rockbeare NP Strategic Framework page 2

Key Planning Documents There are a number of key planning documents which are relevant to most of the topic areas analysed in this report. It is important to understand, in general terms, what these documents are and the implication of their content to the neighbourhood plan. They provide the strategic context with which the Neighbourhood plan needs to conform. To aid comprehension of these documents we have extracted the relevant policy statements and descriptions.

National Planning Policies The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England, setting the parameters within which the planning system, local planning authorities and Neighbourhood Plans should work and be set. In effect, together with relevant statutory legislation, the NPPF along with its companion National Planning Practice Guidance (NPPG) set out the ‘rules’ within which the planning system has to operate. The NPPF is set within the context of a ‘presumption in favour of sustainable development’2. Translating this to what it means for Neighbourhood Plans, it states that “neighbourhoods should:  develop plans that support the strategic development needs set out in Local Plans, including policies for housing and economic development;  plan positively to support local development, shaping and directing development in their area that is outside the strategic elements of the Local Plan; and,  identify opportunities to use Neighbourhood Development Orders to enable developments that are consistent with their neighbourhood plan to proceed.”3

The NPPF also sets out the planning context within which Neighbourhood Plans should work. “Neighbourhood planning gives communities direct power to develop a shared vision for their neighbourhood and deliver the sustainable development they need. Parishes and neighbourhood forums can use neighbourhood planning to: ● set planning policies through neighbourhood plans to determine decisions on planning applications; and, ● grant planning permission through Neighbourhood Development Orders and Community Right to Build Orders for specific development which complies with the order.” 4

It goes on to state that “Neighbourhood plans and orders should not promote less development than set out in the Local Plan or undermine its strategic policies…. Outside these strategic elements, neighbourhood plans will be able to shape and direct sustainable development in their area. Once a neighbourhood plan has demonstrated its general conformity with the strategic policies of the Local Plan and is brought into force, the policies it contains take precedence over existing non-strategic policies in the Local Plan for that neighbourhood, where they are in conflict. Local planning authorities should avoid duplicating planning processes for non- strategic policies where a neighbourhood plan is in preparation.” 5

The National Planning Practice Guidance (NPPG) amplifies the policies in the NPPF and provides further detailed and technical guidance. It contains explanations of the main processes that a neighbourhood plan must go through and also sets out the ‘basic conditions’ with which a neighbourhood plan must comply before proceeding to a local referendum and being ‘made’ (approved), which are as follows: a. having regard to national policies and advice contained in guidance issued by the Secretary of State it is appropriate to make the order (or neighbourhood plan). b. having special regard to the desirability of preserving any listed building or its setting or any features of special architectural or historic interest that it possesses, it is appropriate to make the order. This applies only to Orders.

2 See paragraph 14 of the NPPF for the definition of the ‘presumption in favour of sustainable development’. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 3 Paragraph 16, NPPF, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf states 4 Paragraph 183, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 5 Paragraph 184, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf Rockbeare NP Strategic Framework page 3 c. having special regard to the desirability of preserving or enhancing the character or appearance of any conservation area, it is appropriate to make the order. This applies only to Orders. d. the making of the order (or neighbourhood plan) contributes to the achievement of sustainable development. e. the making of the order (or neighbourhood plan) is in general conformity with the strategic policies contained in the development plan for the area of the authority (or any part of that area). f. the making of the order (or neighbourhood plan) does not breach, and is otherwise compatible with, EU obligations. g. prescribed conditions are met in relation to the Order (or plan) and prescribed matters have been complied with in connection with the proposal for the order (or neighbourhood plan).6

The Adopted East Devon Local Plan A new Local Plan for East Devon was formally adopted by East Devon District Council on the 28th January 2016. The new Plan sets the strategic context and strategic planning policies with which the neighbourhood plan needs to be in ‘general conformity’. This Evidence Report highlights relevant strategy statements and development management policies of the new Local Plan in text boxes as below.

Strategy 1 - Spatial Strategy for Development in East Devon: Planned provision (including existing commitments) will be made in East Devon for: 1. A minimum of 17,100 new homes in the 2013 to 2031 period; and 2. Development on around 150 hectares of land for employment purposes. The overall spatial development approach is as set out below: 1. East Devon's West End will accommodate significant residential development and major employment development to attract strategic inward investment along with supporting infrastructure and community facilities. 2. The seven main towns of East Devon will form focal points for development to serve their own needs and the needs of surrounding rural areas. 3. The Local Plan will set out how development in smaller towns, villages and rural areas will be geared to meeting local needs.

The Neighbourhood Plan will not be able to contest the overall scale of housing proposed, broad location or site specific housing allocations deemed as ‘strategic’ in the Local Plan, once adopted. Other policies deemed as ‘strategic’ and identified in Part 1 of the Local Plan will also need to be used as the policy framework within which the neighbourhood plan is set. These strategic policies can only be amplified or given ‘granularity’ (further detail) in the local context where they provide added value in policy terms. The Development Management policies, in part two of the Local Plan, can be replaced, for good reason, by local neighbourhood planning policies in an adopted Neighbourhood Plan.

The new Local Plan recognises that “if a Neighbourhood Plan is produced it will be in accordance with and apply these strategic policies but it can supersede or overwrite the development management policies in Part Two of the Plan.”7

6 Paragraph 065, National Planning Practice Guidance, DCLG, 2014. The basic conditions are set out in paragraph 8(2) of Schedule 4B to the Town and Country Planning Act 1990 as applied to neighbourhood plans by section 38A of the Planning and Compulsory Purchase Act 2004. 7 http://eastdevon.gov.uk/media/1515081/local-plan-adopted-text-subject-to-final-layout-changes-jan-2016.pdf Rockbeare NP Strategic Framework page 4

East Devon Local Plan Map – West Area (extract)

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Natural Environment National Planning Policy Framework Section 11 focuses on conserving and enhancing the natural environment while the preceding section 10 is concerned with meeting the challenge of climate change, flooding and coastal change.

The following paragraphs8 are of most relevance to the natural environment in broad terms: 109. The planning system should contribute to and enhance the natural and local environment by:  protecting and enhancing valued landscapes, geological conservation interests and soils;  recognising the wider benefits of ecosystem services;  minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures 110. In preparing plans to meet development needs, the aim should be to minimise pollution and other adverse effects on the local and natural environment. Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this Framework 113. Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geo-diversity sites or landscape areas will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks

Natural England National Character Areas9 National Character Areas (NCAs) divide England into 159 distinct natural areas. Each is defined by a unique combination of landscape, biodiversity, geo-diversity and cultural and economic activity. Their boundaries follow natural lines in the landscape rather than administrative boundaries, making them a good decision making framework for the natural environment.

NCA profiles provide a broad range of information that can be used by individuals and communities to help achieve a more sustainable future. The profiles include a description of the ecosystem services provided in each character area and how these benefit people, wildlife and the economy. They identify opportunities for positive environmental change (statements of environmental opportunity) and provide the best available information and evidence as a context for local decision making and action.

Rockbeare fall within NCA 148 area: Devon Redlands. The defining characteristics of this area are given as “deep, narrow lanes, gently rolling hills, network of hedgerows enclosing relatively small grazed or arable fields, hedgerow trees and small copses give wooded appearance, flat bottomed valleys, extensive floodplains, with larger arable or grazed fields.”

The NCA Profile for area 148 Devon Redlands10 identifies four statements of environmental opportunity:  SEO 1: Protect and manage the value and integrity of the coastal and estuarine landscape with its diversity of cliffs, geology, geomorphology, historic features, habitats and associated wildlife, contributing to the livelihoods, enjoyment and education of people.  SEO 2: Manage, enhance and where necessary protect the diversity of land use and activity which gives the Devon Redlands its distinctive character. Increase the connectivity of key habitats for the benefit of landscape, biodiversity and ecosystem services.

8 NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 9 www.naturalengland.org.uk/publications/nca/default.aspx 10 National Character Area Profile, 148 Devon Redlands, Natural England, 2014 http://publications.naturalengland.org.uk/publication/6150022?category=587130 Rockbeare NP Strategic Framework page 6

 SEO 3: Protect and manage the distinctive character of the landscape, the natural beauty, scenic quality, historic environment and geological features. Enhance recreational resources, access to nature and heritage assets, particularly along the coast, to ensure public benefit and enjoyment.  SEO 4: Plan and manage for a strong landscape framework to support and integrate the expansion of Exeter, Exmouth, Teignmouth, Tiverton, Crediton and Cullompton, and the road and rail network throughout the area. Conserve and enhance the existing character, form and pattern of the area’s historic settlement, from single farmsteads to larger villages.

East Devon Local Plan 2013-2031

Strategy 5 – Environment: All development proposals will contribute to the delivery of sustainable development, ensure conservation and enhancement of natural historic and built environmental assets, promote ecosystem services and green infrastructure and geodiversity. Open spaces and areas of biodiversity importance and interest (including internationally, nationally and locally designated sites and also areas otherwise of value) will be protected from damage, and the restoration, enhancement, expansion and linking of these areas to create green networks will be encouraged through a combination of measures to include: 1) Maximising opportunities for the creation of green infrastructure and networks in sites allocated for development; 2) Creating green networks and corridors to link the urban areas and wider countryside to enable access by all potential users; 3) The designation of Local Nature Reserves and County Wildlife Sites; 4) Minimising the fragmentation of habitats, creation of new habitats and connection of existing areas to create an ecological network that is identified within the East Devon District Council Local Biodiversity Plan; 5) Progress towards delivering the Biodiversity Action Plan targets and Local Nature Reserve Strategy; 6) Conservation and enhancement of Sites of Special Scientific Interest (SSSI) in accordance with the Wildlife and Countryside Act. and other statutory and non-statutory nature conservation and wildlife sites and areas of value; 7) Making use of and protecting from development areas that are vulnerable to surface water runoff and flooding. 8) Working in partnership with neighbouring authorities to implement a consistent and strategic approach to the protection and enhancement of the highest tier of wildlife sites.

New development will incorporate open space and high quality landscaping to provide attractive and desirable natural and built environments for new occupants and wildlife. It will contribute to a network of green spaces and ensure potential adverse impacts on the Exe Estuary and East Devon Pebblebed Heaths European wildlife sites are appropriately mitigated against. Where there is no conflict with biodiversity interests, the enjoyment and use of the natural environment will be encouraged and all proposals should seek to encourage public access to the countryside.

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Landscape National Policy Planning Framework 109. The planning system should contribute to and enhance the natural and local environment by:  protecting and enhancing valued landscapes, geological conservation interests and soils;  recognising the wider benefits of ecosystem services;  minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;  preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and  remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. 117. To minimise impacts on biodiversity and geodiversity, planning policies should:  plan for biodiversity at a landscape-scale across local authority boundaries;  identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;  promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;  aim to prevent harm to geological conservation interests; and  where Nature Improvement Areas are identified in Local Plans, consider specifying the types of development that may be appropriate in these Areas. 123. Planning policies and decisions should aim to:  …  identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. 125. By encouraging good design, planning policies and decisions should limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation.

East Devon Local Plan 2013-2031

Strategy 46 - Landscape Conservation and Enhancement and AONBs: (extract) Development will need to be undertaken in a manner that is sympathetic to, and helps conserve and enhance the quality and local distinctiveness of, the natural and historic landscape character of East Devon, in particular in Areas of Outstanding Natural Beauty. Development will only be permitted where it: 1. conserves and enhances the landscape character of the area; 2. does not undermine landscape quality; and 3. is appropriate to the economic, social and well-being of the area.

The … East Devon District Landscape Character Assessment & Management Guidelines 2008 and the Devon County Council Landscape Character Areas Assessment should be used in design and management considerations.

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County and District Landscape Character Assessment & Management Guidelines The County assessment of landscape character places Rockbeare within the broad ‘Clyst Lowland Farmlands’ LCA which is characterised by intensively farmed, lower lying, lightly undulating topography and historic parkland.

The East Devon District landscape character assessment identifies the majority of Rockbeare Parish as falling within its landscape character type (LCT) 4D: ‘Lowland Plains’. Key characteristics of this LCT are recorded as follows: • Level to gently sloping landform • Mixed farmland, often arable cultivation • Small discrete broadleaf woodlands • Regular medium to large field pattern with local variation • Wide low roadside hedges and banks with hedgerow oaks • Settled, with mixed pattern of large villages, hamlets or isolated farms • Some villages significantly enlarged and modified by 20th century expansion • Victorian estate cottages and large farm buildings • Extensive commercial development • Long views over low hedges • Surprising feeling of remoteness in some parts, despite general level of development

Management Guidelines for the 4D landscape character area, as set out by East Devon District Council, are: Boundaries: conserve and enhance by: 1. Encouraging gapping up of hedges with locally indigenous species 2. Encouraging the appropriate management of hedges, in particular to benefit elm hedgerows and ensure their survival in the face of Dutch Elm Disease 3. Encouraging the maintenance and increased planting of hedgerow oaks, to provide vertical elements and help screen development Farming and land use: conserve by: 1. Encouraging traditional mixed farming as the dominant land use throughout this type 2. Encouraging the retention of traditional pastoral farming Semi-natural habitats: conserve by: 1. Encouraging the maintenance and restoration of orchards Settlement and development: conserve by: 1. Where development is permitted, including woodland and copses in development proposals, to increase screening and ecological links 2. Encouraging a characteristic low, small-scale pattern in new development, including industrial uses 3. Where development is permitted, using red brick for boundary walls in and around settlements 4. Encouraging housing development which reflects and respects local Victorian scale, detailing and materials. Informal recreation: renew character by: 1. Encouraging the provision of recreational opportunities and a good rights of way linkage in all development and restoration11

11 Landscape Character Assessment & Management Guidelines, East Devon and Blackdown Hills Areas of Outstanding Natural Beauty and East Devon District, East Devon DC, 2008

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Biodiversity and Geo-diversity National Planning Policy Framework 114. Local planning authorities should:  set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure; 117. To minimise impacts on biodiversity and geodiversity, planning policies should:  plan for biodiversity at a landscape-scale across local authority boundaries;  identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;  promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;  aim to prevent harm to geological conservation interests; and  where Nature Improvement Areas are identified in Local Plans, consider specifying the types of development that may be appropriate in these Areas.

National Planning Practice Guidance Guidance > Natural Environment > Biodiversity, ecosystems and green infrastructure 008. Local and neighbourhood plans and planning decisions have the potential to affect biodiversity or geodiversity outside as well as inside designated areas of importance for biodiversity or geodiversity. Local planning authorities and neighbourhood planning bodies should therefore seek opportunities to work collaboratively with other partners, including Local Nature Partnerships, to develop and deliver a strategic approach to protecting and improving the natural environment based on local priorities and evidence. Equally, they should consider the opportunities that individual development proposals may provide to enhance biodiversity and contribute to wildlife and habitat connectivity in the wider area.

In considering how development can affect biodiversity, and how biodiversity benefits could be delivered through the planning system, it is useful to consider:  the policies and commitments in Biodiversity 2020;  the contents of any existing biodiversity strategies covering the relevant local or neighbourhood plan area and any local biodiversity action plans;  the potential effects of a development on the habitats or species on the Natural Environment and Rural Communities Act 2006 section 41 list (in Biodiversity 2020)  whether an ecological survey is appropriate;  the factors listed in guidance on local ecological networks that supports National Planning Policy Framework paragraph 117.

The statutory obligations in regard to international and national designated sites of importance for biodiversity must also be considered. 017. Biodiversity maintenance and enhancements through the planning system have the potential to make a significant contribution to the achievement of Biodiversity 2020 targets. Biodiversity enhancement in and around development should be led by a local understanding of ecological networks, and should seek to include:  habitat restoration, re-creation and expansion;  improved links between existing sites;  buffering of existing important sites;  new biodiversity features within development; and  securing management for long term enhancement. Rockbeare NP Strategic Framework page 10

The NPPG explains the value of ecological networks and what evidence should be taken into account in identifying and mapping them. Paragraph 009 - The components of an ecological network are explained at section 2.12 of the Natural Environment White Paper12.  Relevant evidence in identifying and mapping local ecological networks includes:  the broad geological, geomorphological and bio-geographical character of the area, creating its main landscapes types;  key natural systems and processes within the area, including fluvial and coastal;  the location and extent of internationally, nationally and locally designated sites;  the distribution of protected and priority habitats and species;  areas of irreplaceable natural habitat, such as ancient woodland or limestone pavement, the significance of which may be derived from habitat age, uniqueness, species diversity and/or the impossibilities of re- creation;  habitats where specific land management practices are required for their conservation;  main landscape features which, due to their linear or continuous nature, are important for the migration, dispersal and genetic exchanges of plants and animals, including any potential for new habitat corridors to link any isolated sites that hold nature conservation value, and therefore improve species dispersal;  areas with potential for habitat enhancement or restoration, including those necessary to help biodiversity adapt to climate change or which could assist with the habitats shifts and species migrations arising from climate change;  an audit of green space within built areas and where new development is proposed;  information on the biodiversity and geodiversity value of previously developed sites and the opportunities for incorporating this in developments; and  areas of geological value which would benefit from enhancement and management.  Local Nature Partnerships can be a useful source of information for existing ecological networks.

Paragraph 13 - Information about ecosystems services is in Biodiversity 2020, A strategy for England’s biodiversity and ecosystems services. An introductory guide to valuing ecosystems services has also been published by Defra along with a practice guide, which could, where appropriate, inform plan-making and decision-taking on planning applications. The National Pollinator Strategy: for bees and other pollinators in England is a ten year plan to protect pollinating insects which support our food production and the diversity of our environment.

12 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/228842/8082.pdf Rockbeare NP Strategic Framework page 11

Devon Biodiversity Action Plan This document is Devon's response to the national biodiversity planning process and takes the objectives and targets of the UK Biodiversity Action Plan and translates and amplifies these within a local context. It is intended to provide a consensus on the priorities for conservation action within Devon. Relevant overall ‘common theme’ objectives: Legislation and planning 1. Ensure that policies within statutory development plans fully recognise the importance of the biodiversity and geological features of Devon, and the need to maintain them. 2. Ensure full consideration of nature conservation issues in the implementation of all planning and regulatory functions, in order to maintain the full range, extent and quality of Devon’s biodiversity and geological heritage. 3. Seek to reconcile the objectives of bio- and geo-diversity conservation with the need for economic and social development in Devon, to achieve environmental sustainability.

Policy for the wider environment: 1. Focus upon and invest in the further development of environmentally sustainable forms of forestry, farming and fisheries production in Devon and its inshore waters, which conserve and enhance biodiversity rather than reducing it. 2. Maintain and where necessary seek to improve the quality of air and water in Devon, to provide a sustainable environment for a healthy biodiversity. 3. Safeguard the integrity and promote the sustainable management of linear features in Devon, such as hedges, rivers and streams, disused railways and roadside verges.13

The Devon BAP contains Action Plans for 20 of Devon’s key wildlife habitats and geological features and for 20 of its species, notable either for their threatened status or popular appeal, or both. Each Action Plan has its own set of objectives, actions and targets. Not all are relevant to the area, but they can be referred to if required. Habitats of particular interest may be wet woodland, cities, towns and villages, flower-rich meadows and pastures, lowland heathland, and species-rich hedges.

Devon Minerals Local Plan Both the County’s Mineral Plan and Waste Plan recognise the importance of protecting our ecology and local habitats. The key policies in the new Minerals Plan relating to the natural environment are: Policy M17: Biodiversity and Geodiversity Mineral development will protect and enhance wildlife and geodiversity through its layout, design and operational practices. Protection of sites and species will be commensurate with their status and the contribution that they make to Devon’s ecological networks. International Sites International nature conservation and geological sites will be protected and all proposed development will avoid adverse impacts….. National Sites and Habitats Sites of Special Scientific Interest, National Nature Reserves, Marine Conservation Zones and irreplaceable priority habitats such as ancient woodland and aged or veteran trees will be protected. Mineral development which impacts on one or more of these assets will only be permitted where the impact does not conflict with the wildlife or geological conservation interests of that asset and its supporting habitat and features, unless the need for, and benefits of, the development clearly outweigh the loss. Local Sites and Other Priority Habitats Mineral development that will impact on local sites (including County Wildlife Sites and County Geological Sites) and other priority habitats will be permitted where it can be demonstrated that: (a) the proposal will not significantly harm the site; or

13 Devon Biodiversity and Geodiversity Action Plan, Devon County Council, version 2009 Rockbeare NP Strategic Framework page 12

(b) the benefits of the development outweigh any adverse effects and such effects can be satisfactorily mitigated or, as a last resort, compensated for through offsetting. Species Mineral development that would impact on legally protected species, UK priority species and other key Devon species will be permitted where it can be demonstrated that: (a) favourable conservation status of the species is maintained; and (b) appropriate avoidance, mitigation, compensation and enhancement measures proportionate to the importance of the species are put in place. Mineral development proposals will be permitted where they result in a net gain for wildlife proportionate to the nature and scale of the proposal. Proposals should show a positive contribution to the restoration, creation, protection, enhancement and management of ecological networks at the landscape scale (including areas identified on the Devon Rebuilding Nature Map). Proposals that achieve the retention of geological exposure for access for education and research will be encouraged.

Policy M18: Landscape and Visual Impact The scale, design layout and operational practices of all mineral development will be sympathetic to the valued or special qualities, distinctive character and features of the landscape. Development proposals must be supported by Landscape and Visual Impact Assessment that reflects the nature, scale and location of development………….

Policy M21: Natural Resources The sustainable development of minerals will conserve and enhance other natural resources, and proposals will be permitted where they would not: (a) harm the quality, availability and/or flow of water and the integrity and function of the water system, both surrounding and, where relevant, within the site; (b) harm the quality of soil resources during mineral operations and the soil’s storage; and (c) result in the loss of the best and most versatile agricultural land unless it can be shown that there is no alternative to that loss and the environmental, social and economic benefits of the proposal outweigh this loss. Any negative impacts of mineral development on natural resources must be mitigated through appropriate measures including the maintenance of water flows and quality and the effective stripping, storage and placing of soils. Proposals that make efficient use of water resources, including reusing process water, will be encouraged.14

Devon Waste Local Plan (adopted 2014) The County’s Waste Plan 2011-2031 makes particular reference to protecting the areas of ecological interest. Policy W11: Biodiversity and Geodiversity 1. Waste management development will protect and enhance wildlife and geodiversity through its siting, design and operational practices. Protection of sites and species will be commensurate with their status and the contribution that they make to Devon’s ecological networks. 2. International Sites International nature conservation and geological sites (including Natura 2000 sites) will be protected and all proposed development should seek to avoid impacts…….. 3. National Sites and Habitats Sites of Special Scientific Interest, National Nature Reserves, Marine Conservation Zones and irreplaceable priority habitats such as ancient woodland and aged or veteran trees will be protected. Waste management

14 Devon Minerals Plan Pre-Submission Consultation, Devon County Council, Aug 2015 Rockbeare NP Strategic Framework page 13 development which impacts on one or more of these assets will only be permitted where the impact does not conflict with the wildlife or geological conservation interests of that asset. 4. Local Sites, Local Nature Reserves and Other Priority Habitats Waste management development that will impact on local sites (County Wildlife Sites and County Geological Sites) and other priority habitats will be permitted where it can be demonstrated that: (a) the proposal will not significantly harm the site; or (b) the benefits of the development outweigh any adverse effects and such effects can be satisfactorily mitigated or, as a last resort, compensated for through offsetting. 5. Species Waste management development that would impact on legally protected species, UK priority species and other key Devon species will be permitted where it can be demonstrated that: (a) favourable conservation status of the species is maintained; and (b) appropriate avoidance, mitigation and enhancement measures are put in place.

Policy W12: Landscape and Visual Impact 1. The scale, design and location of all waste management development should be sympathetic to the qualities, distinctive character and setting of the landscape. Development proposals should be supported by Landscape and Visual Impact Assessment that is proportionate to the nature, scale and location of development, in order to convey likely significant effects and demonstrate: (a) how the siting, scale and design of proposals respond to the landscape context and can be integrated into the landscape without harming its distinctive character or valued qualities; (b) how any potential adverse visual impacts on sensitive receptors will be avoided or minimised to acceptable levels within a reasonable period; and (c) the opportunities that are being taken to improve the character and quality of the area and the way it functions. In taking landscape into account, reference should be made to relevant landscape character assessments. 2. Waste management development will not be permitted where it will have an adverse effect on the natural beauty, distinctive landscape character and special qualities of Dartmoor National Park, Exmoor National Park or their settings. 3. Waste management development will only be permitted within an Area of Outstanding Natural Beauty (AONB), or at locations that would harm the special qualities or the setting of that AONB, where it can be demonstrated that: (a) there are no deliverable alternative sites outside the AONB and its setting; and (b) any impacts on the special qualities of the AONB can be avoided or adequately mitigated to acceptable levels; and/or (c) the environmental, social and economic benefits of the proposal outweigh the adverse impacts on the AONB; and (d) in the case of major development, exceptional circumstances have been demonstrated. 4. Waste management development that would maintain the character of the undeveloped coast, including areas defined as Heritage Coast, will be permitted.15

East Devon Local Plan 2013-2031 The East Devon Local Plan is framed within the context of all the national and county strategies and policies. The Local Plan’s emphasis on conserving and enhancing the environment is reflected in Strategy 47 and Development Management policy EN5.

15 Devon Waste Plan 2011 – 2031, Devon County Council, Dec 2014 Rockbeare NP Strategic Framework page 14

Strategy 47 - Nature Conservation and Geology: (extract) All development proposals will need to: 1. Conserve the biodiversity and geodiversity value of land and buildings and minimise fragmentation of habitats. 2. Maximise opportunities for restoration, enhancement and connection of natural habitats. 3. Incorporate beneficial biodiversity conservation features.

Development proposals that would cause a direct or indirect adverse effect upon internationally and nationally designated sites will not be permitted unless: a) They cannot be located on alternative sites that would cause less or no harm. b) The public benefits of the development clearly outweigh the impacts on the features of the site and the wider network of natural habitats. c) Prevention, mitigation and compensation measures are provided. d) In respect of Internationally designated sites, the integrity of the site will be maintained. Development proposals where the principal objective is to conserve or enhance biodiversity or geodiversity interests will be supported in principle……..

EN5 - Wildlife Habitats and Features: Wherever possible sites supporting important wildlife habitats or features not otherwise protected by policies will be protected from development proposals which would result in the loss of or damage to their nature conservation value, particularly where these form a link between or buffer to designated wildlife sites. Where potential arises positive opportunities for habitat creation will be encouraged through the development process. Where development is permitted on such sites mitigation will be required to reduce the negative impacts and where this is not possible adequate compensatory habitat enhancement or creation schemes will be required and/or measures required to be taken to ensure that the impacts of the development on valued natural features and wildlife have been mitigated to their fullest practical extent.

Flood Risk National Planning Policy Framework 100. Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere. Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards. Local Plans should apply a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change, by:  applying the Sequential Test;  if necessary, applying the Exception Test;  safeguarding land from development that is required for current and future flood management;  using opportunities offered by new development to reduce the causes and impacts of flooding; and

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 where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long-term, seeking opportunities to facilitate the relocation of development, including housing, to more sustainable locations.

National Planning Practice Guidance Guidance > Natural Environment > Flood Risk and Coastal Change 061. The overall approach in paragraph 100 of the National Planning Policy Framework applies to neighbourhood planning. In summary, the qualifying bodies involved in neighbourhood planning should: •seek to ensure neighbourhood plans and neighbourhood development/community right to build orders are informed by an appropriate assessment of flood risk; •ensure policies steer development to areas of lower flood risk as far as possible; •ensure that any development in an area at risk of flooding would be safe, for its lifetime taking account of climate change impacts; •be able to demonstrate how flood risk to and from the plan area/ development site(s) will be managed, so that flood risk will not be increased overall, and that opportunities to reduce flood risk, for example, through the use of sustainable drainage systems, are included in the plan/order. Local planning authorities should have in mind these aims in providing advice or assistance to qualifying bodies involved in neighbourhood planning. Further information on what information and advice should be made available is here [para 062].

062. Local planning authorities’ Strategic Flood Risk Assessments should be the primary source of flood risk information in considering whether particular neighbourhood planning areas may be appropriate for development. Other important sources include the interactive maps of flood risk available on the Environment Agency’s web site. Local planning authorities should make available to qualifying bodies any reports or information relating to the Strategic Flood Risk Assessment, and share any other information relevant to flood risk (such as the application of the Sequential and Exception Tests to the Local Plan). Along with other statutory agencies, the Environment Agency has published advice on neighbourhood planning. Anyone preparing a neighbourhood plan or order may also find it helpful to consult the lead local flood authority for the area.

Environment Agency Rockbeare Parish is covered by the Exe Catchment Flood Management Plan. The extent of the area is shown on the map below.

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As part of the ‘East of Exeter’ sub-area the parish is not considered to be at particular high risk of flooding as a result of climate change. At present, approximately 50 properties in the area (in Broadclyst and Clyst Honiton) are within the 1% annual probability flood extent of the River Clyst. This generally presents a low hazard and a flood embankment in Clyst St Mary provides a 4% standard of protection. We estimate that approximately 90 properties will be in the future 1% flood extent. Fluvial flood risk will remain a relatively low hazard.16 Current Policy Option 4 Policy Option 4 applies i.e. areas of low, moderate or high flood risk where we are already managing the flood risk effectively but where we may need to take further actions to keep pace with climate change. The Management Plan recognises that future flood risk will be largely determined by new development, which consequently must be carefully designed to avoid any long term impacts. The proposed actions to implement the preferred policy include: • Work with developers and the local authority to ensure new development complies with PPS2517 • Complete the Green Infrastructure Study to maximise environmental and recreational use of the floodplain • Influence land use and land management practices in the Clyst catchment, which is relatively shallow and low lying and has the potential to reduce and attenuate peak flows by holding back floodwater

East Devon Strategic Flood Risk Assessment, 2008 The East Devon Strategic Flood Risk Assessment of 2008 still influences the decision-making process. The assessment categorises land according to flood risk as set out below. The flood vulnerability of proposed development, as set out in Appendix D of the East Devon Strategic Flood Risk Assessment (see following pages) is taken into account.

16 Exe Catchment Flood Management Plan, Environment Agency, 2012 https://www.gov.uk/.../Exe_Catchment_Flood_Management_Plan.pdf 17 Planning Policy Statement 25: Development and Flood Risk, which set out Government policy on development and flood risk. Withdrawn in 2014. Rockbeare NP Strategic Framework page 17

Risk of Flooding from River and Sea

Notation = Flood Zone 3 blue; Flood Zone 2 turquoise; Flood Defences pink

Risk of Flooding from Surface Water

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East Devon Local Plan 2013-203 The Local Plan policy EN21 seeks to direct development towards flood zone 1. Policy EN22 addresses the heightened risk of flooding as a result of water-run off from new development. The East Devon Strategic Flood Risk Assessment referred to in policy EN21 can be found online.18

EN21 - River and Coastal Flooding: (extract) A sequential approach will be taken to considering whether new developments, excluding minor developments……… and changes of use, will be permitted in areas subject to river and coastal flooding. Wherever possible developments should be sited in Flood Zone 1 as defined in the East Devon District Council Strategic Flood Risk Assessment106. Only if there is no reasonably available site in Flood Zone 1 will locating the development in Flood Zone 2 and then Flood Zone 3 be considered. The flood vulnerability of proposed development, as set out in Appendix D of the East Devon Strategic Flood Risk Assessment will be taken into account. If, after following this sequential approach, acceptable sites cannot be found and the development is necessary for wider sustainable development reasons, development may be permitted if all of the following criteria are met. 1. It is demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk. 2. The proposed development is on previously developed land that is suitably located and available for development, unless no reasonable alternative sites are available. 3. A flood risk assessment demonstrates that the development will be safe, without increasing flood risk elsewhere and, where possible, will reduce flood risk overall……….

EN22 Surface Run-Off Implications of New Development: Planning permission for new development will require that: 1. The surface water run-off implications of the proposal have been fully considered and found to be acceptable, including implications for coastal erosion. 2. Appropriate remedial measures are included as an integral part of the development, and there are clear arrangements in place for ongoing maintenance over the lifetime of the development. 3. Where remedial measures are required away from the application site, the developer is in a position to secure the implementation of such measures. 4. A Drainage Impact Assessment will be required for all new development with potentially significant surface run off implications. 5. Surface water in all major commercial developments or schemes for 10 homes or more (or any revised threshold set by Government) should be managed by sustainable drainage systems, unless demonstrated to be inappropriate.

18http://eastdevon.gov.uk/planning-libraries/evidence-document-library/chapter8.4-environment/env028- eastdevonstrategicfloodriskassessmentmainreport.pdf

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Agriculture Local Plan Policy EN13 sets out the parameters for development on high grade agricultural land, which is an important factor to consider within the context of housing development in rural areas.

EN13 - Development on High Quality Agricultural Land: The best and most versatile agricultural land (Grades 1, 2 and 3a) will be protected from development not associated with agriculture or forestry. Planning permission for development affecting such land will only be granted exceptionally if there is an overriding need for the development and either: 1. Sufficient land of a lower grade (Grades 3b, 4 and 5) is unavailable or available lower grade land has an environmental value recognised by a statutory wildlife, historic, landscape or archaeological designation and outweighs the agricultural considerations. Or 2. The benefits of the development justify the loss of high quality agricultural land. If best and most versatile land needs to be developed and there is a choice between sites in different grades, land of the lowest grade available must be used except where other sustainability considerations, including intrinsic nature conservation value of a site, outweigh land quality issues.

Green Wedges and Settlement Coalescence The Local Plan expresses an intention to prevent ‘creeping’ development and the consequent coalescence of adjacent or neighbouring settlements, villages or towns. Paragraph .24 of the Local plan stats “to prevent such coalescence, it is important that open land between settlements is retained thus helping them maintain their separate identities, their landscape settings and to avoid the creation of unrelieved development. The areas subject to the policy are defined on the Proposals Map and comprise” It includes: “f) Land separating the villages of Rockbeare and Whimple from the new community site” Making a direct reference to Cranbrook, paragraph 7.26 states “development sites will not lead to settlement coalescence with Broadclyst, Whimple and Rockbeare and by 2031 will accommodate around 8,000 new homes. This level of provision will still allow for extensive open spaces as part of the overall gross development area.”

Strategy 8 - Development in Green Wedges: Within Green Wedges, as defined on the Proposal Map, development will not be permitted if it would add to existing sporadic or isolated development or damage the individual identity of a settlement or could lead to or encourage settlement coalescence.

Green Infrastructure The West End Growth Point Partners have committed to the development of a framework for Green Infrastructure to ensure that there is an accessible network of green spaces, green travel routes, and to ensure that existing natural assets are incorporated into strategic plans. This will be a significant aspect of the master planning exercise.

“This framework could take the form of a number of green projects, to include the planting of historical woodland, improving access across the countryside and at the same time improving the biodiversity for enjoyment and education.”19 This will inevitably impact on the Parish of Rockbeare.

Paragraphs 027-30 relating to Green Infrastructure have been modified or newly added (in February 2016) to the NPPG.

19 http://www.exeterandeastdevon.gov.uk/Green-Infrastructure/ Rockbeare NP Strategic Framework page 20

Paragraph 027 - Green infrastructure is a network of multifunctional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities. Green infrastructure is not simply an alternative description for conventional open space. As a network it includes parks, open spaces, playing fields, woodlands, but also street trees, allotments and private gardens. It can also include streams, canals and other water bodies and features such as green roofs and walls. Green infrastructure is important to the delivery of high quality sustainable development, alongside other forms of infrastructure such as transport, energy, waste and water. Green infrastructure provides multiple benefits, notably ecosystem services, at a range of scales, derived from natural systems and processes, for the individual, for society, the economy and the environment. To ensure that these benefits are delivered, green infrastructure must be well planned, designed and maintained. Green infrastructure should, therefore, be a key consideration in both local plans and planning decisions where relevant. Paragraph 029…….. Local Plans should identify the strategic location of existing and proposed green infrastructure networks. Where appropriate, supplementary planning documents can set out how the planning, design and management components of the green infrastructure strategy for the area will be delivered. This strategic approach to green infrastructure may cross administrative boundaries. Therefore, neighbouring authorities, working collaboratively with other stakeholders including Local Nature Partnerships (LNPs) and Local Enterprise Partnerships (LEPs), may wish to consider how wider strategies for their areas can help address cross- boundary issues and help meet the Duty to Cooperate. Paragraph 030 - Green infrastructure can help to deliver a variety of planning policies including:  Building a strong, competitive economy  Delivering a wide choice of high quality homes  Requiring good design  Promoting healthy communities  Meeting the challenge of climate change, flooding and coastal change  Conserving and enhancing the natural environment20

20 http://planningguidance.communities.gov.uk/revisions/8/ Rockbeare NP Strategic Framework page 21

Built Environment National Planning Policy Framework Regarding Design Matters, Section 7 focuses on policy which seeks to ensure good design. Paragraph 56 of the NPPF states the Government’s intention for the built environment to be required to have good design. “The Government attaches great importance to the design of the built environment. Good design is a key aspect of sustainable development, is indivisible from good planning, and should contribute positively to making places better for people.”21

The paragraph which applies most directly to neighbourhood plans is the following. “Local and neighbourhood plans should develop robust and comprehensive policies that set out the quality of development that will be expected for the area. Such policies should be based on stated objectives for the future of the area and an understanding and evaluation of its defining characteristics. Planning policies and decisions should aim to ensure that developments: • will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development • establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit • optimise the potential of the site to accommodate development, create and sustain an appropriate mix of uses (including incorporation of green and other public space as part of developments) and support local facilities and transport networks • respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation • create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion • are visually attractive as a result of good architecture and appropriate landscaping” 22

The NPPF is also clear that design requirements should not stifle innovation, originality or initiative, nor impose particular architectural styles or tastes. However, it is appropriate to seek to promote or reinforce local distinctiveness.

The NPPF also states the following. “Applicants will be expected to work closely with those directly affected by their proposals to evolve designs that take account of the views of the community. Proposals that can demonstrate this in developing the design of the new development should be looked on more favourably.” 23

The NPPF also has policy relating to advertisements the need for their control to be efficient, effective and simple in concept and operation.

Regarding the historic environment, Section 12 focuses on conserving and enhancing the historic environment. Most of the policy in the NPPF requires specific actions of local planning authorities, although by implication and through reference to planning decisions, much of its content also applies to neighbourhood plans. A number of important sections are reproduced below.

“Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment… including heritage assets most at risk through neglect, decay or other

21 Paragraph 56, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 22 Paragraph 58, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 23 Paragraph 66, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf Rockbeare NP Strategic Framework page 22 threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: • the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation • the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring • the desirability of new development making a positive contribution to local character and distinctiveness • opportunities to draw on the contribution made by the historic environment to the character of a place”24

“When considering the designation of conservation areas, local planning authorities should ensure that an area justifies such status because of its special architectural or historic interest, and that the concept of conservation is not devalued through the designation of areas that lack special interest.” 25 “In determining planning applications, local planning authorities should take account of: • the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation • the positive contribution that conservation of heritage assets can make to sustainable communities including their economic vitality • the desirability of new development making a positive contribution to local character and distinctiveness” 26

“When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be. Significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.” 27

National Planning Practice Guidance The National Planning Practice Guidance28, which amplifies the policies in the NPPF, has a section on design. It sets out why good design is important and focuses on answering the following questions:  What planning objectives can good design help achieve?  What is a well-designed place?  How should buildings and the spaces between them be considered?  Which planning processes and tools can we use to help achieve good design?  Are there design issues that relate to particular types of development?

24 Paragraph 126, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 25 Paragraph 127, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 26 Paragraph 131, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 27 Paragraph 132, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 28 See http://planningguidance.planningportal.gov.uk/blog/guidance/rural-housing/how-should-local-authorities-support-sustainable- rural-communities/ Rockbeare NP Strategic Framework page 23

The NPPG also has a section on conserving and enhancing the historic environment. Two of the sections focus on plan making and decision taking. The former includes a section on ‘How should heritage issues be addressed in neighbourhood plans?’ It states: “Where it is relevant, neighbourhood plans need to include enough information about local heritage to guide decisions and put broader strategic heritage policies from the Local Plan into action at a neighbourhood scale.

Where it is relevant, designated heritage assets within the plan area should be clearly identified at the start of the plan-making process so they can be appropriately taken into account. In addition, and where relevant, neighbourhood plans need to include enough information about local non-designated heritage assets including sites of archaeological interest to guide decisions.

The local planning authority heritage advisers should be able to advise on local heritage issues that should be considered when preparing a neighbourhood plan. The local Historic environment record and any local list will be important sources of information on non-designated heritage assets.”29

English Heritage - Good Practice Advice on Neighbourhood Planning and the Historic Environment Historic England’s website states that “Including heritage matters in a neighbourhood plan will help make sure that potential new development is properly integrated with what is already there and does not result in the loss of local distinctiveness. Addressing how best to integrate new development into an existing place can encourage people to be innovative.

Taking into account what is special about a place often demonstrates that off-the-shelf design and construction might not be appropriate. It encourages sensitive development of historic buildings and places that can invigorate an area, stimulating investment, entrepreneurship, tourism and employment.”30 It provides guidance on heritage and neighbourhood planning which is worth referencing here. The guidance note sets out the benefits of including the historic environment in neighbourhood planning and what information about local heritage should go into a neighbourhood plan.

“Any policies you include in the Neighbourhood Plan should be based on appropriate evidence, and information on how a place has developed and evolved is often a key element. This could include a description of the historic character of the area, as well as identifying any listed buildings, scheduled monuments, conservation areas, registered parks and battlefields or local heritage assets. An assessment of the condition and vulnerability of the local historic environment will also help in identifying the need for any future management action. When deciding on how much information to provide, as a guiding principle, we recommend including as much as is necessary to guide future decisions that may affect the character and heritage of a place. Our guidance on “Knowing Your Place”31 may help you in deciding what information to include in your Plan.”32

The guidance also sets out where information on the historic environment can be found. It also provides guidance on how a community can undertake a local ‘place check’ to help identify the design and heritage issues of importance.33

The guidance sets out the sorts of evidence and policies which could be included in a neighbourhood plan. “It is for the local community to decide on the scope and content of a Neighbourhood Plan. However, there could be benefits in setting out a specific historic environment section within the Plan, drawing on the evidence from

29 Paragraph 007, National Planning Practice Guidance, Department for Communities and Local Government, 2013 http://planningguidance.planningportal.gov.uk/blog/guidance/conserving-and-enhancing-the-historic-environment/plan-making- historic-environment/ 30 See http://www.english-heritage.org.uk/professional/advice/government-planning-policy/national-planning-policy-framework/ 31 See http://www.english-heritage.org.uk/publications/knowing-your-place/ 32 pp.3-4, English Heritage Good Practice Advice on Neighbourhood Planning and the Historic Environment, English Heritage, 2014, https://content.historicengland.org.uk/content/docs/planning/neighbourhood-planning-information-aug14.pdf 33 See http://www.placecheck.info/ Rockbeare NP Strategic Framework page 24

Place check, other sources of information on the historic environment, and/or more detailed assessments where they have been carried out. These could include: • An analysis of the historic character of the area highlighting its contribution to the development and appearance of the place • The identification of any listed buildings, scheduled monuments, registered parks and gardens, and battlefields or local heritage assets, and a discussion of the contribution they make to local character • The environmental issues which the Plan seeks to address • Opportunities to repair, conserve or bring heritage assets back into use, especially those that are at risk • Policies to manage the settings of heritage assets or important views • Policies to promote locally distinctive development in terms of scale and materials • Particular historic environment considerations to be taken into account when seeking to develop specific sites • Opportunities for investment into the historic environment alongside delivery of new development, for example through Neighbourhood Level Community Infrastructure Levy spending, Planning Contributions and other sources of funding The Neighbourhood Plan could also identify any buildings and spaces that are worthy of protection through national designation or local designation, the possibility of new or revised conservation areas together with conservation area appraisals, the need for a local heritage list or local buildings at risk survey.”34

Heritage at Risk Register There are some elements which warrant extra protection through the planning system. Since 1882, when the first Act protecting ancient monuments and archaeological remains was passed, Government has been developing the designation system. Listing is now applied to about half a million buildings ranging from palaces to street lamps.

English Heritage, as the government’s expert adviser, is responsible for making recommendations – but it is still the Secretary of State at the Department for Culture Media and Sport who makes the decisions on whether a site is designated. Understanding and appreciation develop constantly, which makes keeping the designation base up-to-date a never-ending challenge. While responding to threat-driven cases, we also seek to work strategically. Recent developments have seen a greater striving for openness and transparency in the process of designating a site, and better communication of what makes something special.

Conservation areas are designated locally by local planning authorities. They are areas of special architectural or historic interest the character or appearance of which it is desirable to preserve or enhance.

Listed Buildings A listed building is a building (or structure) that has been designated as being of ‘special architectural or historic interest’. The older and rarer a building is, the more likely it is to be listed. Buildings less than 30 years old are listed only if they are of outstanding quality and under threat. Listed buildings are graded I, II* and II. Grade I and II* are particularly important buildings of outstanding interest; together they amount to 8% of all listed buildings. The remaining 92% are of special interest and are listed grade II.

Entries on the statutory list of buildings of special architectural or historic interest may comprise a number of separate buildings. Formal residential terraces are the most obvious example. Entries on this Register reflect how buildings are grouped and recorded on the statutory list. Structures can occasionally be both listed as buildings and scheduled as monuments. Criteria for inclusion on the ‘at Risk Register’

34 pp.7-8, English Heritage Good Practice Advice on Neighbourhood Planning and the Historic Environment, English Heritage, 2014 Rockbeare NP Strategic Framework page 25

Buildings (not in use as a public place of worship) considered for inclusion on the Register must be listed grade I or II*, (or grade II in London) or be a structural scheduled monument. Buildings are assessed for inclusion on the basis of condition and, where applicable, occupancy (or use). The condition of buildings on the Register ranges from ‘very bad’ to ‘poor’, ‘fair’ and (occasionally) ‘good’. The Register also includes buildings that are vulnerable to becoming at risk because they are empty, under-used or face redundancy without a new use to secure their future. Assessing vulnerability in the case of a building in fair condition necessarily involves judgement and discretion. A few buildings on the Register are in good condition, having been repaired or mothballed, but a new use or owner is still to be secured. Buildings are removed from the Register when they are fully repaired/consolidated, their future secured, and where appropriate, occupied or in use.

Conservation Areas East Devon DC has powers to declare an area of special architectural or historic interest, the character or appearance of which it is desirable to conserve or enhance to be a Conservation Area. Such declaration introduces a general control over the demolition of unlisted buildings and provides the basis for policies designed to preserve or enhance all the aspects of character or appearance that define an area's special interest. Apart from a few minor exceptions, no building can be demolished without prior approval (conservation area consent) and six weeks’ notice must be given if any tree is to be cut down or lopped. 33 designated Conservation Areas within East Devon, covering the historic areas of many towns and villages. There is a requirement under Section 71 of the Planning (Listed Building and Conservation Areas) Act 1990 for all local authorities to review their conservation areas and publish proposals for their preservation and enhancement. Reviews must be carried out every five years as the character and appearance of a conservation area can change over even small periods of time.

East Devon Register of Heritage Assets East Devon District Council is in the early stages (at February 2016) of producing a ‘Local List’ of such heritage assets. While the NPPF contains policy on the protection of undesignated heritage assets, local listing provides a sounder, more consistent and accountable means for identification. It also enables the local community to nominate buildings and structures to be included on the Local List. Local listing does not in itself mean the building is covered by any further planning controls it does mean that its conservation as a heritage asset is an objective of the NPPF and a material consideration when determining the outcome of a planning application. It also means it could be made the subject of specific policies in either the Local plan or a Neighbourhood Plan.

East Devon Local Plan 2013-2031 East Devon District Council’s new Local Plan sets the strategic context and statutory development plan strategic policies with which the neighbourhood plan needs to be in ‘general conformity’. The neighbourhood plan is not able to contest an overall scale, broad location or site specific housing allocations deemed as ‘strategic’ in the adopted Local Plan. Other policies deemed as ‘strategic’ and identified in Part 1 of the Local Plan will also need to be used as the policy framework within which the neighbourhood plan is set. These strategic policies can only be amplified or given ‘granularity’ (further detail) in the local context where they provide added value in policy terms. Part 2 of the Local Plan sets out development management policies which can be changed or added to in the local context in the neighbourhood plan where justified by evidence and policies add value (not repeating policy coverage elsewhere). The policies summarised below are those which focus on design and the historic built environment. Apart from the core strategic statements (Strategies 5, 48 and 49) there are a number of development management policies dealing with design and heritage.

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Strategy 5 – Environment: (extract) All development proposals will contribute to the delivery of sustainable development, ensure conservation and enhancement of natural historic and built environmental assets, promote ecosystem services and green infrastructure and geodiversity………

The Local Plan sets out a broad policy in relation to local design distinctiveness. Strategy 48 - Local Distinctiveness in the Built Environment: Local distinctiveness and the importance of local design standards in the development process will be of critical importance to ensure that East Devon's towns and villages retain their intrinsic physical built qualities. Where towns or villages are or have been despoiled we will seek to have qualities reinstated through good design. Use of local materials and local forms and styles will be essential to this distinctiveness. We will work with our partners and local communities to produce Design Statements to guide new development and ensure its appropriateness.

It also has an overarching policy relating to the historic environment. Strategy 49 – The Historic Environment Built Heritage and Building Conservation: The physical and cultural heritage of the district, including archaeological assets and historic landscape character, will be conserved and enhanced and the contribution that historic places make to the economic and social well-being of the population will be recognised, evaluated and promoted. We will work with our partners and local communities to produce or update conservation area appraisals and conservation area management plans.

The Local plan also sets a district strategy for sustainable design and construction.

Strategy 38 - Sustainable Design and Construction: Encouragement is given for proposals for new development and for refurbishment of, conversion or extensions to, existing buildings to demonstrate through a Design and Access Statement how: a) sustainable design and construction methods will be incorporated, specifically, through the re-use of material derived from excavation and demolition, use of renewable energy technology, landform, layout, building orientation, massing, use of local materials and landscaping; b) the development will be resilient to the impacts of climate change; c) potential adverse impacts, such as noise, smell, dust, arising from developments, both during and after construction, are to be mitigated. d) biodiversity improvements are to be incorporated. This could include measures such as integrated bat and owl boxes, native planting or green roofs. Until the adoption of nationally prescribed standards, developments of 10 or more dwellings or 1,000m2 of commercial floor space should be assessed using the CSH or BREEAM, with housing developments meeting at least CSH Level 4 from 2013 and other uses BREEAM of at least ‘Very Good’. Due to their scale, developments in the West End and developments over 4 ha or 200 dwellings elsewhere in East Devon should achieve levels of sustainability in advance of those set out nationally. The Council will wish to see homes built to Code for Sustainable Homes Level 4 and this will be a material consideration. Proposals for water harvesting and sustainable waste management will be encouraged. In building refurbishments, the Council will encourage and promote the integration of renewable energy into existing buildings.

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Part 2 of the Local Plan contains development management policies which relate specifically to development proposals which come forward during the period of the Plan.

D1 - Design and Local Distinctiveness: In order to ensure that new development, including the refurbishment of existing buildings to include renewable energy, is of a high quality design and locally distinctive, a formal Design and Access Statement should accompany applications setting out the design principles to be adopted should accompany proposals for new development. Proposals should have regard to Village and Design Statements and other local policy proposals, including Neighbourhood Plans, whether adopted as Supplementary Planning Guidance or promoted through other means. Proposals will only be permitted where they: 1. Respect the key characteristics and special qualities of the area in which the development is proposed. 2. Ensure that the scale, massing, density, height, fenestration and materials of buildings relate well to their context. 3. Do not adversely affect: a) The distinctive historic or architectural character of the area. b) The urban form, in terms of significant street patterns, groups of buildings and open spaces. c) Important landscape characteristics, prominent topographical features and important ecological features. d) Trees worthy of retention. e) The amenity of occupiers of adjoining residential properties. f) The amenity of occupants of proposed future residential properties, with respect to access to open space, storage space for bins and bicycles and prams and other uses; these considerations can be especially important in respect of proposals for conversions into flats. 4. Have due regard for important aspects of detail and quality and should incorporate: a) Secure and attractive layouts with safe and convenient access for the whole community, including disabled users. b) Measures to create a safe environment for the community and reduce the potential for crime. c) Use of appropriate building materials and techniques respecting local tradition and vernacular styles as well as, where possible, contributing to low embodied energy and CO2 reduction. d) Necessary and appropriate street lighting and furniture and, subject to negotiation with developers, public art integral to the design. e) Features that maintain good levels of daylight and sunlight into and between buildings to minimise the need for powered lighting. f) Appropriate ‘greening’ measures relating to landscaping and planting, open space provision and permeability of hard surfaces. 5. Incorporate measures to reduce carbon emissions and minimise the risks associated with climate change. Measures to secure management of waste in accordance with the waste hierarchy (reduce, reuse, recycle, recovery, disposal) should also feature in proposals during the construction and operational phases. 6. Green Infrastructure and open spaces should be designed and located in a way that will minimise any potential security concerns for users. 7. Mitigate potential adverse impacts, such as noise, smell, dust, arising from developments, both during and after construction.

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D8 – Re-use of Rural Buildings Outside of Settlements: (extract) The re-use or conversion of buildings in the countryside outside of Built-up Area Boundaries will be permitted where: 1. The new use is sympathetic to, and will enhance the rural setting and character of the building and surrounding area and is in a location which will not substantively add to the need to travel by car or lead to a dispersal of activity or uses on such a scale as to prejudice village vitality. 2. The building is structurally sound and capable of conversion without the need for substantial extension, alteration or reconstruction and any alterations protect or enhance the character of the building and its setting; 3. The form, bulk and general design of the building and its proposed conversion are in keeping with its surroundings, local building styles and materials; …………..

Development management policies which focus on the historic built environment are set out in chapter 22, ‘The Natural and Historic Environment’.

EN6 - Nationally and Locally Important Archaeological Sites: Development that would harm nationally important archaeological remains or their settings, whether scheduled or not, including milestones and parish stones, will not be permitted. Development that would harm locally important archaeological remains or their settings will only be permitted where the need for the development outweighs the damage to the archaeological interest of the site and its setting. There is a presumption in favour of preservation in situ in the case of nationally and locally important remains. Preservation of locally important remains by record will be required where the need for the development outweighs the need to preserve the remains in situ.

EN7 - Proposals Affecting Sites which may potentially be of Archaeological Importance: When considering development proposals which affect sites that are considered to potentially have remains of archaeological importance, the District Council will not grant planning permission until an appropriate desk based assessment and, where necessary, a field assessment has been undertaken.

EN8 - Extension, Alteration or Change of Use of Buildings of Special Architectural and Historic Interest: (extract) When considering development proposals, the significance of any heritage assets and their settings, should first be established by the applicant through a proportionate but systematic assessment ……. to understand the potential impact of the proposal on the significance of the asset. This policy applies to both designated and non-designated heritage assets, including any identified on the East Devon local list.

EN9 - Development Affecting a Designated Heritage Asset or Loss of a Building or Structure that makes a Positive Contribution to a Conservation Area: (extract) The Council will not grant permission for developments involving substantial harm or total loss of significance of a designated heritage asset unless it can be demonstrated that it is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following apply: a) the nature of the heritage asset prevents all reasonable uses of the site. b) no viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation. c) conservation by grant-funding or some form of charitable or public ownership is demonstrably not possible. d) the harm or loss is outweighed by the benefit of bringing the site back into use.

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Substantial harm to or loss of a grade ll listed building, park or garden should be exceptional. Substantial harm to of loss of designated heritage assets of the highest significance should be wholly exceptional. Where total or partial loss of a heritage asset is to be permitted the Council may require that: e) A scheme for the phased demolition and redevelopment of the site providing for its management and treatment in the interim is submitted to and approved by the Council……. f) Where practicable the heritage asset is dismantled and rebuilt or removed to a site previously approved. g) Important features of the heritage asset are salvaged and re-used. h) There is an opportunity for the appearance, plan and particular features of the heritage asset to be measured and recorded. i) Provision is made for archaeological investigation by qualified persons and excavation of the site where appropriate. Where a development proposal would lead to less than substantial harm to the significance of a designated heritage asset, the harm will be weighed against the public benefits of the proposal, including securing its optimum viable use. Favourable consideration will be given for new development within the setting of heritage assets that enhance or better reveal the significance of the asset, subject to compliance with other development plan policies and material considerations.

EN10 - Conservation Areas: Proposals for development, including alterations, extensions and changes of use, or the display of advertisements within a Conservation Area, or outside the area, but which would affect its setting or views in or out of the area, will only be permitted where it would preserve or enhance the appearance and character of the area. Favourable consideration will be given to proposals for new development within conservation areas that enhance or better reveal the significance of the asset, subject to compliance with other development plan policies and material considerations. Loss of a building or other structure that makes a positive contribution to the significance of a Conservation Area will be considered against the criteria set out in Policy EN9.

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Cranbrook and the Exeter Growth Point The proximity of the Rockbeare Neighbourhood Plan Area to a number of major development projects makes it necessary to understand the nature of these projects and the potential impact they may have on the Parish.

The major developments at East Devon’s West end are all listed in Strategy 9 of the new Local Plan. The approved development plans for each of the major development projects must be considered as part of the strategic context in which the neighbourhood plan for Rockbeare has to be prepared.

Strategy 9 - Major Development at East Devon’s West End: (extract) High quality development with associated infrastructure, built within a high quality landscape setting, will be provided in East Devon's West End. The overarching strategy for development will need to dovetail with the development strategy for Exeter with the provision of homes close to jobs and other facilities and services. High quality walking and cycling connections; enhanced bus and rail services, and improved highway provision will be integral to the overall development Within the West End of East Devon the following schemes will be provided: 1. Cranbrook - Major new East Devon market town; 2. Pinhoe - Mixed use, residential led development; 3. North of Blackhorse/Redhayes (Tithebarn Green/Mosshayne) – residential development; 4. Skypark - Substantial high quality business park; 5. Exeter Science Park - Research/technology employment site; 6. Exeter International Airport - ……… airport-related employment uses within operational site area. 7. Multi-modal Interchange - Facility for interchange of goods and distribution centre; and 8. Exeter Airport Business Park - Middle range business park providing for medium to smaller business uses. The major developments at East Devon’s West End and the Clyst Valley Regional Park proposals are identified on the Proposals Map (West End inset map). Funding contributions will be sought from all developments in the West End to secure implementation of integrated transport and infrastructure provision.

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Development Projects The following major projects are all in the vicinity and in course of development:

Cranbrook Cranbrook is the first new stand -alone settlement in Devon since the Middle Ages. Development started on site in June 2011 and the first new homes were completed in May 2012.

According to East Devon District Council’s website (at December 2015) “currently, a total of 3,561 homes, two primary schools, a secondary school, town centre, local centre and associated infrastructure and green spaces have planning permission but there are plans for a further 4,370 homes and associated infrastructure set out in the New Local Plan meaning that the town is planned to grow to a total of nearly 8,000 homes by the year 2031. This is expected to equate to a town almost the size of Barnstaple.

Cranbrook is planned to be a sustainable settlement by reducing energy consumption and minimising carbon emissions. These aspirations are being met by delivering sustainable transport options (such as a brand new train station on the Exeter-Waterloo mainline, cycle routes and bus services) and a Combined Heat and Power (CHP) District Heating Scheme early in the development as well as high sustainability credentials in building specifications.

Cranbrook is planned in the context of significant growth within the "West End" of East Devon and on the eastern edge of Exeter. This means that Cranbrook will be in close proximity to the employment developments of Skypark, Science Park, the Inter-Modal Freight Facility and Exeter Airport as well as linked to Exeter by rail, good quality cycle routes and bus and to the surrounding countryside and the new Clyst Valley Regional Park through a network of footpaths and cycleways. The Local Plan West End Inset Map provides a good overview of the developments that are planned.”

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Strategy 12 - Development at Cranbrook: (extract) Land at Cranbrook …..is allocated for development and will be developed as a modern market town. Mixed use development, to provide housing (including affordable housing) social and community facilities, recreation and education facilities and jobs will occur on a phased basis. The town will be built to distinctive high quality design standards incorporating the best in environmentally friendly technology. Open spaces and facilities will be readily accessible to all residents with convenient and attractive pedestrian and cycle links to local destinations and access to high quality public transport services. Working with our partners we will promote Cranbrook, up to 2031 to accommodate: 1. New Homes - Around 6,300 new homes on allocated land - which will be required to be of the highest standards in terms of energy and resource efficiency, quality of design and access to services and facilities. At peak build rates 500 new homes a year could be built at Cranbrook. 2. Gypsy and Traveller Provision - provision will be made for new gypsy and traveller sites 3. Jobs - provision of up to 18.4 hectares of employment land shall be made throughout the town to provide a range of business spaces suitable for the needs of businesses as they develop and grow and to accommodate a range of employment opportunities for residents of Cranbrook and surrounding areas. Serviced or otherwise available land should be available for occupation by employment uses on a phased based that is directly proportionate to house building: • 4. 5 hectares at/before 2,500 homes are occupied; • 9 hectares at/before 5,000 homes are occupied; • 13.5 hectares at/before 7,500 homes are occupied; • The remainder after 7,500 homes. Monitoring of take up of employment land and jobs provided will allow for future policy adjustment. Nearby West End employment sites will also provide jobs for Cranbrook residents and some will travel to other locations for work purposes including Exeter City. 4. Town Centre - The town centre of Cranbrook will provide a focal point for retail, business and leisure activities and will be designed to create a vibrant day and night-time economy and this will be complemented by a series of smaller neighbourhood centres. 5. Social and Community and Education Facilities - Cranbrook will accommodate a full range of social, leisure, health, community and education facilities (including new schools) to meet the needs of all age groups that will live at the new town. 6. Infrastructure - The existing district heating system will provide for the combined heat and power needs of the town. The Council will produce an Infrastructure Delivery Plan that will set out key requirements recognising the need for improved transport links and road improvements as Cranbrook grows as well as improved education provision, high speed broadband and other services and facilities to ensure sustainable development is delivered at Cranbrook. Developments at Cranbrook shall be developed in a phased and co-ordinated manner alongside the required infrastructure and in accordance with parameter plans that will form part of a plan for Cranbrook which will be developed in partnership with the developers and the community as a Development Plan Document. The Cranbrook Plan area also identifies land for the further expansion/intensification of Cranbrook to accommodate a further 1,550 houses and associated jobs, social, community and education facilities and infrastructure outside the designated Neighbourhood Plan Areas of Rockbeare, Broadclyst and Clyst Honiton.

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Future development of Cranbrook is to be subject to a master-planning exercise, which will lead not only to a Master Plan but to a Development Plan Document (DPD). The last progress and position statement on the Cranbrook Plan was reported to East Devon District Council on the 16th June 2105. “Revised Local Plan wording provides for the future development of Cranbrook through intensification of existing land allocations and/or development of additional land. Development will be in the Local Plan proposed Cranbrook Plan Area. 1.2 The Cranbrook Plan is a master planning exercise that was commissioned by the Council in 2014. The master plan will set out, amongst other matters, the proposed form and nature of future Cranbrook development and land areas appropriate for future development. It is important to recognise, however, that the Masterplan itself, is not directly a Development Plan Document. It …..will need to be ‘translated’ into a formal document and run through various further stages of work to attain this status, most notably: a) formal consultation under the plan making regulations b) submission for examination c) examination by a planning inspector, possibly to include oral hearing sessions, to consider plan content and any objections d) responding to recommendations made by the planning inspector The key benefit of the master plan work being ‘translated’ into a formal Development Plan Document is that with this formal status it will carry far more weight in the decision making process.”

The scoping study for the Master plan exercise35 identified the following sustainability issues that would need to be addressed as part of the exercise:  There are no designated biodiversity sites very close proximity of Cranbrook, although the East Devon Pebblebed Heaths Special Area of Conservation (SAC) and East Devon Heaths Special Protection Area (SPA) are approximately 3.5 km to the south east  Cranbrook lies in the ‘lowland plains’ landscape character type, as identified in the East Devon Landscape Character Assessment.  Most of Cranbrook lies outside of high flood risk zones, although there are areas of flood zones 2 and 3 which extend within the area that is allocated in the emerging East Devon Local Plan, across the northern boundary and through the centre of the area.  Much of the Cranbrook development area is within Grade 3 agricultural land, although it is not known if this is Grade 3a or 3b. The northern part of the site is within Grade 4 agricultural land.  Rockbeare Manor Registered Park and Garden is located approximately 500m to the south east of Cranbrook and there are a number of listed buildings within and around the development area.  There are no Air Quality Management Areas within or near to Cranbrook  The proximity of Exeter Airport to the south of Cranbrook means that noise could potentially be a concern, as well as other possible impacts associated with airport operation. Specific Cranbrook area issues were summarised as follows:  The need to ensure that large-scale new development is appropriately integrated into the landscape, respecting and enhancing local character where possible.  The need to protect biodiversity (in particular the Exe Estuary SPA and East Devon Pebblebed Heaths SAC) from the impacts of large-scale development in the area, in particular increased recreation pressure. • High flood risk in some parts of the development area.  The need to conserve and enhance the setting of listed buildings and other heritage features.  The need to avoid high levels of car use by balancing residential development with an appropriate range of employment opportunities, services and facilities.

35 SA/SEA Scoping Letter for the Cranbrook Plan DPD, Land Use Consultants, September 2015 Rockbeare NP Strategic Framework page 34

Sky Park Business Park The site was formerly run by Devon County Council as part of Exeter Airport. In 2008, the Council concluded that a Corporate Joint Venture with a private sector partner was required to drive forward the development of the 1.4 million sq ft Skypark Business Park comprising of office and industrial/manufacturing space.

“The intention for Skypark is to redevelop a 100 acre disused site into a sustainable Business Park, which will accommodate more than 1.4 million sq.ft of office, industrial and manufacturing space when complete. Working closely with joint venture partners, St. Modwen will seek to realise the full economic potential of Exeter as a major regional centre by providing regional and national occupiers with access to high quality employment space which will create around 6,500 jobs over the course of the Business Park's development.”36 Size: Landscaped environment of approximately 100 acres Expected date of completion: 15-20 year project Job creation: 6,500 jobs Current land owners: St. Modwen

Exeter International Airport The Airport’s growth ambitions have been established for some long time. They are set out in an approved Master Plan of 201037, which include the following list of developments: Schedule of Works 2008 – 2015 Passenger Facilities • Terminal Development Phase 1 (Terminal increased to 12,000m2) • Additional long term car parking • Relocation of Car Park 4

36 http://www.exeterandeastdevon.gov.uk/skypark-business-park/ 37 http://www.exeter-airport.co.uk/masterplan Rockbeare NP Strategic Framework page 35

• New Passenger Transport Interchange & Internal Road System • Hotel Operational Infrastructure • Runway pavement before threshold • New aircraft stands & associated taxi-ways to the east of the terminal • Construction of parallel taxiway – Phase 1 • Additional aircraft stands to the north of the runway • New stands and buildings for General Aviation north-side • Resurfacing & strengthening of the runway • Fire Station relocation • Fuel Farm relocation and extended • New Compass Swing Bay • Service utility improvements • Royal Mail operations moved north of the runway • Relocated Engine Test facility Flybe • Development of Flybe Academy • Additional hangars for aircraft maintenance

Schedule of Works 2015 – 2030 Passenger Facilities • Terminal Development Phase 2 (Terminal increased to 15,000m2) • Terminal Development Phase 3 (Terminal increased to 18,000m2) • Reconfigured short term car park • Additional long term car parking Operational Infrastructure • New aircraft stands and associated taxi-ways to the south of the runway • Construction of parallel taxiway – Phase 2 • Runway holding loop • Remote aircraft stands to the north of the runway • Service Utility improvements Flybe • Additional hangars for aircraft maintenance

The need to acquire further land was recognised in the master plan. In 2012 an addendum was published which seemed to temper ambition as far as the speed of growth was concerned, to “global and national events have conspired to frustrate that growth within the aviation industry and the wider economy”, however expansion and growth was still the thrust of the addendum. “The Airport has worked closely with EDDC in recent years to bring forward a strategic Master Plan and the Airport is also a key part of the Sky Park business park proposals which will bring forward high quality office and other development which will enjoy the benefits of being at the Airport. Furthermore, the Airport has been closely involved with the Growth Point in the West End, being a member of the Exeter & East Devon Growth Point Steering Board and helping to facilitate major proposals such as the Science Park, the Clyst Honiton Bypass and the Cranbrook New Community. Whilst airport operational and airport related development land is essential to enable the growth of the Airport, as described in the adopted Master Plan, the establishment of land for economic development within the zones will be essential to enable funds, secured from such developments, to be available to the Airport to improve road and utility infrastructure around the estate.”38

38 www.exeter-airport.co.uk/masterplanaddendum Rockbeare NP Strategic Framework page 36

The addendum confirmed that Exeter Airport had secured control of approximately 33 hectare of land to the south east of the Airport to safeguard its medium and long term operational requirements, and those of Flybe as shown overleaf:

Of the 33 hectares, approximately 4 hectares has already been developed as the Flybe Academy and Airport Hotel. An exercise to determine the additional land needed for airport operational development and airport related development has been carried out and this has concluded that of the remaining c. 29 hectares: around 14 ha are required for operational and airport related development; and around 15 ha are available as land for other economic development.

The latest proposals for the northern zone of the airport include the following facilities within the Northern Development Zone, all of which will be either airport operational or airport related development: • Up to 1,000 overflow long-term car parking spaces • Relocated primary radar and other uses • Engine test stand • Compass swing • Royal Mail sortation and screening • Devon & Cornwall Police Air Support Unit • Devon Air Ambulance Trust • Joint Fire Training Ground • Relocated primary radar • Engine test stand • Compass Swing • Flying schools • Aviation workshops and servicing facilities • General Aviation parking and facilities • Executive Aviation • Hangars for GA and Flying clubs • New aviation SMEs • Fuel storage • Flood attenuation

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• Waste water treatment works “The pace of development of the Northern Development Zone, which is all within the existing airport operational boundary, will depend on user demand and terminal development to the south. Additionally, some flexibility will be required as a result of the timing of different demands, the integration with Sky Park and the possible demand for a large aircraft engineering facility.”

Flybe Training Academy Flybe has built a state of the art training academy for the benefit of its staff. The £24 million training academy includes 26 classrooms, Flight Simulators and Cabin Crew door trainers, thereby creating an international training facility for the airline industry. Training in areas such as customer service are also available for non- aviation related companies. The training academy will also benefit from a new 4 star, 160-bedroom hotel which will be built alongside the site.

Strategy 17 - Future Development at or near Exeter International Airport: The Local Plan recognises the importance of airport expansion and encourages supporting infrastructure to provide for its direct airport related growth. It is recognised that many operational uses do not require planning permission and these developments, where compatible with safe and efficient airport operation and where they do not have adverse impacts on land within operational boundaries, will be supported. The Habitats Regulations require the Appropriate Assessment of any project where the likelihood of significant effects on European wildlife sites cannot be ruled out Developments that are near to or could be affected by noise from the airport will not be allowed unless evidence is provided that current or futures users or occupiers of new dwellings, schools, open spaces or other sensitive uses will not be significantly adversely affected, taking proposed mitigations into account, by airport related noise.

Strategy 18 - Future Development of Exeter Airport Business Park: To enable modest expansion of the Exeter Airport Business Park 5 hectares of additional land (over and above the Training Academy and hotel site) is allocated, for business/employment generating uses as shown on the Proposals Map. Highway improvements will be required in order to access this site and also to enhance general airport access.

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Exeter Gateway Inter-Modal Interchange The long-term vision for this project is to provide a rail road interchange for bulk transport of containers. There is also scope for integrated rail, road and air transport. Conditions within the approved planning application require the provision of a rail bulk head on the Exeter to Waterloo railway line before the completion of phase one of the development. The buildings are likely to comprise of warehousing suitable for handling the storage of containers and the take up of floor space is likely to be for transport logistic centres or single use distribution centres. For example, food retailing. Location: land at Hayes Farm Size of Site (in hectares): 65 Ha Phase One: The site, also known as the Exeter Gateway, already has planning permission for a distribution warehouse of 50,000 m². After carrying out extensive site preparation works Sainsbury’s put its plans for a depot on hold in 2013. It has now agreed a deal with Lidl who will acquire the site in East Devon, and bring forward plans for a new distribution centre. Job creation: The site has the potential, it is estimated, to create around 500 jobs Current land owners: The Church Commissioners for England

Strategy 15 - Intermodal Interchange: Land is allocated on the Proposals Map for an Intermodal Interchange Facility alongside the Exeter- Waterloo Railway Line.

An efficient and sustainable transport strategy is a key feature of the proposals for the West End (see Strategy 11 overleaf).

Alongside the development strategy for the West End there is also a clear statement of regard for the open environment. Strategy 10 is the key policy statement with this regard.

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Strategy 11 - Integrated Transport and Infrastructure Provision at East Devon's West End: We will promote high quality and integrated transport provision at East Devon's West End where, working with partner organisations, we will secure a provision based on a hierarchy of; 1. Walking 2. Cycling 3. Frequent and high quality public transport provision (given priority over other road users) 4. Private motor vehicles. Though transport solutions will take into account site specific needs of a development to secure the most suitable form of sustainable transport provision. Coordinated infrastructure provision will be required to cover: 1. Low carbon heat and power supply; 2. waste management facilities and waste water treatment; 3. Highest quality data service infrastructure provision, especially broadband connections; 4. Health and education provision.

Strategy 10 - Green Infrastructure in East Devon's West End: (extract) We will ensure that the Green Infrastructure Strategy for East Devon's West End dovetails with comparable work being undertaken in Exeter to provide a green framework within which strategic development occurs. All development proposals of the West End will individually and collectively contribute to the implementation and long-term management of green infrastructure initiatives through appropriate contributions and/or on site provision, and Green Infrastructure initiatives should feature in all developments. Clyst Valley Regional Park Land to accommodate the Clyst Valley Regional Park is allocated on the Proposals Map. Developer contributions, the Community Infrastructure Levy and other agricultural-environmental funding streams will be used in combination to deliver this ‘landscape’ scale strategic project. Landowner, developer and multi-agency collaboration will be essential to achieve the broad range of outcomes intended for this area to ensure the planned growth is delivered sustainably over the plan period. …………….

Habitat Regulations and West End Development Where the likelihood of significant effects on European wildlife sites cannot be ruled out from developments in the West End, the Council will undertake an appropriate assessment of impacts and will only support and approve proposals where it can be demonstrated that adverse effects on site integrity can be prevented. Of particular relevance to the Habitat Regulations will be the need for continued checks and monitoring to ensure that any mitigation measures for built development, linked to Clyst Valley Regional Park provision, achieve the ends envisaged and offers effective mitigation against adverse impacts that could otherwise occur. Each phase of any development occurring and park provision will be assessed and monitored. Mitigation measures in respect of the West End established as needed to comply with Habitat Regulation assessment will need to accord with measures set out in the ‘South-east Devon European Site Mitigation Strategy’. Provision of SANGS will be an essential part of the overall West End development. Where possible SANGS should dovetail with wider Green Infrastructure policies and be compatible with neighbouring authorities’ plans. The functionality of any potential SANGS and its contribution to the avoidance of a likely significant effect must be clearly demonstrated.

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Housing National Planning Policy Framework It is important to understand the framework provided to ensure that local planning authorities establish policies and practices that will ensure provision of adequate numbers of appropriate new dwellings in their district. Paragraph 184 recognises that neighbourhood plans also have a role to play. “Neighbourhood planning provides a powerful set of tools for local people to ensure that they get the right types of development for their community. The ambition of the neighbourhood should be aligned with the strategic needs and priorities of the wider local area. Neighbourhood plans must be in general conformity with the strategic policies of the Local Plan. To facilitate this, local planning authorities should set out clearly their strategic policies for the area and ensure that an up-to-date Local Plan is in place as quickly as possible. Neighbourhood plans should reflect these policies and neighbourhoods should plan positively to support them. Neighbourhood plans and orders should not promote less development than set out in the Local Plan or undermine its strategic policies.”39

Section 6 of the NPPF focuses on policy which seeks to deliver a wide choice of high quality homes. Much of the policy is directed towards provisions local planning authorities should make through their plans and the decision making process for planning applications. It includes requirements to boost the supply of housing through an understanding of market and affordable housing needs in the housing market area, identify a five-year housing land supply of deliverable sites, identify developable sites or broad locations for growth for a further 10 years, understand the expected rate of housing delivery and set out appropriate housing densities for the locality.

Importantly, paragraph 49 states that “Housing applications should be considered in the context of the presumption in favour of sustainable development. Relevant policies for the supply of housing should not be considered up-to-date if the local planning authority cannot demonstrate a five-year supply of deliverable housing sites.”40

Paragraphs 54 and 55 relate to housing in rural areas. They state that: “In rural areas, exercising the duty to cooperate with neighbouring authorities, local planning authorities should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs.”41

“To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. For example, where there are groups of smaller settlements, development in one village may support services in a village nearby. Local planning authorities should avoid new isolated homes in the countryside unless there are special circumstances such as:  the essential need for a rural worker to live permanently at or near their place of work in the countryside; or  where such development would represent the optimal viable use of a heritage asset or would be appropriate enabling development to secure the future of heritage assets; or  where the development would re-use redundant or disused buildings and lead to an enhancement to the immediate setting; or  the exceptional quality or innovative nature of the design of the dwelling. Such a design should: –– be truly outstanding or innovative, helping to raise standards of design more generally in rural areas; –– reflect the highest standards in architecture;

39 Paragraph 184, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 40 Paragraph 49, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 41 Paragraph 54, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf Rockbeare NP Strategic Framework page 41

–– significantly enhance its immediate setting; and, –– be sensitive to the defining characteristics of the local area.”42

Another key principle of the NPPF relates strongly to housing development, “Requiring Good Design”. Paragraph 58 encourages neighbourhood plans to plan positively for the achievement of high quality and inclusive design for all development (not just housing). “Local and neighbourhood plans should develop robust and comprehensive policies that set out the quality of development that will be expected for the area. Such policies should be based on stated objectives for the future of the area and an understanding and evaluation of its defining characteristics. Planning policies and decisions should aim to ensure that developments:  will function well and add to the overall quality of the area, not just for the short term but over the lifetime of the development;  establish a strong sense of place, using streetscapes and buildings to create attractive and comfortable places to live, work and visit;  optimise the potential of the site to accommodate development, create and sustain an appropriate mix of uses (including incorporation of green and other public space as part of developments) and support local facilities and transport networks;  respond to local character and history, and reflect the identity of local surroundings and materials, while not preventing or discouraging appropriate innovation;  create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion; and  are visually attractive as a result of good architecture and appropriate landscaping.”43

National Planning Practice Guidance The National Planning Practice Guidance44, which amplifies the policies in the NPPF, has a section on how local authorities should support sustainable rural housing and communities and is worth noting the guidance it offers on housing provision:  “It is important to recognise the particular issues facing rural areas in terms of housing supply and affordability, and the role of housing in supporting the broader sustainability of villages and smaller settlements.  Assessing housing need and allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process. However, all settlements can play a role in delivering sustainable development in rural areas – and so blanket policies restricting housing development in some settlements and preventing other settlements from expanding should be avoided unless their use can be supported by robust evidence.”

It is particularly important to note the line “…allocating sites should be considered at a strategic level and through the Local Plan and/or neighbourhood plan process.” in the context of considering whether or not a neighbourhood plan should allocate housing sites for development or not. (The term ‘allocation’ refers to development sites which are set out on a map with boundaries to the site and which define exactly where development will take place. Allocating sites does not mean that no other development will come forward on other sites.) As already set out above, a neighbourhood plan cannot determine or deal with housing sites deemed by the local authority as being ‘strategic’ in nature, usually large scale developments, but which can also be sites deemed to be of critical importance to the delivery of the overall scale of housing identified in the Local Plan. Smaller, non-strategic (or ‘local’), sites can be allocated in the neighbourhood plan, although they do not have to be.

42 Paragraph 55, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 43 National Planning Policy Framework (DCLG), paragraph 58, page 15 44 See http://planningguidance.planningportal.gov.uk/blog/guidance/rural-housing/how-should-local-authorities-support-sustainable- rural-communities/ Rockbeare NP Strategic Framework page 42

Clearly, local consultation will play a role in determining the approach to housing sites. However, there are also other factors which are worth identifying in order to frame a debate on whether or not the neighbourhood plan allocates housing sites.

So, in summary, there are a number of options to deal with housing delivery: A. Allow the local authority to lead the process of allocation, but also introduce local criteria based policies in the neighbourhood plan to guide design, layout, density, steer away from inappropriate locations for development, etc.; or B. Allocate housing sites through the neighbourhood plan, and also introduce local criteria based policies in the neighbourhood plan to guide design, layout, density, steer away from inappropriate locations for development, etc.; or C. leave delivery solely to the market, but also introduce local criteria based policies in the neighbourhood plan to guide design, layout, density, steer away from inappropriate locations for development, etc

East Devon Local Plan 2013-2031 The neighbourhood plan is not able to contest overall scale, broad location or site specific housing allocations deemed as ‘strategic’ in the adopted Local Plan.

Local Plan ‘Strategy 2’ sets out the scale and distribution of development.

Strategy 2 - Scale and Distribution of Residential Development: Future development in the 2013 to 2031 period will be accommodated in accordance with the pattern of distribution tabled below with specific allocations detailed in the highlighted columns. (Please note that the following is a snapshot in time based on monitoring to a base date of 30 September 2014.)

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Strategy 4 sets out important context for housing development, dealing with the development of balanced communities.

Strategy 4 - Balanced Communities: By balanced communities we mean that in any area or neighbourhood there is a match between jobs, homes, education, and social and community facilities. Ideally these should complement the range of ages of the resident population and have appropriate access for those with disabilities. Key components of a balanced community include: a) Securing employment provision across East Devon - this should reduce the need for commuting - where housing is proposed we will require new job provision. b) Securing social, educational, green infrastructure and health and community facilities - these facilities play a central part in community life and new housing should help secure their provision and keep the community vibrant and viable by making financial contributions towards their provision or by providing such facilities on site where necessary. c) Getting more age-balanced communities - many East Devon communities have an overtly aged population profile. Where this is the case we will encourage residential development that will be suited to or provide for younger people and younger families.

The parish of Rockbeare has not been identified in the Local Plan as a focus for growth and development. It is adjacent however to major growth areas, in particular Cranbrook. For this reason, it is important to understand the relevant Local Plan policy and its implications. The following strategic housing policies have been identified as having some relevance:

Strategy 9 - Major Development at East Devon’s West End: High quality development with associated infrastructure, built within a high quality landscape setting, will be provided in East Devon's West End. The overarching strategy for development will need to dovetail with the development strategy for Exeter with the provision of homes close to jobs and other facilities and services. High quality walking and cycling connections; enhanced bus and rail services, and improved highway provision will be integral to the overall development Within the West End of East Devon the following schemes will be provided: 1. Cranbrook - Major new East Devon market town; 2. Pinhoe - Mixed use, residential led development; 3. North of Blackhorse/Redhayes (Tithebarn Green/Mosshayne) – residential development; 4. Skypark - Substantial high quality business park; 5. Exeter Science Park - Research/technology employment site; 6. Exeter International Airport - Provision to be made for airport-related employment uses within operational site area. 7. Multi-modal Interchange - Facility for interchange of goods and distribution centre; and 8. Exeter Airport Business Park - Middle range business park providing for medium to smaller business uses. The major developments at East Devon’s West End and the Clyst Valley Regional Park proposals are identified on the Proposals Map (West End inset map). Funding contributions will be sought from all developments in the West End to secure implementation of integrated transport and infrastructure provision.

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Strategy 12 - Development at Cranbrook: (extract) Land at Cranbrook shown on the proposals Map is allocated for development and will be developed as a modern market town. Mixed use development, to provide housing (including affordable housing) social and community facilities, recreation and education facilities and jobs will occur on a phased basis. The town will be built to distinctive high quality design standards incorporating the best in environmentally friendly technology. Open spaces and facilities will be readily accessible to all residents with convenient and attractive pedestrian and cycle links to local destinations and access to high quality public transport services. Working with our partners we will promote Cranbrook, up to 2031 to accommodate: 1. New Homes - Around 6,300 new homes on allocated land - which will be required to be of the highest standards in terms of energy and resource efficiency, quality of design and access to services and facilities. At peak build rates 500 new homes a year could be built at Cranbrook. 2. Gypsy and Traveller Provision - provision will be made for new gypsy and traveller sites. Developments at Cranbrook shall be developed in a phased and co-ordinated manner alongside the required infrastructure and in accordance with parameter plans that will form part of a plan for Cranbrook which will be developed in partnership with the developers and the community as a Development Plan Document. The Cranbrook Plan area also identifies land for the further expansion/intensification of Cranbrook to accommodate a further 1,550 houses and associated jobs, social, community and education facilities and infrastructure outside the designated Neighbourhood Plan Areas of Rockbeare, Broadclyst and Clyst Honiton.

‘Strategy 6’ is of particular relevance to neighbourhood plans as it deals with the issue of built-up area boundaries, which, for some villages sets out the boundary within which development is acceptable. However, the policy introduces a caveat giving flexibility to neighbourhood plans to better define the boundary where justified. ‘Strategy 7’ is equally important, dealing with development outside of built-up area boundaries in the countryside.

Strategy 6 - Development within Built-Up Area Boundaries: Built-up Area Boundaries are defined on the Proposals Map around the settlements of East Devon that are considered appropriate through strategic policy to accommodate growth and development. Within the boundaries development will be permitted if: 1. It would be compatible with the character of the site and its surroundings and in villages with the rural character of the settlement. 2. It would not lead to unacceptable pressure on services and would not adversely affect risk of flooding or coastal erosion. 3. It would not damage, and where practical, it will support promotion of wildlife, landscape, townscape or historic interests. 4. It would not involve the loss of land of local amenity importance or of recreational value; 5. It would not impair highway safety or traffic flows. 6. It would not prejudice the development potential of an adjacent site. For the main Local Plan the boundaries relate to the Towns of East Devon. For our Villages they will be defined in the Villages Development Plan Document. Where a local community prepare a Neighbourhood Plan they may specifically allocate sites and/or include criteria based or other policies for promoting development/land uses beyond the boundary. Such ‘outside of boundaries’ policy provision would supersede relevant constraint considerations set out in ‘Strategy 7 - Development in the Countryside’ and also other relevant constraint policies.

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Strategy 7 – Development in the Countryside: The countryside is defined as all those parts of the plan area that are outside the Built-up Area Boundaries and outside of site specific allocations shown on the Proposals Map. Development in the countryside will only be permitted where it is in accordance with a specific Local or Neighbourhood Plan policy that explicitly permits such development and where it would not harm the distinctive landscape, amenity and environmental qualities within which it is located, including: 1. Land form and patterns of settlement. 2. Important natural and manmade features which contribute to the local landscape character, including topography, traditional field boundaries, areas of importance for nature conservation and rural buildings. 3. The adverse disruption of a view from a public place which forms part of the distinctive character of the area or otherwise causes significant visual intrusions.

‘Strategy 27’ of the Local Plan is the most significant strategic policy in terms of housing development outside of the main development areas. Rockbeare is not one of the cited villages, although the option is open for Rockbeare to promote housing development.

Strategy 27 - Development at the Small Towns and Larger Villages: The following settlements vary in size and character but all offer a range of accessible services and facilities to meet many of the everyday needs of local residents and they have reasonable public transport. They will have a Built-up Area Boundary that will be designated in the East Devon Villages DPD though they will not have land specifically allocated for development. • Beer • Broadclyst • Clyst St Mary • Colyton • East Budleigh • Feniton • Kilmington • Lympstone • Musbury • Newton Poppleford • Sidbury • Uplyme • West Hill • Whimple • Woodbury If communities wish to promote development other than that which is supported through this strategy and other strategies in the Plan (at the settlements listed above or any other settlement) they will need to produce a Neighbourhood Plan or promote community led development (for example Community Land Trusts) justifying how and why, promote the objectives of sustainable development.

Turning to affordable housing, ‘Strategy 34’ sets out the district’s affordable housing targets and ‘Strategy 35 deals with affordable housing and mixed market housing outside of built-up area boundaries.

Strategy 34 - District Wide Affordable Housing Provision Targets: (extract) Affordable housing will be required on residential developments in East Devon as follows. Within the areas defined below a target of 25% of the dwellings shall be affordable: Axminster; Exmouth; Honiton; Ottery St Mary; Seaton; and Major strategic ‘West end’ development sites. Under this policy: 1 the towns listed above are defined by the area within the Built-up Area Boundary 2 the major strategic West End development sites to which policy will apply are a) Cranbrook, b) adjacent to Pinhoe and c) North of Blackhorse Areas to which higher (50%) affordable housing targets apply: Outside of the areas listed above (i.e. all other parts of East Devon including all settlements not listed, coastal and rural areas and Budleigh Salterton and Sidmouth) 50% of the dwellings shall be affordable subject to viability considerations. The 50% figure applies to all areas that do not come under the 25% classification and which are permitted under Strategy 35 ‘Exceptions’ policy. Where a proposal does not meet the above targets it will be necessary to submit evidence to demonstrate why provision is not viable or otherwise appropriate……..

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Strategy 35 – Exception Mixed Market and Affordable Housing at Villages, Small Towns and Outside Built-up Area Boundaries: Exception site mixed affordable and open market housing schemes, at villages and outside of Built up Area Boundaries, for up to or around 15 dwellings will be allowed where there is a proven local need demonstrated through an up to date robust housing needs survey. Affordable housing must account for at least 66% of the houses built. a) Villages WITH a Built-up Area Boundary the scheme must be abutting or physically closely related to that boundary; or b) Villages WITHOUT a Built-up Area Boundary the scheme should be physically very well related to the built form of the village. To be permitted, evidence will need to show: The affordable housing need in any given locality would not otherwise be met, and the village or small town has a population that falls below 3,000 persons, the scheme is well designed using local materials, close to a range of community services and facilities (including four or more of a school, pub, village hall, shop/post office, doctors’ surgery, place of worship or public transport service) and sympathetic to the character of the settlement and has a satisfactory highway access. Initial and subsequent occupancy of the affordable housing is restricted to a person(s) who: a) Does not have access to general market housing and is in housing need; and b) Is a resident of that Parish group, or has a local connection with that parish group because of family ties or a need to be near their workplace. In the event that an occupier who fulfils both criterion (a) or (b) cannot be found within a reasonable period of time, then the criterion will be widened firstly to a person(s) with a local connection to the parish group because of family ties or a need to be near their workplace, and subsequently to a person(s) with an East Devon connection. In this policy, local connection means one or more of the following connections in priority order in respect of parishes or the parish grouping: i) persons who have been permanently resident therein for a continuous period of three years out of the five years immediately prior to the Affordable Dwelling being offered to them; or ii) being formerly permanently resident therein for a continuous period of five years at some time in the past; iii) having his or her place of permanent work (normally regarded as 16 hours or more a week and not including seasonal employment) therein for a continuous period of at least twelve (12) months immediately prior to being offered the Affordable Dwelling; or iv) persons who can demonstrate a close family connection to the District in that the person’s mother, father, son, daughter or sibling has been permanently resident

The supporting text for ‘Strategy 35’ provides important context for the policy. “16.27 To assist with securing affordable housing provision the District Council will continue to take initiatives aimed at securing affordable housing by permitting development in locations where ordinarily, residential development would not be acceptable (notably outside Built-up Area Boundaries. For such land to be released, however, rigorous stipulations will be applied to avoid prejudicing the environmental conservation policies of the plan. Development of such sites will not be regarded as creating a precedent for future expansion to meet other housing needs. 16.28 To help provide for affordable housing, recognising that there can be a need to generate money to subsidise provision, mixed affordable/open market schemes will be permitted in rural areas where there is an identified need and new residents will be able to access facilities. Policy sets out the criteria for such schemes where they are located adjacent to, but outside, settlements with a range of facilities and services to meet the everyday needs of local residents. Preference will be given to locating new housing at settlements with Built-up Area Boundaries but this will not be possible for all the Parish groupings below and this policy may apply to

Rockbeare NP Strategic Framework page 47 settlements without a Built-up Area Boundary that meet the criteria set. In some instances, due to the need to protect an important historic, landscape or nature feature, sites not immediately adjacent but physically well- related and within easy walking distance will be considered. All sites will need to be close to a range of facilities and meet a proven local need. Such schemes will be required to contribute towards community facilities and infrastructure to the same extent as other market residential development. Up to 15 houses may be built under this policy and the affordable housing must account for at least 66% of all the houses built, but the percentage can be higher (up to 100% affordable). 16.29 For affordable housing in rural areas account will be taken of the specific need within the Parish in which the application land is sited and in addition regard will also be paid to need in surrounding Parishes. The grouping of geographic parishes will be used for assessing housing needs is as follows: c) Broadclyst, Clyst Honiton, Clyst Hydon, Clyst St. Lawrence, Rockbeare and Poltimore.

The Local Plan also sets out broad standards for design and construction, which applies across all building types and not just housing.

Strategy 38 - Sustainable Design and Construction: (extract) Encouragement is given for proposals for new development and for refurbishment of, conversion or extensions to, existing buildings to demonstrate through a Design and Access Statement how: a) sustainable design and construction methods will be incorporated, specifically, through the re-use of material derived from excavation and demolition, use of renewable energy technology, landform, layout, building orientation, massing, use of local materials and landscaping; b) the development will be resilient to the impacts of climate change; c) potential adverse impacts, such as noise, smell, dust, arising from developments, both during and after construction, are to be mitigated. d) biodiversity improvements are to be incorporated. This could include measures such as integrated bat and owl boxes, native planting or green roofs. Until the adoption of nationally prescribed standards, developments of 10 or more dwellings or 1,000m2 of commercial floor space should be assessed using the CSH or BREEAM, with housing developments meeting at least CSH Level 4 from 2013 and other uses BREEAM of at least ‘Very Good’…….

Within the context of this policy, policy D1 ‘Design and Local Distinctiveness’ in Part 2 of the Plan (which deals with development management policies over which the neighbourhood plan has more influence to alter or amplify) sets out the criteria which will be applied.

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D1 - Design and Local Distinctiveness: In order to ensure that new development, including the refurbishment of existing buildings to include renewable energy, is of a high quality design and locally distinctive, a formal Design and Access Statement should accompany applications setting out the design principles to be adopted should accompany proposals for new development. Proposals should have regard to Village and Design Statements and other local policy proposals, including Neighbourhood Plans, whether adopted as Supplementary Planning Guidance or promoted through other means. Proposals will only be permitted where they: 1. Respect the key characteristics and special qualities of the area in which the development is proposed. 2. Ensure that the scale, massing, density, height, fenestration and materials of buildings relate well to their context. 3. Do not adversely affect: a) The distinctive historic or architectural character of the area. b) The urban form, in terms of significant street patterns, groups of buildings and open spaces. c) Important landscape characteristics, prominent topographical features and important ecological features. d) Trees worthy of retention. e) The amenity of occupiers of adjoining residential properties. f) The amenity of occupants of proposed future residential properties, with respect to access to open space, storage space for bins and bicycles and prams and other uses; these considerations can be especially important in respect of proposals for conversions into flats. 4. Have due regard for important aspects of detail and quality and should incorporate: a) Secure and attractive layouts with safe and convenient access for the whole community, including disabled users. b) Measures to create a safe environment for the community and reduce the potential for crime. c) Use of appropriate building materials and techniques respecting local tradition and vernacular styles as well as, where possible, contributing to low embodied energy and CO2 reduction. d) Necessary and appropriate street lighting and furniture and, subject to negotiation with developers, public art integral to the design. e) Features that maintain good levels of daylight and sunlight into and between buildings to minimise the need for powered lighting. f) Appropriate ‘greening’ measures relating to landscaping and planting, open space provision and permeability of hard surfaces. 5. Incorporate measures to reduce carbon emissions and minimise the risks associated with climate change. Measures to secure management of waste in accordance with the waste hierarchy (reduce, reuse, recycle, recovery, disposal) should also feature in proposals during the construction and operational phases. 6. Green Infrastructure and open spaces should be designed and located in a way that will minimise any potential security concerns for users. 7. Mitigate potential adverse impacts, such as noise, smell, dust, arising from developments, both during and after construction.

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Policy D8 sets out the criteria against which the re-use of rural buildings outside of settlements will be applied.

D8 – Re-use of Rural Buildings Outside of Settlements: The re-use or conversion of buildings in the countryside outside of Built-up Area Boundaries will be permitted where: 1. The new use is sympathetic to, and will enhance the rural setting and character of the building and surrounding area and is in a location which will not substantively add to the need to travel by car or lead to a dispersal of activity or uses on such a scale as to prejudice village vitality. 2. The building is structurally sound and capable of conversion without the need for substantial extension, alteration or reconstruction and any alterations protect or enhance the character of the building and its setting; 3. The form, bulk and general design of the building and its proposed conversion are in keeping with its surroundings, local building styles and materials; 4. The proposed use would not harm the countryside by way of traffic, parking, storage, pollution or the erection of associated structures; 5. The proposal will not undermine the viability of an existing agricultural enterprise or require replacement buildings to fulfil a similar function. For residential proposals it must be established that: a) the building is no longer required for agricultural use or diversification purposes; and b) that its conversion will enhance its setting - e.g. through removal of modern extensions and materials, outside storage, landscaping etc. c) Development is located close to a range of accessible services and facilities to meet the everyday needs of residents Residential use will be expected to comply with the affordable housing and, open space and education provision policies of the Plan. Applications for the re-use of rural buildings should be accompanied by the results of a combined bat and barn owl survey together with a heritage survey and heritage statement where appropriate. Furthermore, provision for barn owls should be incorporated into all rural barn conversions, within 1 kilometre of sightings of barn owls or signs of their activity. Where a future alteration or extension could have a detrimental effect on the character of the converted building or the area, permitted development rights will be withdrawn for such development. Where a proposal involves the re-use or conversion of agricultural buildings and the proliferation of any replacement or new buildings would have a serious detrimental effect on the landscape, permitted development rights will be withdrawn for new farm buildings on the relevant part of that particular agricultural unit or holding. In determining proposals to convert a building constructed using agricultural permitted development rights, account will be taken of the extent to which the building has been used for its original purpose.

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The range and mix of new housing development is set out by policy H2.

H2 - Range and Mix of New Housing Development: Planning permission will not be granted for new residential development which provides for 15 dwellings or more, or is situated on a site of 0.5 ha or larger, unless it contains a mix of dwelling sizes or comprises predominantly, or totally, of smaller dwellings. However, where site characteristics, including in respect of landscape prominence and character, clearly indicate an alternative scale is appropriate there will be flexibility in scale. Landscape Character Assessment will be of key importance in site assessment work and establishing an appropriate dwelling mix. To ensure a variety of housing provision, where possible, developers will be encouraged to make at least 10% of plots available for sale to small builders or individuals or groups who wish to custom build their own homes.

Policies H4, H5 and H6 set out important considerations for housing in rural areas.

H4 - Dwellings for Persons Employed in Rural Businesses: Permission for dwellings in the countryside for new agricultural or forestry workers or people employed in rural businesses or activities will be granted where the proposal fully satisfies the following: 1. There is a proven and essential agricultural or forestry or rural business need for the occupier of the proposed dwelling to be housed permanently on the unit or in the specific rural location for functional reasons and the size of the proposed dwelling is commensurate with the scale of the established functional need. Where this need is unproven or a new business is being established a temporary dwelling (such as a mobile home) may be permitted to allow time to establish that there is a genuine functional and financial need for a permanent dwelling. A temporary dwelling will normally be permitted for a period of three years, subject to meeting relevant criteria detailed below. 2. In the case of a permanent dwelling, the rural business has been operational for a minimum of three years, it is demonstrable that it is commercially viable and has clear prospects for remaining so. 3. In the case of a temporary dwelling, a financial assessment, specifically in the form of a business plan setting out projected future operations, must demonstrate future operational viability. 4. The qualifying test of occupancy must involve at least one occupant being employed full time in the relevant rural business. Two occupants in partnership can meet the condition so long as their joint weekly hours equate to a full working week 5. There are no buildings on the operational holding suitable for conversion to meet the residential need or exiting dwellings available now or likely to be available within a nearby location or settlement. Sale within the last three years of any dwellings or buildings suitable for conversion will be taken into account and will count against ‘need’ in the assessment carried out. 6. Any permission granted will be subject to an occupancy condition tying it to the relevant business on the proposed dwelling and where appropriate, any existing dwelling on the farm holding. Applications for extensions to, or replacement of, agricultural or forestry workers dwellings (other than where minor works are proposed commensurate with the scale and needs of the business) will require a reassessment of need. Any permission granted will be tied through legal agreement to the agricultural holding.

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H5 - Occupancy Conditions on Agricultural/Forestry Rural Workers Dwellings: Proposals to relax occupancy conditions or a planning obligation will only be permitted where it is demonstrable that economic circumstances have changed such that: 1. There is no long term functional need for the dwelling for rural worker and; 2. Satisfactory evidence has been provided that the dwelling has been offered for sale or rent with its occupancy restriction, at a realistic price for a reasonable period of time (at least 18 months and up to 2 years depending on market conditions), and no interest has been shown in its purchase or rent, unless the property is to be sold/ leased to a Registered Social Landlord. Records of all viewings and offers will be required and the property should be regularly advertised in specialist agricultural publications as well as local media and the internet. Where these conditions have been met, and there is a demonstrated housing need in the area (as established through a local needs survey as applied to the Parish in which the dwelling is located) the condition will be modified to limit the occupancy of the dwelling to meet local affordable housing needs of the local community. Occupancy will be restricted to a person or persons who: a) Do not have access to general market housing; and b) Is a resident of that Parish group, or has a local connection with that parish group because of family ties or a need to be near their workplace. Where viable future occupancy will be tied through legal agreement to the operation and associated land which has the essential need, and a condition/legal agreement imposed to prevent the severing of the operation from the dwelling.

H6 - Replacement of Existing Dwellings in the Countryside: Proposals for the replacement of an existing dwelling outside the defined Built-up Area Boundaries will be permitted, provided that all the following criteria are satisfied: 1. There is an existing, permanent, habitable dwelling located on the site, which is not a dwelling specifically granted planning permission under the agricultural or forestry exceptions policy. 2. The replacement dwelling is located on, or adjacent to, the footprint of the existing dwelling, or elsewhere within the curtilage of the building where a clear planning or environmental benefit will be achieved. 4. The replacement dwelling does not detract from the appearance and character of the landscape, and within the East Devon and Blackdown Hills Areas of Outstanding Natural Beauty harm the natural beauty of the landscape. 5. The dwelling to be replaced is not of architectural importance (whether Listed or not) or important in terms of contributing to landscape character or quality or local distinctiveness. A condition will be attached to any planning permission granted, which requires the demolition of the existing dwelling prior to the occupancy of the replacement dwelling, should an alternative location for the replacement dwelling be agreed.

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East Devon Villages Development Plan Document East Devon District Council intends to produce an East Devon Villages Development Plan Document (DPD), which will complement the Local Plan and set out policies and boundaries for developments at those settlements proposed for housing growth.

It will set out how local plan policies will be implemented at the village level and includes maps for each village (named in Strategy 27 that “will have a Built-up Area Boundary that will be designated in the East Devon Villages DPD though they will not have land specifically allocated for development. built-up area boundary.”) showing the Built-up Area Boundary and land allocated or identified for housing development. The maps also show land for other uses and locations where plan policies will apply.

A consultation draft for the Villages DPD was produced in 2013 following an initial consultation with the town and parish councils of the district. The 2013 draft proposed that Rockbeare should allocate land for ten dwellings. This draft allocation has now been superseded by the Local Plan policy that does not allocate specific numbers to parish areas and excludes Rockbeare from those areas in Strategy 27 where sustainable development will be directed. However, Strategy 27 does state that “if communities wish to promote development other than that which is supported through this strategy and other strategies in the Plan (at the settlements listed….. or any other settlement) they will need to produce a Neighbourhood Plan or promote community led development (for example Community Land Trusts) justifying how and why, promote the objectives of sustainable development.”

East Devon Strategic Housing Market Assessment Local authorities undertake a Strategic Housing Market Assessment (SHMA) to ensure that their strategies and policies are based on a good understanding of the local housing market across various housing types and tenures, and includes an assessment of housing needs. The local SHMA was first commissioned by East Devon District Council and other local authorities in the Exeter and Torbay housing market area (covering Exeter, East Devon, Mid-Devon, Teignbridge and Torbay) in 2007 and up-dated for East Devon in 2011. The Inspector, of the draft East Devon Local Plan, found the up-dated SHMA to be out-of-date in 2015, when he carried out an inspection of the draft Local Plan. As a consequence, East Devon District Council was required to commission a new study. This reported in February 2015.

The independent SHMA report was again commissioned jointly by the planning authorities of Exeter, East Devon, Mid Devon and Teignbridge, and Dartmoor National Park. As regards East Devon, the key finding of the report is that the correct amount of housing stock that East Devon District Council should be providing (in line with the local plan inspector’s recommendation) is 950 homes per year, which will be spread over 18 years. This figure was influenced by independent job projections, which showed that the projected job growth for East Devon averaged out at an extra 549 jobs per year. Most telling of the conclusions of the SHMA is perhaps that “future need for all authorities is concluded to be largely dominated by a need for smaller properties, mostly in the 1 and 2 bedroom size categories. But this may not coincide with purchasing aspirations of new some home buyers or developers’ build aspirations”45.

Strategic Housing Land Availability Assessment (SHLAA), 2012 (updated July 2013) As well as an understanding of the demand side, the local planning process also requires an understanding of the land supply side of the housing equation. The latest East Devon Strategic Housing Land Availability Assessment (SHLAA) was produced in 2012 and updated in July 2013. It sets out the process through which land with potential to be developed for housing (and other uses) has been identified and assessed for its developability. The SHLAA was done in response to the requirements in the NPPF for local authorities to have an up-to-date understanding of land availability and supply for housing development46. (The findings of the work were used to inform the preparation of the 2014 draft of the Villages DPD.)

45 Exeter Housing Market Area Strategic Housing Market Assessment Final Report 2014/15, DCA, 2015 46 See paragraphs 47-49 in the NPPF. Rockbeare NP Strategic Framework page 53

The SHLAA is a technical (i.e. non politicised and free from value judgement) process where the public, organisations, land owners and developers can submit suggestions for land which they consider is appropriate to be developed for housing through the Local Plan process. Each site submitted is then assessed against various criteria to determine which sites, from a constraints and opportunity assessment, are the most suitable (and viable) to accommodate development. An expert panel was used, comprising of land agents, developers, local authority officers, Registered Social Landlords (Housing Associations) and Agencies to help determine viability of sites and the likelihood of them realistically coming forward for development. This process does not mean that all ‘nominated’ sites can or will come forward for development and a site’s inclusion in the exercise does not give that site planning permission nor replace the need for a planning application to be made.

Sites of 15 dwellings or more that were “currently” (in July 2013) in the planning system are identified in the SHLAA. The report states that more than 160 sites were reviewed through the SHLAA process. It has also estimated the yield of dwellings for these sites and splits them into three time periods of likely delivery. These sites are all mapped47 (including sites at Rockbeare and Marsh Green) and provide a useful reference resource not just for the Local Plan but for neighbourhood plans too.

Homes and Communities Plan 2012–16: Living in this Outstanding Place The Homes and Communities Plan sets out East District Council’s key priorities and plans for housing between 2012 and 2016. It encapsulates some of the key actions required for housing from documents such as the Local Plan, Tenancy Strategy, Resident Involvement Strategy, Private Sector Renewal Strategy and Homelessness Strategy. It identifies the main housing issues in East Devon as: • “a need for more affordable housing (demand far exceeds supply) • the high cost of owner occupation and renting in the private sector affecting the ability to secure suitable housing • low wages in the district as compared to the national average poor housing conditions in the private sector • fuel poverty and affordable warmth • the lack of suitable housing for young people.”48

It identifies the Council’s ten key strategic aims, to: • “provide a range of affordable housing to meet housing needs • prevent homelessness wherever possible, and make sure that accommodation is found for those who do become homeless • maintain and manage the council owned housing stock to a high standard, actively involving tenants in all aspects of the service • bring sub-standard housing (of all tenures) up to current standards • improve the use and safety of housing • enable elderly people, disabled people, and people with special needs to live as independently as possible and remain in their own homes if they so wish • improve the sustainability and energy efficiency of housing and eliminate fuel poverty • widen the choice of housing, especially for those in priority need • support the improvement and regeneration of local communities by encouraging social inclusion, involving children and young people in housing issues, and enabling residents to actively participate in their communities • have consistently satisfied customers.”49

47 http://maps2.eastdevon.gov.uk/mapping/shlaa/ 48 p.9, Homes and Communities Plan 2012–16: Living in this outstanding place, East Devon District Council, 2012 49 p.14, Homes and Communities Plan 2012–16: Living in this outstanding place, East Devon District Council, 2012 Rockbeare NP Strategic Framework page 54

Housing Aspirations of Older People Living in Rural Devon, 2011 This study was undertaken by Community Council of Devon on behalf of the Devon Rural Housing Partnership in 2011. Although not specific to East Devon, it raises a number of common issues across rural communities in Devon, summarising its key findings as follows. “a. Most older people want to stay within their existing community as they age. b. The demand for supported housing schemes in villages is limited. c. The maintenance of village shops and public transport is important to supporting older people in rural communities. d. Given that the aspiration is for people to remain in their home as long as possible there are challenges for policy makers to facilitate the demand that this will make for domiciliary and other care services in rural areas with varying degrees of remoteness. e. To allow older residents to remain in their home there are also issues about physical changes needed to properties to allow this to happen. f. Local Authorities need to consider amending planning policy which restricts open market housing development for older people in rural villages. This may lead to older residents being forced to move away from their community support networks to find the easy and cheap to maintain new home that they need to allow them to continue to live independently. h. The new localism agenda provides an opportunity for communities to create bottom up solutions for how to support older residents to stay in their community.”50

East Devon Tenancy Strategy 2012 The District Council’s most recent assessment of the local housing market concludes that “the main housing issues and challenges within East Devon are:  A need for more affordable housing (demand far exceeds supply)  The high cost of owner occupation and renting in the private sector affecting the ability to secure suitable housing  Low wages in the district as compared to the national average  Poor housing conditions in the private sector  Fuel poverty and affordable warmth  The lack of suitable housing for young people”51

The Tenancy Strategy is due for review during 2016.

50 p.3, Housing Aspirations of Older People Living in Rural Devon, Community Council of Devon (on behalf of the Devon Rural Housing Partnership), 2011 51 http://eastdevon.gov.uk/housing/housing-strategies-and-policies/tenancy-strategy/local-housing-market-in-east-devon/#article- content Rockbeare NP Strategic Framework page 55

Community Services and Facilities National Planning Policy Framework “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:  an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or  the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or  the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss Planning policies should protect and enhance public rights of way and access. Local authorities should seek opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails. Local communities through local and neighbourhood plans should be able to identify for special protection green areas of particular importance to them. By designating land as Local Green Space local communities will be able to rule out new development other than in very special circumstances.”52 “Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities.” 53 Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education. They should:  give great weight to the need to create, expand or alter schools  work with schools’ promoters to identify and resolve key planning issues before applications are submitted”54 “Planning should…..take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.”55 Planning policies and decisions, in turn, should aim to achieve places which promote:  opportunities for meetings between members of the community who might not otherwise come into contact with each other, including through mixed-use developments, strong neighbourhood centres and active street frontages which bring together those who work, live and play in the vicinity  safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion  safe and accessible developments, containing clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas”56

National Planning Practice Guidance National Planning Practice Guidance, published by DCLG, provides supplementary guidance to the NPPF. A number of recent and relevant revisions to the guidance have been published. These include guidance on health and wellbeing and Local Green Space:

Health & Wellbeing “Local planning authorities should ensure that health and wellbeing, and health infrastructure are considered in local and neighbourhood plans and in planning decision making. Public health organisations, health service organisations, commissioners and providers, and local communities should use this guidance to help them work

52 Page 18, paras 74-76, National Planning Policy Framework, HM Government, 2012 53 Page 10, para 37, National Planning Policy Framework, HM Government, 2012 54 Page 17, para 72, National Planning Policy Framework, HM Government, 2012 55 Page 6, para 17, National Planning Policy Framework, HM Government, 2012 56 Page 17, para 69, National Planning Policy Framework, HM Government, 2012 Rockbeare NP Strategic Framework page 56 effectively with local planning authorities in order to promote healthy communities and support appropriate health infrastructure.”57

Open Space “Open space should be taken into account in planning for new development and considering proposals that may affect existing open space. Open space, which includes all open space of public value, can take many forms, from formal sports pitches to open areas within a development, linear corridors and country parks. It can provide health and recreation benefits to people living and working nearby; have an ecological value and contribute to green infrastructure, as well as being an important part of the landscape and setting of built development, and an important component in the achievement of sustainable development. It is for local planning authorities to assess the need for open space and opportunities for new provision in their areas. In carrying out this work, they should have regard to the duty to cooperate where open space serves a wider area.”58

Local Green Space “Local Green Space designation is a way to provide special protection against development for green areas of particular importance to local communities. Local Green Space designation is for use in Local Plans or Neighbourhood Plans. These plans can identify on a map (‘designate’) green areas for special protection. Anyone who wants an area to be designated as Local Green Space should contact the local planning authority about the contents of its local plan or get involved in neighbourhood planning. Designating any Local Green Space will need to be consistent with local planning for sustainable development in the area. In particular, plans must identify sufficient land in suitable locations to meet identified development needs and the Local Green Space designation should not be used in a way that undermines this aim of plan making. Local Green Space designation will rarely be appropriate where the land has planning permission for development. Exceptions could be where the development would be compatible with the reasons for designation or where planning permission is no longer capable of being implemented. Local Green Spaces may be designated where those spaces are demonstrably special to the local community, whether in a village or in a neighbourhood in a town or city. The green area will need to meet the criteria set out in paragraph 77 of the National Planning Policy Framework. Whether to designate land is a matter for local discretion. For example, green areas could include land where sports pavilions, boating lakes or structures such as war memorials are located, allotments, or urban spaces that provide a tranquil oasis. Provided land can meet the criteria at paragraph 77 of the National Planning Policy Framework there is no lower size limit for a Local Green Space. Land designated as Local Green Space may potentially also be nominated for listing by the local authority as an Asset of Community Value. Listing gives community interest groups an opportunity to bid if the owner wants to dispose of the land.”59

National agencies have been considering the implications of the new NPPF and setting out their own national policies and guidance which often makes reference to the role of neighbourhood plans.

Sport England believes that it is important that the Neighbourhood Plan reflects national policy for sport as set out in the NPPF document with particular reference to Pars 73 and 74 to ensure proposals comply with national planning policy. It is also important to be aware of Sport England’s role in protecting playing fields and the presumption against the loss of playing fields. “As set out in our national guide, playing fields are one of the most important resources for sport in England. They provide the valuable space required to maintain and

57 Planning Practice Guidance Para: 001 Ref ID: 53-001-20140306 Revision date: 06 03 2014 58 Planning Practice Guidance Para:001 Ref: 37-001-20140306 Revision date: 06 03 2014 59 Planning Practice Guidance Para:022 Ref: 37-022-20140306 Revision date: 06 03 2014 Rockbeare NP Strategic Framework page 57 enhance opportunities for people to participate both in formal team sports and in other more informal activities. Along with sporting benefits, good quality, accessible playing fields also contribute to maintaining active and healthy communities and securing wider reaching benefits. Planning applications affecting playing field land Since 1996 Sport England has been a statutory consultee on all planning applications for development affecting playing field land. This requires local planning authorities to consult Sport England when a relevant planning application is received. Sport England’s comments should then be taking into account prior to them making any decision whether or not to grant planning permission. This requirement is set out by the government in Statutory Instrument 2010/2184.

Depending on the nature of the application Sport England will inform the relevant sport’s national governing body of the proposals and seek their comments prior to submitting a response to the local planning authority.

It is Sport England’s policy to oppose any planning application which will result in the loss of playing field land unless it is satisfied that the application meets with one or more of five specific exceptions. If a local planning authority is minded to grant planning permission for an application despite receiving an objection from Sport England then the requirements of Circular 02/2009 may apply. This instructs local planning authorities to notify the Secretary of State for Communities and Local Government of an application if the land is owned by a local authority or used by an educational establishment (currently or within the five years prior to receiving the application), and where Sport England has objected due to a current or resulting deficiency of playing field land in the area or because the replacement to be provided in inadequate. Playing Pitch Strategies Sport England believes that the best way to protect and improve the provision of playing fields is for a local area to have an up-to-date and adopted Playing Pitch Strategy in place. The starting point for assessing the vast majority of planning applications affecting playing field land should therefore be to look at how the proposals fit with the local Playing Pitch Strategy. The following link provides guidance on developing a Playing Pitch Strategy and Sport England’s knowledge of the coverage of such strategies across the country.” 60

“Sport England works with Local Authorities to ensure Local Plan policy is underpinned by robust and up to date assessments and strategies for indoor and outdoor sports delivery. If local authorities have prepared a Playing Pitch Strategy or other indoor/outdoor sports strategy it will be important that the Neighbourhood Plan reflects the recommendations set out in that document and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support the delivery of those recommendations. If new sports facilities are being proposed, Sport England recommend you ensure such facilities are fit for purpose and designed in accordance with our design guidance notes.”61

Devon Education Infrastructure Plan 2013-2031 “Our principles for providing facilities are to: • provide local schools for local children - promoting a pattern of sustainable, high-quality provision which maximises accessibility, meets local needs and recognises the needs generated by planned growth in specific localities • provide parents and children with choice, diversity and excellence • ensure that there is a flexible framework in place which promotes a mixed market of providers and manages the impact of new providers entering the system We will do this by: • maintaining a network of provision in all parts of Devon, with a presumption against closing schools unless necessary for educational reasons • working with small schools to explore options to maintain sustainable provision and excellence

60 A Sporting Future for the Playing Fields of England – Planning Policy Statement, Sport England, 2014 61 Correspondence with Planning Administrator, Sport England, May 2014 Rockbeare NP Strategic Framework page 58

• expanding popular and successful schools, in particular where this would secure greater parental preference • minimising the reliance on the school transport budget to meet our statutory responsibilities • working with each Local Learning Community to identify optimal solutions to capacity issues arising from demographic change in local communities • securing provision which supports the most vulnerable children, in particular the need to expand the special school offer”62

“We will work with key stakeholders to secure: • a network of provision for 0-5 year olds in locations accessible to local circumstances to improve outcomes and reduce inequalities • early years provision to support the most vulnerable two year olds • primary school accommodation within walking distance promoting local schools for local children, community cohesion and minimising the need to use transport to travel to school • secondary school accommodation with a wide range and choice of provision for pupils and parents • transition and choice for young people from secondary to further education • an enhanced range of special needs facilities in each part of the county to reduce travelling and increase accessibility • childcare to meet the needs of working parents”63

Joint Health & Wellbeing Strategy for Devon 2013-2026 “Priority four: Social capital and building communities This priority involves improving health and wellbeing by developing social capital, including neighbourliness, family support and personal responsibility. Mental Health and Emotional Health and Wellbeing Why is it an issue? Most people will come into contact with mental health issues during their lifetime, and one in four will have personal experience of a mental health problem. The invisibility of mental illness means that many do not receive the support and treatment that could help them. What is the position in Devon? At present, around 83,000 adults in Devon have a neurotic disorder. What is the evidence of effective interventions? Devon has produced a Mental Health and Wellbeing Promotion Strategy which has adopted the life course approach. Some people and groups are more at risk of common mental health problems often as a result of the social, economic or environmental circumstances in which they find themselves. Early identification and supportive intervention, across a range of services and initiatives, will help provide stability and negate the need for further more intensive health care and treatment. Living Environments Why is it an issue? The home environment plays a significant role in physical and emotional health and wellbeing, which can be addressed through a focus on safety in the home and supporting vulnerable residents. There is a link between cold homes and an increased propensity for falls. What is the position in Devon? The 2010 national Indices of Deprivation highlighted that housing conditions in Devon are generally poorer than the national average. The housing stock in Devon is generally older than nationally and many households lack basic amenities. What is the evidence of effective interventions? Improving heating, thermal insulation and removing dampness from homes can improve the general and respiratory health of children and cardiovascular, respiratory, rheumatoid and mental health in the population. Reducing housing defects can reduce health hazards which occur in the home through disrepair, fire hazards and excess cold. Interventions need to target the most vulnerable populations in the poorest housing with a focus on deprived areas, rough sleepers and the homeless. Housing

62 Page11, para. 2.4, Devon Education Infrastructure Plan 2013-2031, Devon CC, April 2013 63 Page18, para. 2.29, Devon Education Infrastructure Plan 2013-2031, Devon CC, April 2013 Rockbeare NP Strategic Framework page 59

Why is it an issue? The age, condition and high cost of housing in Devon have a number of health consequences relating to overcrowding, fuel poverty and excessive cold, respiratory problems and emotional wellbeing. Poor housing has an impact on the health outcomes for children and older people in particular, including psychological distress and mental disorders, with people in crowded conditions tending to suffer from multiple deprivation. What is the position in Devon? The availability of housing in Devon is worse than the national average, with average house prices 10 times average salaries. Vulnerable households account for just under a fifth of the population living in private rented housing in Devon. What is the evidence of effective interventions? A number of initiatives are currently in place to address affordability and volume of housing including extra care housing, domestic violence support schemes and initiatives to provide adaptations to enable people to stay in their homes for longer and address overcrowding. The use of personalised budgets for rough sleepers has been shown to enable long-term rough sleepers to come off the streets and plan for the future. The future challenge relates to a lack of funding programmes, in the form of grants or loans, for owners to improve the existing housing stock alongside a reduction in housing development, impacting on the future supply of affordable housing. Social Isolation Why is it an issue? A combination of an ageing population, higher levels of rural deprivation compared to the national average, and greater distance from health and social care services and amenities contribute to higher levels of social isolation in Devon, and a focus on social support and improving access to services can help to address this. These issues may be compounded for people, particularly older people, with physical or sensory disability. What is the position in Devon? 28.8% of the Devon population live in rural areas compared with 9.5% nationally. A higher proportion of the Devon population live alone (16.6% compared with 14.4% nationally). The Devon Community Life Choices consultation found that for some people limited by disability, frailty or ill health accessing social activities becomes difficult if not impossible resulting in loneliness, isolation, feelings of low self-worth and poor mental and physical health. What is the evidence of effective interventions? Social capital can be created by enabling and empowering communities through community-led planning, volunteering, supporting social enterprise and the voluntary and community sector and through the civic behaviour of business. It is important that social isolation is addressed for all ages. The guidance on improving the wellbeing of young people promotes taking action to connect young people with their communities; supporting volunteering and a sense of belonging; mixing safely with peers and enjoying spending time with older people. Our focus for Priority four is to: • build on the strengths in our communities and promote social cohesion and support for vulnerable groups and individuals • carry out a Health Needs Assessment for mental health to better understand future commissioning needs • target the most vulnerable individuals for fuel poverty and housing interventions • take effective action to address homelessness and improve the quality of the housing stock across Devon • ensure the health needs of offenders in institutional settings and the community remain a priority”64

Update on the Joint Health and Wellbeing Strategy for 2013-2016 Action Plan summary: “A focus on children and families Additional actions  Support families with children living in poverty  Commission services to reduce domestic and sexual violence and abuse  Smoking cessation support for vulnerable groups

64 Pages 25-29, Joint Health & Wellbeing Strategy for Devon 2013-2026, NHS Devon and Devon CC, 2013 Rockbeare NP Strategic Framework page 60

 Ensure the multi-agency ‘Early Help’ strategy is implemented

Healthy lifestyle choices Additional priorities Integrated pathway for self-care Additional actions  Healthy lifestyle advice to people at risk of circulatory diseases  Weight management on referral scheme  Increase physical activity levels for all ages

Good health and wellbeing in older age Additional priorities End of life care integrated pathway Additional actions  Promote healthy lifestyle advice to people with dementia  Implement carers strategy  Undertake a sight loss/visual impairment health needs assessment

Strong and supportive communities Additional priorities Protected characteristics JSNA Additional actions  New suicide prevention strategy  Revised public mental health strategy  Identify new indicators for wellbeing “65

East Devon Open Space Study 2011 This study has guided open space planning in East Devon since it was adopted in 2012. It was up-dated in 2014 to take account of new open space sites, sites which have been removed since the study’s production, sites which have been upgraded/changed, and amending some classifications to be more appropriate to their use/management. The 2014 Open Space Review report does not seek to change the general thrust of the 2011 study, the methodology used or the open space standards. “From the consultation we have seen that there is a particular demand for and appreciation of: · High quality and well connected open space facilities using greenways and other public rights of way · High quality signposting of footpaths and cycleways, and informative and attractive notice boards · Well managed and clearly designated cycle paths. · Making the most of existing open space facilities, through improvements to quality and accessibility. · Additional provision of grass playing pitches and artificial turf surfaces in certain areas. · High quality play equipment, updating where appropriate and incorporating innovative and contemporary design for enhancing play opportunities · The importance of managing dogs in open space areas, both accommodating their and their owners’ needs whilst not prejudicing enjoyment and safety of other users · Generally, more play and recreation opportunities and facilities for young people”66 “Recommendations: R1 - Whilst there is a perception that the district is well provided for in terms of open space, distribution is sporadic and there are local deficiencies across all typologies. Therefore, decisions related to the protection of

65 Pages 11-14, Appendix 1, Update on the Joint Health and Wellbeing Strategy for 2013-2016, Devon Health & Wellbeing Board, Sep 2013 66 Page 120, para. 7.3, East Devon Open Space Study for EDDC, Belap/JPC, 2011 Rockbeare NP Strategic Framework page 61 open space need to be considered at a local level, and in close consultation with the local community and through neighbourhood plans. R2 - Sites which are critical to avoiding deficiencies in quality, quantity or access should be protected unless suitable alternative provision can be provided. R3 - Sites which have nature conservation, historical or cultural value should be afforded protection, even if there is an identified surplus in quality, quantity or access in that local area. R4 - There is an under supply of facilities for young people across the district. Loss of any existing provision should be avoided, unless equivalent alternative new provision can be provided. R5 - All sports grounds and playing fields, including those on education sites and identified as being of ‘limited access’ in this study (typically those owned or on long leases to clubs but which meet a recognised community need), should be afforded protection. Redevelopment or reassignment to another open space use should only be considered if: · there is an identified overall surplus of open space and surplus of that typology in the local area and locality, · alternative equivalent provision can be made or an acceptable mitigation package developed, · the development results in an over-riding community benefit · Sport England are consulted and satisfied that the proposals meet their current policy. · A relevant and valid playing pitch strategy identifies a surplus of provision. R6 - There is a significant supply of semi-natural greenspace across the district. It is unlikely that any of this is ‘surplus to requirements’ as it is largely protected; however, it does offer the opportunity to provide alternative provision, e.g. the creation of natural play areas, BMX tracks and signed routeways where there is an existing under supply of these facilities. These opportunities would need to be considered on a site by site basis, due to the sensitivity of biodiversity on some sites. R7 - Develop a pilot project within one local community such as a ward or parish (for example, where significant growth is planned) to develop a neighbourhood plan which incorporates a proactive approach to green space planning which will consider possible relocation of open space sites, together with new and improved provision. R8 - The study makes recommendations for improving the quality of open space across the district. However, a long term strategy for achieving improvements is required which should be delivered through neighbourhood plans. R9 - Priorities for improvement include the enhancement of the existing provision for children and young people. R10 - Management plans should be developed for parks and recreation grounds and outdoor sports space. These priorities should be identified through neighbourhood plans, and could be delivered by the local community. R11 - Developer contributions should be made accessible across all typologies (with the exception of private golf courses). R12 - New provision of open space may be required as part of new development in order to meet any deficiencies in provision in both quantity and access within a parish within which the development takes place. Where on site provision is required, it should be provided in line with the proposed open space standards. Where on site provision is deemed impractical, or not required, off site contributions will be required to meet the quantity, access and quality standards where possible. R13 - A developers’ contribution fund should be established to target funding across a range of facilities (to be guided in the long term by a green-space strategy and neighbourhood plans). R14 - The priorities for new provision are for: · children and young people, particularly young people’s space; · the creation of green routes and cycleways linking new and existing provision (see R15) and · new and improved playing pitch provision in certain areas. It is recommended that a detailed playing pitch study be undertaken to provide a robust and valid assessment of supply and demand. R15 - Future Local Development Plan documents and neighbourhood plans should consider the opportunities for creating additional routes for recreation and commuting by foot and cycle in both urban and rural areas across East Devon.

Rockbeare NP Strategic Framework page 62

The creative application of the informal open space and the semi-natural green space components of the proposed overall standard in respect of new development should be explored.”67

“The different types of open space considered in the report and suggested standards for rural areas are summarised below (hectares/1000) Allotments 0.30 Amenity Open Space 0.30 Outdoor Sport - Pitches (open access) & Outdoor Sport - Pitches (LA: limited access) 1.50 Parks and Recreation Grounds 0.40 Play Space - Children 0.05 Play Space - Youth 0.05 Natural and Semi Natural (accessible) 1.00”68 “Allotments - Proposed Standards Suggested increase in level of provision highlights individual town and parish variations. Proposed standards are: 0.25 ha/1000 in urban areas and 0.30 ha/1000 in rural areas. Accessibility is very local with a distance threshold of up to 10 minutes travel time in urban areas and up to 15 minutes in rural areas. Amenity Open Space - Proposed Standards Proposed standards are for 0.35 ha/1000 in urban areas and 0.30 ha/1000 in rural areas. The increase from the current level of 0.31 ha/1000 to 0.35 ha/000 in urban areas may appear large, but this typology offers opportunities to create imaginative open spaces for a wide range of informal recreation and play activity, and in a variety of settings. They can serve a variety of functions dependent on their size, shape, location and topography. Amenity open spaces are frequently used. Demand has been noted for more and the desire is for very accessible areas, and thus the accessibility standards are set at 10 minutes travel time in both urban and rural areas. It should be East Devon’s long-term aim to meet the accessible standards as set by ANGSt69. Education – Play and Sport - Proposed Standards A standard for this typology is not appropriate and therefore has not been proposed. The strategy recommendations will relate to the need to safeguard such provision and encourage its wider use for the local community wherever possible. Outdoor Sport - Proposed Standards Fixed sports facilities such as tennis courts and bowling greens are better analysed in terms of numbers of facilities per head of population, rather than in area (ha). Analysis should look at how many facilities there are of each type of provision per head of population and then consider access to that typology. The higher standard of 1.5 ha/1000 for rural areas reflects their additional informal recreation role. In both rural and urban situations, a distance threshold of 600m, or up to 15 minutes walking time is proposed. Parks and Recreation Grounds - Proposed Standards The proposed standard is 1.00 ha/1000 in urban areas, and 0.40 ha/1000 in rural areas. The accessibility standard given is 10 minutes’ travel time in both urban and rural areas. Play Space - Proposed Standards A level of provision for play space in urban areas is proposed at 0.06 ha/1000 and rural areas at 0.10 ha/1000. An overall increase from existing provision to 0.05 ha/1000 is proposed for young people In all consultation, facilities for teenagers and young people was the most requested type of open space provision. Consultation also showed that in rural areas, people were prepared to travel for longer (11-15 minutes) than in urban areas (10 minutes) to children’s play space.

67 Pages 130-134, East Devon Open Space Study for EDDC, Belap/JPC, 2011 68 Page 121, para 7.4, East Devon Open Space Study for EDDC, Belap/JPC, 2011 69 ANGst = accessible natural green space standard Rockbeare NP Strategic Framework page 63

Therefore, the proposed accessibility standards for play space – children are 10 minutes travel time in urban areas and 11-15 minutes in rural areas. For play space for young people the accessibility standard is 11-15 minutes in both urban and rural areas. Natural and Semi Natural Green Space - Proposed Standards A proposed standard would only be applicable in an area where there is no current provision, or where it is used as a basis for a contribution from new housing. The proposed standard of 1.00 ha/00 is set for a minimum target in such situations across the district. Accessibility in both urban and rural areas is proposed as a distance of 800 metres (straight-line), or 15-20 minutes walking time”70

East Devon Open Space Study 2014 On the subject of assessing planning application for residential development and the provision of open space, the policy document states the following: “On-site / Off-site As a guide, developments will be expected to provide open space on-site through a Section 106 Agreement in line with the following thresholds (this is an adaptation and slight variation of Table 5 in Appendix A to the Open Space Study): 9 dwellings or less will not be required to provide any specific open space typologies on-site, however developers may choose to make such provision. 10 – 49 dwellings will be required to provide amenity open space on-site as per the open space standards. 50 – 199 dwellings will be required to provide amenity open space, and children’s and youth play space on-site as per the open space standards. 200+ dwellings will be required to provide for all open space typologies on-site as per the open space standards. It may be necessary or desirable to provide more of certain typologies and subsequently less of others depending on site specifics. In some cases the Council may consider it reasonable to have no open space provision on-site so long as an adequate off-site contribution is provided. Where financial contributions are made through Section 106 Agreements/Unilateral Undertakings towards off- site open space then they will be pooled with money from other developments and spent on relevant open space projects within the Parish that the development has taken place.”71

East Devon Playing Pitch Strategy 2015 The East Devon Playing Pitch Strategy was adopted by the district council in 2015. Its Vision is “to ensure that sufficient pitches are provided of a good quality and which support the needs of each sport and club around East Devon and take account of cross-border issues within the city of Exeter. This provision should be sufficient and flexible to deal with current and projected increases in demand.” The key general issues it seeks to address are:  Provision of youth and mini football and rugby pitches is particularly poor  Management and maintenance of many grounds is poor due to lack of funds  Distinct lack of access to all-weather floodlit training facilities throughout the district and need for at least 2 full-size 3G AGPs  Number of Exeter based clubs playing in East Devon  In general, in addition to existing stock there is a district-wide need for 4x adult football pitches, 6x youth 11v11 pitches, 4x 9v9 pitches, 6x mini soccer  Conservative estimate there is a district-wide need for two to three cricket grounds in East Devon  Given aspirations and current supply, shortage of good quality grass pitches will restrict rugby development

70 Page 121-123, para 7.5-7.32, East Devon Open Space Study for EDDC, Belap/JPC, 2011 71 Page 38, paras 7.1-7.3, East Devon Open Space Study Review, East Devon DC, June 2014 Rockbeare NP Strategic Framework page 64

Rockbeare Playing Fields feature in the strategy. They are recorded as having pitches of “poor quality and at capacity”. There is one specific policy (OT15) for the Playing Fields: “Support clubs and trust in improving maintenance on site and filling in dips causing problems with evenness to bring quality up to “standard” and therefore increase capacity.”

The general policies and the issues they relate to are:

Issue Policy Open access, dogs walked on the pitch Support installation of signs to discourage walking dogs on pitch and dog bins to increase likelihood of owners picking up. Also explore possibility of dog exclusion areas in some cases. Shared sites e.g. football over-marking Ensure the clubs sign up to a code of conduct to ensure the cricket outfield quality of the cricket outfield is respected. Clubs struggle to keep up with maintenance Explore the possibility of establishing a shared maintenance or do as much as they would like to due to pool for hire which may be cheaper for clubs in long run. restricted funds Few schools with secured community use Work to secure long-term community use agreements with schools that have suitable pitches. Support schools with suitable pitches in development of facilities to allow secured community use (e.g. Changing facilities accessible from outside school building). Several grounds do not have changing Support clubs in development of ancillary facilities where provision possible. If a site is not appropriate for such facilities, consider encouraging the club to move to new premises that could be developed. Football pitch congestion on Saturday Actively lobby leagues to spread play over the weekend or afternoons due to general shift to Saturday stagger kick-offs to free up pitch capacities. teams away from Sunday teams Generally, district wide projected increase in Explore possibility of developing of a junior football hub within requirements for youth 11v11, youth 9v9 and East Devon to cater for the needs of multiple youth clubs from mini football pitches but no increase in the area, help increase club and site viability and demand for adult pitches. maintenance. Little 'joined-up thinking'. Steering group to continue meeting once per year to keep dialog going and increase joined-up thinking. Management and maintenance of grounds Encourage and support clubs in becoming more self-sufficient leased to clubs is variable and often poor. in a world with less public subsidy. In some cases, this may mean encouraging ground sharing or fundraising or increasing membership subs. Many cricket sites do not have long term Work with clubs and landowners to help secure tenancies and security of tenure therefore allow clubs to plan for the future. East Devon Youth League hopes to set up a Encourage female participation in cricket and facilitate this girl’s cricket section next year where necessary by supporting clubs in providing appropriate changing facilities etc. No mini rugby pitches in East Devon despite Explore the potential for laying out additional mini rugby large-scale youth participation pitches in Exmouth, Sidmouth and Honiton to allow close links with existing clubs. Need for a minimum of two full size 3G AGPs See Action Refs EF.16, EX.18 and SI.6 in East Devon in addition to the planned full size provision at Axminster and converted half size at Exmouth Community College

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East Devon is a priority area for Rounders Work with Rounders England to identify demand and need for England in developing the sport facilities. General trend towards small sided soccer in Explore possibility of developing a floodlit, 5 -a-side 3G hub adult football participation. venue in East Devon's West End to cater for this kind of demand. Most cities around the UK now have centres similar to this with pitches available for hire however Exeter does not as yet. A facility in the West End could capture both Exeter and East Devon demand for such a facility. Such a facility would be in addition to the main 3G needs uncovered by this strategy. East Devon Hockey Club are playing in Explore whether East Devon Hockey Club would be interested Exeter. in relocating back to East Devon if suitable facilities existed. East Devon Hockey Club want to set up more boys and junior mixed teams but lack of facilities in Exeter is restricting this. In general, in addition to existing stock See Action Refs G.8, EF.2,10,15, AX.4,11,14, EX.6,19,20,21,27, suggest the need for an additional: 4x adult HO.5,13,18,19, OT.8,19,20,21, football pitches; 6x 11v11 pitches of different SE.3,4,12, and SI.2 sizes; 4x 9v9 pitches; 6x mini pitches (7v7 and 5v5). Conservative estimate, given the basic trend See Action Refs EF.15, EX1,2,4,11, OT.11,12,13, SI.18 of greater participation for women and girls and junior teams, the requirement is for two to three cricket grounds within East Devon

East & Mid Devon Community Safety Partnership Plan 2012-15 “Local Action Groups - Promote and Develop Over a number of years, the Local Action Groups in both districts have proved their worth in helping to reduce crime, disorder and anti-social behaviour by acting as a multi-agency problem solving mechanism and opportunity to exchange best practice. Although East and Mid Devon are very safe places to live, by working in Partnership and meeting to discuss local issues, the benefits are clear to see as there has been a year on year reduction in overall crime and anti-social behaviour.”72

Project Title Action Planned local initiative by To identify and deliver one targeted activity via each Local Action Group Local Action Groups (LAG) to impact on local confidence in each geographical LAG area. Local agencies to identify and promote positive activities regarding Positive News Stories & crime & anti-social behaviour (ASB), resulting actions, preventative Information on Agency Actions action, and self-help. Promote the Activities of To identify and promote LAG activities to impact on local confidence in the Local Action Groups each geographical LAG area. To improve communications with Parish Councils and provide Engagement and Improve Links suggestions on how they might engage in more pro-active community with Parish Councils initiatives to support To identify communities that have experienced an increase in acquisitive Support & Increase crime and promote Neighbourhood Watch in order that the community Neighbourhood Watch Groups takes action for self-protection.

72 Page 10, Plan 2012-15, East & Mid Devon Community Safety Partnership, 2012 Rockbeare NP Strategic Framework page 66

Police and Crime Plan 2014/17 The Police and Crime Commissioner’s six priorities for Devon, Cornwall and the Isles of Scilly are: 1. To make our area a safer place to live, work and visit – reducing the likelihood that people will become victims of crime 2. To reduce the crime and harm caused by the misuse of alcohol 3. To make every penny count in protecting policing for the long term…. 4. To promote an effective criminal justice system for our area, delivering a high quality service for victims, witnesses and society 5. To deliver a high quality victim support service across our area 6. To encourage and enable citizens and communities to play their part in tackling crime and making their communities safer As regards priority number 6 the Plan states: We must: • Secure active involvement by citizens and communities in policing • Engage with existing volunteering schemes and organisations • Inspire communities to instigate their own safety initiatives • Work with Devon & Cornwall Police to create new volunteering opportunities • Consider start-up grants for community projects that promote community action • Encourage businesses to work more closely with the police to help deter and tackle crime

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East Devon Local Plan 2013-2031 The Local Plan states that “East Devon has a healthy living environment and healthy population. Facilities in the District's towns (and some larger villages) are good and crime levels are low. We have good schools and friendly people.” It has a key objective to ensure that “the infrastructure of both physical and service elements is adequate for the population in each locality ……. this especially includes water and sewage, food availability, schools, medical and social care” This is reflected particularly in Strategy 4.

Strategy 4 - Balanced Communities: (extract) By balanced communities we mean that in any area or neighbourhood there is a match between jobs, homes, education, and social and community facilities. Ideally these should complement the range of ages of the resident population and have appropriate access for those with disabilities. Key components of a balanced community include: ……………. b) Securing social, educational, green infrastructure and health and community facilities - these facilities play a central part in community life and new housing should help secure their provision and keep the community vibrant and viable by making financial contributions towards their provision or by providing such facilities on site where necessary ………

The community of Rockbeare Parish could benefit from the new community facilities that will be provided at nearby Cranbrook. Local Plan Strategy 12 states:

Strategy 12 - Development at Cranbrook: (extract) Land at Cranbrook….. is allocated for development and will be developed as a modern market town. Mixed use development, to provide housing (including affordable housing) social and community facilities, recreation and education facilities and jobs will occur on a phased basis … Working with our partners we will promote Cranbrook, up to 2031 to accommodate: ……… 4. Town Centre - The town centre of Cranbrook will provide a focal point for retail, business and leisure activities and will be designed to create a vibrant day and night-time economy and this will be complemented by a series of smaller neighbourhood centres. 5. Social and Community and Education Facilities - Cranbrook will accommodate a full range of social, leisure, health, community and education facilities (including new schools) to meet the needs of all age groups that will live at the new town……

There are a number of development management policies in the Local Plan that relate to community facilities and recreation spaces:

RC1 - Retention of Land for Sport and Recreation: Proposals that would result in the loss of open space currently or previously used for recreation and/or sports uses, play areas or playing fields will not be permitted unless: 1. Alternative provision of equivalent community benefit is made available and will be appropriately laid out by the applicant as a replacement. Or 2. Sports and recreational facilities can best be retained and enhanced through the redevelopment of a small part of the site. Or 3. Locally There is an excess of public open space, children's play areas or sports pitch provision in the area as the case may be.

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RC2 – New Open Space, Sports Facilities and Parks: Within or adjoining urban or built-up areas, permission will be granted for new open space areas, allotments, sports facilities and parks, the accommodation of the visual and performing arts, and the upgrading or enhancement of existing facilities provided the following criteria are met: 1. They do not unduly affect the character and appearance of the area and the visual and physical amenities enjoyed by adjoining residential areas. 2. They are accessible by public transport, bicycle and on foot. 3. Appropriate car and cycle parking is provided. 4. The proposed road access to the site provides for safe exit and entry and the local road network can safely accommodate the extra traffic the proposal would generate. 5. The facilities are located without detriment to the best and most versatile agricultural land, nature conservation interest and the conservation of areas of landscape, scientific, archaeological or historic interest.

RC3 - Allotments: Permission will not be granted for proposals involving the loss of allotments for other development unless there is insufficient demand for allotment use or appropriate alternative sites can be provided.

RC4 - Recreation Facilities in the Countryside and on the Coast: Planning permission will be granted for outdoor recreation facilities in the countryside and on the coast provided that the nature of the activities undertaken or the space requirements of the proposal require a countryside or coastal location and: 1. The facilities or development proposals are in scale with the character, environmental characteristics and setting of the area and do not conflict with countryside, nature or landscape policies, nor detract from the amenities of the area. 2. The proposals allow for safe access and discreet parking arrangements, particularly in environmentally sensitive areas, and do not result in the loss of or cause unacceptable disruption to existing public rights of way. 3. On site facilities should be appropriate to meet the needs of the proposal and links with adjacent footpaths and bridleways should be suited to any proposed site uses. Where indoor areas are required use should be made of existing buildings. Any new buildings and necessary extensions should be limited in scale and be in close proximity to existing groups of buildings or an existing settlement. Where it is proposed to extend or intensify an existing use the cumulative effect of the use will be considered in the interests of the character of the area.

RC5 - Community Buildings: New community facilities and buildings will be accommodated on sites that lie within or adjacent to Built-up Area Boundaries. Where residential development intensifies the need for community buildings a developer contribution towards their provision or the upgrading of existing buildings will be sought.

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RC6 - Local Community Facilities: Proposals for new facilities, extensions and/or alterations to existing facilities to serve the local community will be permitted on sites within or adjoining Built-up Area Boundaries provided they meet the following criteria in full: 1. The proposal would be compatible with the character of the site and its surroundings and in villages with the rural character of the settlement. 2. The proposal will be well related to the built form of the settlement and close to existing development. 3. The site is accessible by a variety of types of transport, including walking and cycling and the amount of traffic generated by the proposal could be accommodated on the local highway network without harming road safety. 4. The proposal would not be detrimental to the amenity of neighbouring residents by reason of undue noise or traffic. In the countryside, outside defined Built-up Area Boundaries, proposals will only be permitted if they meet the above criteria and a need for the facility has been proven. Planning Permission will not be granted for developments that would result in the loss or closure of a community facility unless the community facility is no longer needed or is not viable or an alternative facility of equal or higher value is being provided.

RC7 - Shared Community Facilities: In order to ensure that land is used efficiently and effectively, to ensure that facilities become a vibrant focus for community activities and to enable access by a wide section of the community, proposals for new community facilities, both public and private, will be expected to be capable of dual-use, as considered appropriate by the community and unless local circumstances indicate that dual use is not appropriate. Proposals for new community facilities in villages and rural areas should share existing premises wherever possible.

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Transport and Accessibility Introduction Transport and accessibility is not wholly the responsibility of the planning system and not always the subject of planning policies. Everyday matters such as road maintenance and control of vehicle access to certain roads, for example, are usually the responsibility of the Highways Authority, where planning permission is not usually required. Likewise, the frequency of bus services is not something over which planning policy can have much, if any, influence in rural areas. Other things such as the erection of mobile phone masts can often be the subject of permitted development rights, particularly outside of protected areas. Neighbourhood planning should explore the degree to which local policy can affect change to address issues or concerns, and adapt and improve facilities and services through the application of planning policy as development proposals are submitted.

Strategic Written Evidence The following sections summarise the main strategic documents and key policies which will need to inform the development of the Neighbourhood Plan. Other key documents are ‘signposted’ and should be considered if necessary to help to fill gaps in contextual understanding, following completion of local research.

National Planning Policy Framework Section 4 of the National Planning Policy Framework (NPPF) focuses on policy which seeks to promote sustainable transport. Paragraph 29 states that “Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives. Smarter use of technologies can reduce the need to travel. The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas.”73

Transport policy guidance also sets out the relationship between appropriate locations and scales of development and transport. “Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport.”74

The NPPF emphasises the need for plans and decisions on development to be mindful of the importance of accessibility in relation to scale and infrastructure. “Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. However, this needs to take account of policies set out elsewhere in this Framework, particularly in rural areas.”75

It also sets out criteria to apply to the practicalities that new development should accommodate: “Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. Therefore, developments should be located and designed where practical to • accommodate the efficient delivery of goods and supplies • give priority to pedestrian and cycle movements, and have access to high quality public transport facilities • create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones • incorporate facilities for charging plug-in and other ultra-low emission vehicles

73 Paragraph 29, NPPF, Department for Communities and Local Government, 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 74 Paragraph 30, NPPF, Department for Communities and Local Government, 2012 75 Paragraph 34, NPPF, Department for Communities and Local Government, 2012 Rockbeare NP Strategic Framework page 71

• consider the needs of people with disabilities by all modes of transport”76

Paragraph 39 sets out the criteria to be applied when local authorities seek to set parking standards for development. • “If setting local parking standards for residential and non-residential development, local planning authorities should take into account: • the accessibility of the development • the type, mix and use of development • the availability of and opportunities for public transport • local car ownership levels • an overall need to reduce the use of high-emission vehicles”77

The NPPF also sets out the Government’s policy in relation to telecommunications in section 5 of the NPPF, ‘Supporting high quality communications infrastructure’ stating that high quality communications infrastructure is essential for sustainable economic growth. Paragraphs 43 and 44 state that: “In preparing Local Plans, local planning authorities should support the expansion of electronic communications networks, including telecommunications and high speed broadband. They should aim to keep the numbers of radio and telecommunications masts and the sites for such installations to a minimum consistent with the efficient operation of the network. Existing masts, buildings and other structures should be used, unless the need for a new site has been justified. Where new sites are required, equipment should be sympathetically designed and camouflaged where appropriate. Local planning authorities should not impose a ban on new telecommunications development in certain areas, impose blanket Article 4 directions over a wide area or a wide range of telecommunications development or insist on minimum distances between new telecommunications development and existing development. They should ensure that: • they have evidence to demonstrate that telecommunications infrastructure will not cause significant and irremediable interference with other electrical equipment, air traffic services or instrumentation operated in the national interest; and • they have considered the possibility of the construction of new buildings or other structures interfering with broadcast and telecommunications services.”78

National Planning Practice Guidance The National Planning Practice Guidance79, which amplifies the policies in the NPPF, has a section on travel plans, transport assessments and statements in decision making. This provides detail on what these processes and documents are and how to develop them, which is not repeated here.

Devon Local Transport Plan 2011-2026 The Devon and Torbay Local Transport Plan sets out the transport policies and proposals for the administrative areas of Devon County Council and Torbay Borough Council. LTP3 is not a statutory planning document, but it is a statutory requirement placed upon Transport Authorities to produce an LTP. It sets out the transport strategies for Exeter, Torbay and the market and coastal towns and rural Devon and in doing so aligns with the plans and proposals in the Local Plan for East Devon.

The Vision Devon & Torbay’s transport system will offer business, communities and individuals safe and sustainable travel choices. The transport system will help to deliver a low carbon future, a successful economy and a prosperous, healthy population living in an attractive environment.

76 Paragraph 35, NPPF, Department for Communities and Local Government, 2012 77 Paragraph 39, NPPF, Department for Communities and Local Government, 2012 78 Paragraphs 43-44, NPPF, Department for Communities and Local Government, 2012 79 See http://planningguidance.planningportal.gov.uk/blog/guidance/rural-housing/how-should-local-authorities-support-sustainable- rural-communities/ Rockbeare NP Strategic Framework page 72

Over the next 15 years Devon & Torbay will need to diversify and grow the economy, but just as importantly develop a low carbon transport system that offers choice and encourages sustainable travel behaviour. To achieve Devon & Torbay’s vision the strategy has five key objectives:  Deliver and support new development and economic growth  Make best use of the transport network and protect the existing transport asset by prioritising maintenance  Work with communities to provide safe, sustainable and low carbon transport choices  Strengthen and improve the public transport network  Make Devon the ‘Place to be naturally active’

The parish is most affected by the policies relating to Exeter. Key Elements of the Exeter Strategy are as follows: “Improve access to the city:  Improve the comfort, journey reliability and cost of rail travel by lobbying the train operators, Network Rail and DfT  Develop a new park & ride to the west of the city and build on the success of the current sites  Deliver the hierarchy of cycle connections between key locations  Complete the Exe Estuary Cycle Route  Improve the walking environment  Improve bus journey times with a particular focus on the city centre  Improve parking enforcement  Develop a traffic management strategy focused on key corridors into the city Enable and support smarter travel  Support a continued programme of travel planning with retail, leisure, schools and employers making it easier for people to walk, cycle, use public transport or car share, and provide better information about transport options  Improve access to education and training by working in partnership with the University of Exeter, Exeter College and schools  Ensure that all users of the transport system in Exeter can travel safely by raising awareness, maintaining high safety standards and by using high quality design in all transport schemes  Support expansion of car clubs  Support continued provision of transport schemes for people with disabilities Deliver the east of Exeter development:  Assist in the delivery of the key access roads and rail station  Develop a long term area wide travel plan with parking charges  Develop high quality bus and cycle connections Deliver major developments within Exeter:  Develop an area wide travel plan and consider charging for parking  Enhance the walking and cycling links between the city centre and the main development areas and other key destinations  Review the traffic management of key junctions Protect Exeter as a gateway:  Support low cost improvements to the trunk road network to improve safety and network resilience  Work with the train operators to improve connections to London and the rest of the UK  Improve the arrival experience at key transport interchanges”80

The Vision for the market and coastal towns and rural Devon strategy is “Devon’s market and coastal towns will be better connected to their closest urban area, for the journey to work, access to health care, education, training, leisure and retail. Within the towns, people will be supported to make the most of the existing road, rail,

80 Local Transport Plan 3, Devon and Torbay Strategy 2011 – 2026, Devon CC, Apr 2011 Rockbeare NP Strategic Framework page 73 bus networks and cycle and footpaths for local trips. This will promote more active lifestyles, better accessibility and reduce local congestion.”81

The transport priorities for the market towns and rural parts of Devon focus on five key things: • “Assist in supporting existing and future development of the towns • Work with the community to demonstrate a low carbon approach to travel • Improve accessibility by developing a core bus and rail service supported by community transport • Make Devon ‘the place to be naturally active’ through investment in the leisure network • Develop an approach to parking policy which supports the vitality of town centres”82

The majority of the actions and capital interventions relate to the market towns, although links with rural hinterlands of the market towns are highlighted.

East Devon Local Plan 2013-2031 The new Local Plan sets the strategic context and statutory development plan strategic policies with which the neighbourhood plan needs to be in ‘general conformity’.

Strategy 5B is the principle ‘high level’ policy relating to transport.

Strategy 5B – Sustainable Transport Development proposals should contribute to the objectives of promoting and securing sustainable modes of travel and transport. Development will need to be of a form, incorporate proposals for and be at locations where it will encourage and allow for efficient, safe and accessible means of transport with overall low impact on the environment, including walking and cycling, low and ultra-low emission vehicles, car sharing and public transport.

Strategy 6 ‘Development within Built-up Area Boundaries’ is relevant given criteria to new development in these locations to not impair traffic flows.

Strategy 6 - Development within Built-Up Area Boundaries: (extract) Built-up Area Boundaries are defined on the Proposals Map around the settlements of East Devon that are considered appropriate through strategic policy to accommodate growth and development. Within the boundaries development will be permitted if:…………. 5. It would not impair highway safety or traffic flows………….

Strategy 30 focuses on the importance of communication links to improve accessibility within the context of inward investment opportunities and local benefits.

Strategy 30 – Inward Investment, Communication Links and Local Benefits Procurement: (extract) Support will be given to promoting inward investment by businesses and service providers and to improvements of both transport links and electronic media links……………….

It is worth noting Strategy 50 ‘Infrastructure Delivery’ in the context of delivering transport infrastructure. The policy refers to the development of the Infrastructure Delivery Plan and Community Infrastructure Levy (CIL).

81 p.86, Devon and Torbay Local Transport Plan 3, Devon County Council and Torbay Borough Council, 2011 82 p.89, Devon and Torbay Local Transport Plan 3, Devon County Council and Torbay Borough Council, 2011 Rockbeare NP Strategic Framework page 74

Part 2 of the Local Plan sets out policies which will be applied during the development management process, i.e. when considering applications for planning permission. There are 12 policies in total of which the following are particularly relevant:

TC2 - Accessibility of New Development: New development should be located so as to be accessible by pedestrians, cyclists and public transport and also well related to compatible land uses so as to minimise the need to travel by car. Where proposals are likely to attract large numbers of visitors they must be accessible by public transport available to all sectors of the community. Development involving the creation of public open space, car parking area, highways and other areas to which the public have access, must provide adequate provision for persons with reduced mobility.

TC4 - Footpaths, Bridleways and Cycleways: Development proposals will be required to include measures to provide, improve and extend facilities for pedestrians and cyclists commensurate with the scale of the proposal. Footways and routes for pedestrians and cyclists within and through new development schemes will be encouraged. These measures may include both shared and exclusive surfaces to provide safe, convenient and attractive routes, and must be designed to take account of the needs of persons with restricted mobility. Wherever possible the opportunity should be taken to join, upgrade and extend existing or proposed networks. Development which would result in the loss, or reduce the convenience or attractiveness of an existing or proposed footpath, cycleway or bridleway, will not be permitted unless an acceptable alternative route is provided.

TC7 - Adequacy of Road Network and Site Access: Planning permission for new development will not be granted if the proposed access, or the traffic generated by the development, would be detrimental to the safe and satisfactory operation of the local, or wider, highway network. Where new development requires off-site highway improvements any planning permission granted will be subject to a planning obligation requiring these works to be carried out either by the developer, or through an agreement with the Highway Authority to ensure that: 1. The required highway improvements are included in, and, will be constructed as an integral part of the development or are part of a programmed improvement scheme to be undertaken by the Highway Authority. In the case of programmed schemes the planning permission will be subject to a condition delaying its implementation until the highway improvements have been carried out, unless otherwise agreed by the Highway Authority. 2. The applicant is in a position to secure the implementation of the required highway improvements.

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TC9 - Parking Provision in New Development: Spaces will need to be provided for Parking of cars and bicycles in new developments. As a guide at least 1 car parking space should be provided for one bedroom homes and 2 car parking spaces per home with two or more bedrooms. At least 1 bicycle parking space should be provided per home. In town centres where there is access to public car parks and/or on-street parking lower levels of parking and in exceptional cases where there are also very good public transport links, car parking spaces may not be deemed necessary. All small scale and large scale major developments should include charging points for electric cars.

TC11 - Roadside Service Facilities: Any proposal for a roadside service facility along a trunk road and motorway will only be granted planning permission if it meets the following criteria in full: 1. It offers a range of essential services appropriate to the route it serves. 2. It is appropriately spaced in relation to other roadside service facilities. 3. Access to the trunk road or motorway including any connection to the local road network, and the internal circulation is satisfactory. 4. It is sited, designed and landscaped to minimise impact on the character and appearance of the landscape. 5. It does not cause a material loss of amenity to nearby residents. 6. It should be capable of serving traffic travelling in both directions on the route. 7. The design of new or improved accesses or other necessary trunk road works should be sufficient to accommodate anticipated traffic flows up to 15 years after the opening of the development. 8. Proposals for roadside facilities along trunk roads that are the subject of major improvements will not be granted planning permission unless they will be compatible with the future highway design. New roadside service facilities along other routes constituting the high quality road network should be located on sites within the identified Built-up Area Boundaries, and meet criteria 1, 2, 3 and 5 above. Upgrading of existing facilities on this network will need to be compatible with criteria 1, 2, 3, and 5 above.

TC12 – Aerodrome Safeguarded Areas and Public Safety Zones: The outer boundary of the aerodrome safeguarded areas and the Public Safety Zones for Exeter International Airport are shown on the Proposals Map. Within these areas planning permission will not be granted for development that would prejudice the safe operation of protected aerodromes or give rise to public safety concerns. Planning permission will not be granted for developments in the vicinity of an airport (or that could impact on safe operation of aeroplanes) that would compromise air safety by creating physical obstructions that could interfere with flight paths or navigational aids. Permission will not be granted for developments that will unduly prejudice future development or expansion programmes or potential at Exeter airport.

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The Local Plan also includes policy TC1, which relates specifically to electronic communication.

TC1 – Telecommunications: In considering applications for the installation of telecommunications systems, the Council will have regard to the following criteria: 1. The development should be sited, well designed and landscaped to minimise the visual impact on the surrounding area while taking due account of operational efficiency. 2. The development will not adversely affect the amenity of nearby residents or significantly impact upon their enjoyment of their homes 3 New antennas will, wherever technically and legally possible, share existing masts or be erected on existing buildings or other structures. Where the sharing of a mast will require its extension the District Council may alternatively consider the sharing of the site. 4. The development will not have an adverse effect on areas designated for their landscape or nature conservation value. 5. The development will not have a significant impact on radio or television reception which cannot be mitigated. 6. The development will not have a serious adverse effect on the character, appearance and setting of a conservation area, listed building, historic park or garden, ancient monument or site of archaeological interest. 7. The development will have no adverse effect on aviation safety. 8. There has been consultation with organisations with an interest in the proposed development – most notably any nearby schools and colleges or technical businesses. Proposals to erect masts or towers will not be permitted unless the applicants can demonstrate that they have attempted to use sites with low environmental impact or share masts and have been unsuccessful. Any planning permission granted will be conditioned so that when any facility ceases to be used, becomes obsolete, or falls into disrepair, the demolition and removal of all works undertaken, both above and below ground, and the reinstatement of the site to its original condition or to an agreed specification, will be required.

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Employment National Planning Policy Framework “Local planning authorities should:  Support existing business sectors, taking account of whether they are expanding or contracting and, where possible, identify and plan for new or emerging sectors likely to locate in their area. Policies should be flexible enough to accommodate needs not anticipated in the plan and to allow a rapid response to changes in economic circumstances  plan positively for the location, promotion and expansion of clusters or networks of knowledge driven, creative or high technology industries  identify priority areas for economic regeneration, infrastructure provision and environmental enhancement  facilitate flexible working practices such as the integration of residential and commercial uses within the same unit Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose.”83

In terms of retail, the NPPF focuses on the role of town centres and a sequential test being applied to retail development, with a focus on town centres first and then edge and out of town development. With regard to areas outside of town centres, the focus is on proposals being subject to an impact assessment. In rural areas, the focus is very much as set out above in terms of the role in relation to the rural economy but also in relation to the sustainability of services and facilities reflected elsewhere in the NPPF and summarised in other topic areas in this report.

Devon Strategic Economic Plan 2014 The latest strategy from the Local Economic Partnership (LEP) recognises the predominance of rural areas in Cornwall and Devon whilst justifying an emphasis on the economic development focus on the urban areas and their population. “Our area is predominantly rural with over 90% of the land area designated as such. However, over 40% of the population live in urban areas and plans for urban expansion are being realised.”84

“Our business population spans both the rural and urban environment on a roughly 50:50 basis and analysis shows that with the exception of agriculture and land-based industries, the sector profiles are not so different. That said, our evidence to support our Rural Growth Network, established that rural businesses tended to have differing needs. Our approach to business support measures will therefore be mindful of rural and urban need.”85

The Vision for Growth in the Devon Strategic Economic Plan is that- “Both our urban and rural economies will be vibrant and strong. Therefore, in tackling barriers to economic growth we want our approach to benefit both urban and rural people, places and businesses.”86 It does recognise the particular “the challenge to stimulate growth in both rural and urban areas whilst protecting and enhancing our outstanding natural environment.” 87

83 National Planning Policy Framework, HM Government, 2012 84 Page 7, Strategic Economic Plan 2014-2030 Final Submission: 31st March 2014, Heart of the SW LEP, Mar 2014 85 Page 9, Strategic Economic Plan 2014-2030 Final Submission: 31st March 2014, Heart of the SW LEP, Mar 2014 86 Page 14, Strategic Economic Plan 2014-2030 Final Submission: 31st March 2014, Heart of the SW LEP, Mar 2014 87 Page 16, Strategic Economic Plan 2014-2030 Final Submission: 31st March 2014, Heart of the SW LEP, Mar 2014 Rockbeare NP Strategic Framework page 78

With this in mind the strategy sets the following priorities for growth: “Our Priorities for Growth Creating the Conditions for Growth - Improving our infrastructure and services to underpin growth Infrastructure for growth: • Transport and accessibility • Digital infrastructure • Sustainable solutions for flood management • Energy Infrastructure Creating a favourable business environment • A simpler, more accessible, business support system, tailored to our needs o Improving access to finance o Stimulating enterprise and growth Creating a responsive environment, where businesses and individuals can reach their potential: • Skills infrastructure and facilities • Accessibility to education/employment (transport, careers advice and digital inclusion) • Employer engagement and ownership

Maximising Productivity and Employment Opportunities - stimulating jobs and growth across the whole economy The infrastructure and facilities to create more and better employment: • Enterprise infrastructure • Strategic employment sites • Unlocking housing growth Achieving more sustainable and broadly based business growth: • Reaching new markets (on-line, supply chains, public sector) • Globalisation (exports and inward investment) Increasing employment, progression and workforce skills. • Moving people into employment • Supporting people to progress to better jobs • Improving workforce skills

Capitalising on our Distinctive Assets - Utilising our distinctive assets to create opportunities for business growth and better jobs The infrastructure and facilities needed to support higher value growth: • Specialist marine sites • Science/Innovation infrastructure • Maximising our environmental assets Supporting higher value growth: • Innovation through Smart Specialisation • Building our capacity for innovation Creating a world class workforce to support higher value growth: • Enterprise and business skills • Technical and higher level skills development and retention • Maximising the skills and employment opportunities aligned to our transformational opportunities.”88

88 Page 10, Strategic Economic Plan 2014-2030 Final Submission: 31st March 2014, Heart of the SW LEP, Mar 2014 Rockbeare NP Strategic Framework page 79

Devon County Growth Strategy 2013-2020 “Summary of critical issues – barriers to growth Critical issue 1: Devon’s economy is performing poorly in terms of productivity Critical issue 2: Devon has a relatively skilled workforce however this masks significant differences at a District level Critical issue 3: Earnings are lower than average in most of Devon and link to housing affordability and relative poverty Critical issue 4: Devon has an opportunity to better exploit the assets it has for high value economic growth Critical issue 5: Devon’s towns and rural communities in more peripheral areas are falling behind Critical issue 6: Devon’s population is ageing rapidly – particularly in more rural areas Critical issue 7: Devon’s resilience to face environmental changes is being challenged.”89 The overarching vision for Devon is clearly stated in the Strategic Plan (2011-2015) ‘Backing Devon’: To improve the quality of life for the people who live, work and visit the county. The Strategic Plan also has a separate vision to create: A flourishing and balanced economy, with strong economic growth and high quality employment

In order to realise the vision, the evidence base points to 7 critical issues within the economy that need to be tackled. Our aim is to tackle these issues and by doing so, secure the following strategic outcomes: • A more productive economy • A higher wage economy • Employment opportunities for all and a workforce with the right skills for the future • A well connected county • A thriving business community90

Devon and Somerset Rural Growth Network The Rural Growth Network (RGN) is a key aspect of the County growth strategy. The aim of the RGN is to create a sustainable rural economy by developing a network of rural enterprise hubs. “Devon and Somerset Rural Growth Network (RGN) will also deliver a range of business support to encourage enterprise in the rural economy. Promoting growth in rural areas is recognised as a key issue for Devon and the RGN will provide support to businesses to enable them to assess their needs and to access appropriate help. Innovation will be promoted, alongside specialist support to family based businesses and women entrepreneurs.”91 Revenue Projects The LEP is also offering a range of business support packages to aid business growth within the rural areas of Devon and Somerset. The aim is to ensure that maximum benefit is gained from investment in new business premises. The Heart of the South West Business Support Service is a brand new service offering:  Access to a local business adviser  Inspiring events and workshops  Online business support community  Unique support for women’s led enterprises The Heart of the South West Business Support Service can benefit your business by helping you to:  Improve your marketing and boost sales  Identify opportunities to grow your business  Learn practical steps that can move your business forward  Keep up-to-date with business and technology trends  Improve cash flow, manage finances and source appropriate finance options

89 Page 9, A Strategy for Growth 2013 – 2020, Devon County Council, May 2013 90 Page 16, A Strategy for Growth 2013 – 2020, Devon County Council, May 2013 91 Page 20, A Strategy for Growth 2013 – 2020, Devon County Council, May 2013 Rockbeare NP Strategic Framework page 80

 Prioritise your plans for the future

East Devon Economic Strategy The last published Economic Strategy for the district of East Devon was in 2005. Whilst it may now be regarded as out-of-date its objectives did underpin the development of the Core Strategy and the Local Plan. Objectives “To promote communities strong enough to sustain healthy living, working and natural environments To foster productivity, innovation, skills development and ensure an adequate supply of employment land and premises To prioritise areas and sectors of greatest need”

East Devon Local Plan 2013-2031 The strategy documents quoted from above all contribute to the strategic framework in which the East Devon Local Plan has been develop. The Local Plan for East Devon is promulgated on the following; “Paragraph 21 of the NPPF suggests that local planning authorities should set out a clear economic vision and strategy for their area which positively and proactively encourages sustainable economic growth. The East Devon Local Plan in recognition of the issues in the local economy has highlighted four key objectives: • Improve average income levels. • Diversify the sectors where jobs can be found. • Improve local job opportunities. • Reduce the need to travel by car to secure work and jobs.”92

The following are the relevant strategy and policy statements taken from the Local Plan.

Jobs and Economic Growth “Issue: East Devon is an attractive environment for enterprise witnessed particularly by the number of thriving small businesses. We have a vibrant tourism industry and some high quality jobs particularly in the Western part of the District with good access to the Exeter work market too. As a District we have low unemployment rates but also lower paid jobs. Objectives a) Improve average income levels b) Diversify the sectors where jobs can be found c) Improve local job opportunities d) Reduce the need to travel by car to secure work and jobs”93

Rockbeare is situated close to East Devon’s major growth and development area. Strategy 9 of the Local Plan lists a number of important employment related schemes including: 1. Cranbrook - Major new East Devon market town; 2. Pinhoe - Mixed use, residential led development; 3. North of Blackhorse/Redhayes (Tithebarn Green/Mosshayne) – residential development; 4. Skypark - Substantial high quality business park; 5. Exeter Science Park - Research/technology employment site; 6. Exeter International Airport - Provision to be made for airport-related employment uses within operational site area. 7. Multi-modal Interchange - Facility for interchange of goods and distribution centre; and 8. Exeter Airport Business Park - Middle range business park providing for medium to smaller business uses.

Local Plan Strategy 12 proposes “the provision of up to 18.4 hectares of employment land shall be made throughout the town to provide a range of business spaces suitable for the needs of businesses as they develop

92 Page 28, Local Plan employment numbers East Devon DC, July 2013 93 Page 23, para. 4.1, The East Devon Local Plan, East Devon District Council, 2016 Rockbeare NP Strategic Framework page 81 and grow and to accommodate a range of employment opportunities for residents of Cranbrook and surrounding areas.”

The nearby international airport is the subject of two strategic policies that have employment-related consequences:

Strategy 18 - Future Development of Exeter Airport Business Park: To enable modest expansion of the Exeter Airport Business Park 5 hectares of additional land (over and above the Training Academy and hotel site) is allocated, for business/employment generating uses as shown on the Proposals Map. Highway improvements will be required in order to access this site and also to enhance general airport access. .

Strategy 17 - Future Development at or near Exeter International Airport: The Local Plan recognises the importance of airport expansion and encourages supporting infrastructure to provide for its direct airport related growth. It is recognised that many operational uses do not require planning permission and these developments, where compatible with safe and efficient airport operation and where they do not have adverse impacts on land within operational boundaries, will be supported. The Habitats Regulations require the Appropriate Assessment of any project where the likelihood of significant effects on European wildlife sites cannot be ruled out. Developments that are near to or could be affected by noise from the airport will not be allowed unless evidence is provided that current or futures users or occupiers of new dwellings, schools, open spaces or other sensitive uses will not be significantly adversely affected, taking proposed mitigations into account, by airport related noise.

Rockbeare residents could also benefit from the strategic employment policy for Cranbrook:

Strategy 12 - Development at Cranbrook: (extract) Land at Cranbrook …..is allocated for development and will be developed as a modern market town. Mixed use development, to provide housing (including affordable housing) social and community facilities, recreation and education facilities and jobs will occur on a phased basis. 3. Jobs - provision of up to 18.4 hectares of employment land shall be made throughout the town to provide a range of business spaces suitable for the needs of businesses as they develop and grow and to accommodate a range of employment opportunities for residents of Cranbrook and surrounding areas. Serviced or otherwise available land should be available for occupation by employment uses on a phased based that is directly proportionate to house building: • 4. 5 hectares at/before 2,500 homes are occupied; • 9 hectares at/before 5,000 homes are occupied; • 13.5 hectares at/before 7,500 homes are occupied; • The remainder after 7,500 homes. Monitoring of take up of employment land and jobs provided will allow for future policy adjustment. Nearby West End employment sites will also provide jobs for Cranbrook residents and some will travel to other locations for work purposes including Exeter City.

Rockbeare NP Strategic Framework page 82

The Local Plan’s other strategic policies relating to employment are as follows:

Strategy 28 - Sustaining and Diversifying Rural Enterprises: The Local Plan will provide for developments that will help sustain and diversify agricultural and traditional rural enterprises and add value to rural produce. The reuse of rural buildings to provide jobs and accommodate business start-ups and expansions will be encouraged.

Strategy 31 - Future Job and Employment Land Provision: Employment provision can potentially achieve greater education and skills development for the population of East Devon, particularly through work-based training opportunities. In order to secure local job provision we will promote mixed use developments and provision of employment uses close to where people live. Appropriate, sustainable, mixed use schemes of all scales incorporating housing and employment will be encouraged across the district. All large scale major housing developments (or parts/phases of any large scale major development) should be accompanied by employment provision to provide around: 1. One job for each new home built. 2. Around 1 hectare of employment land for each 250 homes proposed. As part of any proposal for development of employment land evidence will be taken into account on suitability of existing available and unused or underused employments sites and the ability of these to meet the needs for proposed development. On development between 50-199 units, applicants will be encouraged to make provision of ‘live/work’ units at 10% of the total units to be constructed and we will encourage the ‘work’ element to be appropriately secured by condition or S106 Agreement. In the villages we may allocate mixed use development sites and encourage the provision of a range of employment types. On smaller developments, provision for home working will be encouraged in individual dwellings.

Strategy 32 - Resisting Loss of Employment, Retail and Community Sites and Buildings: In order to ensure that local communities remain vibrant and viable and are able to meet the needs of residents we will resist the loss of employment, retail and community uses. This will include facilities such as buildings and spaces used by or for job generating uses and community and social gathering purposes, such as pubs, shops and Post Offices. Permission will not be granted for the change of use of current or allocated employment land and premises or social or community facilities, where it would harm social or community gathering and/or business and employment opportunities in the area, unless: 1. Continued use (or new use on a specifically allocated site) would significantly harm the quality of a locality whether through traffic, amenity, environmental or other associated problems; or 2. The new use would safeguard a listed building where current uses are detrimental to it and where it would otherwise not be afforded protection; or 3. Options for retention of the site or premises for its current or similar use have been fully explored without success for at least 12 months (and up to 2 years depending on market conditions) and there is a clear demonstration of surplus supply of land or provision in a locality; or 4. The proposed use would result in the provision or restoration of retail (Class A1) facilities in a settlement otherwise bereft of shops. Such facilities should be commensurate with the needs of the settlement. Employment uses include those falling into Class B of the Use Classes Order or similar uses classified under planning legislation as ‘Sui Generis’ uses. Redundant petrol filling stations and associated garage facilities will fall within the scope of this policy as do public and community uses and main town centre uses and other uses that directly provide jobs or employment, community meeting space or serve a community or social function.

Rockbeare NP Strategic Framework page 83

Local Plan development management policies focus on the well-being of the rural economy:

Policy E4 - Rural Diversification: Proposals to diversify and expand upon the range of traditional agricultural related economic activities undertaken in rural areas will be permitted where a proposal meets the following criteria in full: 1. The proposal is complementary to, or compatible with, the agricultural operations in the rural area or on a farm and is operated as part of an overall holding. 2. The character, scale and location of a proposal are compatible with its landscape setting and any area of nature conservation importance. 3. The proposal would not use the best and most versatile agricultural land. 4. The likely amount of traffic generated by the proposal could be accommodated on the local highway network without harming road safety and without adverse visual impact upon the surrounding countryside. 5. Any new building (and associated parking and other structures/storage) does not detract from the historic environment is modest in scale and is sited in or adjacent to an existing group of buildings and is of a compatible design and will blend into the landscape in terms of design, siting and materials. 6 The proposal would not cause noise, air or water pollution or flooding nor harm the amenity of local residents. 7. All new agricultural and agricultural related buildings within 1 kilometre of sighting of barn owls or signs of their activity with a ridge height of 3 metres or more shall make suitable provision for the nesting of barn owls, whether or not they have been observed at the site.

Policy E5 - Small Scale Economic Development in Rural Areas: In villages and rural areas small scale economic development (not including retail use classes/other uses in Classes A1 – A4) and expansion of existing businesses designed to provide jobs for local people will be permitted where: 1. It involves the conversion of existing buildings. Or 2. If new buildings are involved, it is on previously developed land. Or 3. If on a Greenfield site, shall be well related in scale and form and in sustainability terms to the village and surrounding areas. Provided that the following criteria are met: a safe highway access, the local highway network is capable of accommodating the forecast increase in traffic established by a Traffic Assessment, no detrimental impact upon the amenities of neighbouring properties, wildlife, landscape or historic interests. All new buildings shall be designed to blend into their location and shall meet sustainable construction and on site renewable energy production. In order to ensure that land is retained for the benefit of the local economy, permitted development rights allowing changes to alternative uses will be withdrawn.

Rockbeare NP Strategic Framework page 84

Policy E7 - Extensions to Existing Employment Sites: (extract) Outside Built-up Area Boundaries and where it is clear that a business or employment site or estate is at or near full occupancy the Council will permit the small scale expansion of the site in a manner that is proportionate to the existing size and scale of site operations provided the following criteria are met in full: 1. The local highway network is capable of accommodating the forecast increase in traffic established by a Traffic Assessment; or where these can be mitigated either by physical works being undertaken by the applicant or contributions are secured towards the cost of the works. 2. There will be no detrimental impact upon any nearby residential properties. 3. No protected landscapes or historic interests or other environmental interests are adversely affected and the existing local biodiversity and habitats are conserved or enhanced. In association with any development encouragement will be given for on-site renewable energy production. In order to ensure that land is retained for the benefit of the local economy, permitted development rights allowing changes to alternative uses will be withdrawn …..

Policy E14 - Change of Use of Village Shops or Services: Existing retail and service provision within villages should be maintained and potential providers of future retail development within villages will be encouraged to make provision of a scale and nature appropriate to local needs. Proposals which would result in a significant or total loss of shops, Post Offices, Public Houses or other services to the community will not be permitted except where the existing provision of a use of this nature is no longer viable and there is no market for the business as a going concern, evidence will need to be presented to show that the site has been actively market for at least 12 months at a sound, realistic and viable price for the type of commercial uses that the type of use can command. A vigorous economic assessment will be undertaken to establish the potential and viability of any specific concern and marketing of any property or business will need to include offering to the local community for their acquisition/operation. Permission to change the use of a shop will be subject to the retention of the shopfront.

PolPolicyicy E16E15 - ProposalsRetail Developme for Holidaynt in or Rural Overnight Areas OAccommodationutside Built-up Areaand Associated Boundaries: Facilities: ProposalsIn order to for protect hotel thedevelopment, viability of conversiontown centres of indwellings the District into yet self support catering local accommodation, businesses, retail guest houses anddevelopment upgrading in of rural existing areas, holiday outside accommodation villages, will be will permitted be permitted only where within it the directly Built -relatesup Area to an existing Boundariesrural business of townssubject and to: villages provided the following criteria are met in full: 1.a) Thea minimum scale, level of 60% and ofintensity the produce/products of development for is compasale betibleing produced with the characteron the premises of the surroundingor holding, and: area, includingb) No more adjoining than 30% and of nearby the produce/products settlements. being sourced and produced off the site of the premises or 2.holding The proposal and from does within not aharm 16 km the (10 amenities mile) radius enjoyed of the by business. the occupiers of neighbouring properties. 3.c) NoOn -moresite servicing than 10% and of parkingthe produce/products facilities are provided are from commensurate elsewhere. with the level and intensity of the proposedand subject use. to: 4.1. The proposalscale and is type accessible of retail on shop foo t,proposed by bicycle will and not public adversely transport affect an easilyd will accessible not impair convenience road safety or the freeshopping flow ofavailable traffic. to the local community. Conversion2. The proposal or use does of existingnot harm buildings the rural in character the open ofcountryside, the landscape within or closethe amenities proximity of to the the locality. main farm3. The house local orroad country network house, and foraccess small to-scale the site holiday can safely accommo accommdationodate uses the will extra be permitted traffic generated where by the cproposal.ompatible with the above. 4. The car parking will be proportionate to the scale of the development and the layout and siting will be sympathetic to the surroundings. 5. The scale and scope of any additional services will be restricted to ensure that they are ancillary to the main use.

Rockbeare NP Strategic Framework page 85

East Devon Sustainable Community Strategy 2010 The East Devon economy is summarised in the East Devon Sustainable Community Strategy as follows: “The District’s 4,700 businesses provide work for some 53,000 employees…… Unemployment is relatively low but these headlines mask some major challenges. The age profile of the district is heavily skewed to the middle aged and elderly; in part because young people leave the area to pursue careers elsewhere. Average weekly wage levels are low; £370.60 per week in East Devon compared to £475.80 per week nationally. East Devon has one the highest gaps between house prices and incomes in the country. East Devon can enhance its natural strengths through an economy that facilitates innovation and diversity within strong urban and rural communities. Our market and coastal towns can offer a much wider range of local employment opportunity and build on their visitor heritage. The rural areas can develop a breadth of enterprise capable of sustaining not only the fabric of the countryside but also the culture and diversity of their resident communities.”94

The challenges the Community Strategy sees are: “A low wage economy is coupled with transport and other infrastructure which often fails to reflect the needs of modern business and the work force that sustains them. There’s a shortage of land and buildings for work related investment and expansion. The industries that maintain the fabric of the countryside, farming and forestry for example are experiencing serious difficulties. Other sectors valuable to the countryside such as tourism are often low wage, small-scale and fragmented. Whilst we need to enhance average wages we also need to ensure that essential low waged employees (e.g. care workers and shop workers) are able to afford to live locally.”95 The single most important economic/employment priority of this plan for the LSP to tackle, as a body, is “increasing opportunities for raising average income and job prospects.”96

94 Page 15, East Devon Sustainable Community Strategy 2006-026 (up-dated 2010), East Devon Local Strategic Partnership 95 Page 15, East Devon Sustainable Community Strategy 2006-026 (up-dated 2010), East Devon Local Strategic Partnership 96 Page 25, East Devon Sustainable Community Strategy 2006-026 (up-dated 2010), East Devon Local Strategic Partnership Rockbeare NP Strategic Framework page 86

Renewable Energy National Planning Policy Framework Section 10 of the NPPF is concerned with meeting the challenge of climate change, flooding and coastal change.97

Paragraph 93 highlights that planning plays a key role in helping to secure reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure. In terms of energy efficiency and carbon emission the following paragraphs are relevant: 95. To support the move to a low carbon future, local planning authorities should:  plan for new development in locations and ways which reduce greenhouse gas emissions;  actively support energy efficiency improvements to existing buildings; and  when setting any local requirement for a building’s sustainability, do so in a way consistent with the Government’s zero carbon buildings policy and adopt nationally described standards. 96. In determining planning applications, local planning authorities should expect new development to:  comply with adopted Local Plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable; and  take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption.

In respect of renewable energy, the NPPF goes on to say: 97. To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources. They should:  have a positive strategy to promote energy from renewable and low carbon sources;  design their policies to maximise renewable and low carbon energy development while ensuring that adverse impacts are addressed satisfactorily, including cumulative landscape and visual impacts;  consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure the development of such sources;  support community-led initiatives for renewable and low carbon energy, including developments outside such areas being taken forward through neighbourhood planning; and  identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.

National Planning Practice Guidance To amplify the NPPF guidance, the National Planning Practice Guidance online resource includes guidance on the bigger picture of climate change, as well as renewable energy and low carbon development.

To set the context with climate change: Guidance > Climate change > Why is it important for planning to consider climate change?98 001. In addition to supporting the delivery of appropriately sited green energy, effective spatial planning is an important part of a successful response to climate change as it can influence the emission of greenhouse gases. In doing so, local planning authorities should ensure that protecting the local environment is properly considered alongside the broader issues of protecting the global environment. Planning can also help increase resilience to climate change impact through the location, mix and design of development.

97 http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable- development/10-meeting-the-challenge-of-climate-change-flooding-and-coastal-change/ 98 http://planningguidance.planningportal.gov.uk/blog/guidance/climate-change/ Rockbeare NP Strategic Framework page 87

Addressing climate change is one of the core land use planning principles which the National Planning Policy Framework expects to underpin both plan-making and decision-taking. To be found sound, Local Plans will need to reflect this principle and enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework. These include the requirements for local authorities to adopt proactive strategies to mitigate and adapt to climate change in line with the provisions and objectives of the Climate Change Act 2008, and co-operate to deliver strategic priorities which include climate change.

In addition to the statutory requirement to take the Framework into account in the preparation of Local Plans, there is a statutory duty on local planning authorities to include policies in their Local Plan designed to tackle climate change and its impacts. This complements the sustainable development duty on plan-makers and the expectation that neighbourhood plans will contribute to the achievement of sustainable development. The National Planning Policy Framework emphasises that responding to climate change is central to the economic, social and environmental dimensions of sustainable development.

More specifically concerning renewable and low carbon energy, another section of the Guidance contains information in relation to developing a strategy for renewable and low carbon energy. Guidance > Renewable and low carbon energy > Developing a strategy for renewable and low carbon energy99 003. The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities. As with other types of development, it is important that the planning concerns of local communities are properly heard in matters that directly affect them.

Local and neighbourhood plans are the key to delivering development that has the backing of local communities. When drawing up a Local Plan local planning authorities should first consider what the local potential is for renewable and low carbon energy generation. In considering that potential, the matters local planning authorities should think about include:  the range of technologies that could be accommodated and the policies needed to encourage their development in the right places;  the costs of many renewable energy technologies are falling, potentially increasing their attractiveness and the number of proposals;  different technologies have different impacts and the impacts can vary by place;  the UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver. 004. What is the role for community led renewable energy initiatives? Community initiatives are likely to play an increasingly important role and should be encouraged as a way of providing positive local benefit from renewable energy development. Further information for communities interested in developing their own initiatives is provided by the Department of Energy and Climate Change. Local planning authorities may wish to establish policies which give positive weight to renewable and low carbon energy initiatives which have clear evidence of local community involvement and leadership.

Neighbourhood plans are an opportunity for communities to plan for community led renewable energy developments. Neighbourhood Development Orders and Community Right to Build Orders can be used to grant planning permission for renewable energy development. To support community based initiatives a local planning authority should set out clearly any strategic policies that those producing neighbourhood plans or Orders will need to consider when developing proposals that address renewable energy development. Local planning authorities should also share relevant evidence that may assist those producing a neighbourhood plan or Order,

99 http://planningguidance.planningportal.gov.uk/blog/guidance/renewable-and-low-carbon-energy/ Rockbeare NP Strategic Framework page 88 as part of their duty to advise or assist. As part of a neighbourhood plan, communities can also look at developing a community energy plan to underpin the neighbourhood plan.

Suitable areas for wind energy development will need to have been allocated clearly in a Local plan or Neighbourhood Plan. “When determining planning applications for wind energy development involving one or more wind turbines, local planning authorities should only grant planning permission if: · the development site is in an area identified as suitable for wind energy development in a Local or Neighbourhood Plan; and · following consultation, it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing. Maps showing the wind resource as favourable to wind turbines, or similar, will not be sufficient. Whether a proposal has the backing of the affected local community is a planning judgement for the local planning authority.”100

Further parts of the Guidance deal with particular considerations for specific types of renewable and low carbon energy technologies, these being hydropower, active solar technology (photo-voltaics and solar water heating), solar farms and wind turbines.

Guidance > Renewable and low carbon energy > Particular planning considerations for hydropower, active solar technology, solar farms and wind turbines101 011. What are the particular planning considerations that relate to Hydropower? Planning applications for hydropower should normally be accompanied by a Flood Risk Assessment. Early engagement with the local planning authority and the Environment Agency will help to identify the potential planning issues, which are likely to be highly specific to the location. Advice on environmental protection for new hydropower schemes has been published by the Environment Agency. 012. What are the particular planning considerations that relate to Active solar technology (Photovoltaic and Solar Water Heating)? Active solar technology, (photovoltaic and solar water heating) on or related to a particular building is often permitted development (which does not require a planning application) provided the installation is not of an unusual design, or does not involve a listed building, and is not in a designated area. Where a planning application is required, factors to bear in mind include:  the importance of siting systems in situations where they can collect the most energy from the sun;  need for sufficient area of solar modules to produce the required energy output from the system;  the effect on a protected area such as an Area of Outstanding Natural Beauty or other designated areas;  the colour and appearance of the modules, particularly if not a standard design. 013. What are the particular planning considerations that relate to large scale ground-mounted solar photovoltaic Farms? The deployment of large-scale solar farms can have a negative impact on the rural environment, particularly in undulating landscapes. However, the visual impact of a well-planned and well-screened solar farm can be properly addressed within the landscape if planned sensitively. Particular factors a local planning authority will need to consider include:  encouraging the effective use of land by focussing large scale solar farms on previously developed and non-agricultural land, provided that it is not of high environmental value;  where a proposal involves greenfield land, whether (i) the proposed use of any agricultural land has been shown to be necessary and poorer quality land has been used in preference to higher quality land; and

100 Written Statement made by: Secretary of State for Communities and Local Government (Greg Clark) on 18 Jun 2015. 101 http://planningguidance.planningportal.gov.uk/blog/guidance/renewable-and-low-carbon-energy/particular-planning-considerations- for-hydropower-active-solar-technology-solar-farms-and-wind-turbines/ Rockbeare NP Strategic Framework page 89

(ii) the proposal allows for continued agricultural use where applicable and/or encourages biodiversity improvements around arrays. (See also a speech by the Minister for Energy and Climate Change, the Rt Hon Gregory Barker MP, to the solar PV industry on 25 April 2013).  that solar farms are normally temporary structures and planning conditions can be used to ensure that the installations are removed when no longer in use and the land is restored to its previous use;  the proposal’s visual impact, the effect on landscape of glint and glare (see guidance on landscape assessment) and on neighbouring uses and aircraft safety;  the extent to which there may be additional impacts if solar arrays follow the daily movement of the sun;  the need for, and impact of, security measures such as lights and fencing;  great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting. As the significance of a heritage asset derives not only from its physical presence, but also from its setting, careful consideration should be given to the impact of large scale solar farms on such assets. Depending on their scale, design and prominence, a large scale solar farm within the setting of a heritage asset may cause substantial harm to the significance of the asset;  the potential to mitigate landscape and visual impacts through, for example, screening with native hedges;  the energy generating potential, which can vary for a number of reasons including, latitude and aspect. The approach to assessing cumulative landscape and visual impact of large scale solar farms is likely to be the same as assessing the impact of wind turbines. However, in the case of ground-mounted solar panels it should be noted that with effective screening and appropriate land topography the area of a zone of visual influence could be zero.

Finally, ‘What are the particular planning considerations that relate to wind turbines’ is dealt with at paragraph 014 in the format of a series of questions, that then link to extensive detailed advice on different aspects of wind turbine development.102 The following questions should be considered when determining applications for wind turbines: • How are noise impacts of wind turbines assessed? • Is safety an issue when wind turbine applications are assessed? • Is interference with electromagnetic transmissions an issue for wind turbine applications? • How can the risk of wind turbines be assessed for ecology? • How should heritage be taken into account in assessing wind turbine applications? • Is shadow flicker and reflected light an issue for wind turbine applications? • How to assess the likely energy output of a wind turbine? • How should cumulative landscape and visual impacts from wind turbines be assessed? • What information is needed to assess cumulative landscape and visual impacts of wind turbines? • Decommissioning wind turbines

Design of buildings is also a consideration in relation to energy efficiency and this is also dealt with in the Planning Practice Guidance.

Guidance > Design > What planning objectives can good design help achieve?103 013. Planning should promote efficient use of natural resources The structure, layout and design of places can help reduce their resource requirements in terms of energy demands, water and land take, and help to sustain natural ecosystems. Having a mix of uses and facilities within a neighbourhood can reduce travel demand and energy demands.

102 http://planningguidance.planningportal.gov.uk/blog/guidance/renewable-and-low-carbon-energy/particular-planning-considerations- for-hydropower-active-solar-technology-solar-farms-and-wind-turbines/#paragraph_014 103 http://planningguidance.planningportal.gov.uk/blog/guidance/design/what-planning-objectives-can-good-design-help-achieve/ Rockbeare NP Strategic Framework page 90

Ensuring a place is durable and adaptable will help make it less resource hungry over time. For example the layout of infrastructure servicing development (including water supply, sewerage, drainage, gas, electricity, cable, telephone, roads, footpaths, cycle ways and parks) should take account of foreseeable changes in demand to reduce the need for expensive future changes. The layout and design of buildings and planting can reduce energy and water use and mitigate against flooding, pollution and over-heating. Passive solar design is the siting and design of buildings to maximise the use of the sun’s energy for heating and cooling. Passive solar design takes advantage of natural characteristics in building materials and air to help reduce the additional energy needed for heating and cooling. Policies can encourage sites to be planned to permit good solar access to as many buildings as possible. The potential benefits of passive solar design can only be realised by careful siting and layout. For example, access roads could predominantly run east-west, with local distributors running north-south and glazing minimised on north facing elevations to reduce heat loss. Passive solar design principles can be applied equally effectively in housing and commercial developments. It is important that passive design considers the potential for overheating in the summer, as well as reducing need for heating in the winter. A range of design solutions can be considered to help avoid overheating and the need for air conditioning. For example, high levels of thermal mass, maximising natural ventilation, passive cooling using planting for shade, roof overhangs to provide shade for high-sun angles, and smart glazing materials. The urban heat island effect can be reduced by, for example, allowing sufficient space between buildings, tree planting, shading and street layouts which encourage air flow and using light and reflective surfaces or vegetation on buildings.

East Devon Local Plan 2013-2031 The Local Plan deals with Climate Change and Renewable Energy, including low carbon development.

Strategy 38 - Sustainable Design and Construction: (extract) Proposals for new development and for refurbishment of, conversion or extensions to existing buildings will be expected to demonstrate through a Design and Access Statement how: a) sustainable design and construction methods will be incorporated, specifically, through the re-use of material derived from excavation and demolition, use of renewable energy technology, landform, layout, building orientation, massing, use of local materials and landscaping; b) the development will be resilient to the impacts of climate change; …………………

Strategy 39 - Renewable and Low Carbon Energy Projects: Renewable or low-carbon energy projects in either domestic or commercial development will in principle be supported and encouraged subject to them following current best practice guidance and the adverse impacts on features of environmental and heritage sensitivity, including any cumulative landscape and visual impacts, being satisfactorily addressed. Applicants will need to demonstrate that they have taken appropriate steps in considering the options in relation to location, scale and design, for firstly avoiding harm, and then reducing and mitigating any unavoidable harm, to ensure an acceptable balance between harm and benefit. Where schemes are in open countryside there will be a requirement to remove all equipment from the site and restore land to its former, or better, condition if the project ceases in the future.

The Plan explains that: ‘The requirement for new buildings to be “zero carbon” will occur within the timescale of this plan and is likely to require the adoption of Allowable Solutions. Allowable Solutions is a concept that has been developed to account for the fact that it may not always be possible to achieve zero carbon on-site using carbon compliance measures (i.e. energy efficiency and renewable energy).’

Rockbeare NP Strategic Framework page 91

Strategy 40 - Decentralised Energy Networks: Decentralised Energy Networks will be developed and brought forward. New development (either new build or conversion) with a floor space of at least 1,000m2 or comprising ten or more dwellings should connect to any existing, or proposed, Decentralised Energy Network in the locality to bring forward low and zero carbon energy supply and distribution. Where there is no existing Decentralised Energy Network in the locality, proposals for larger developments of 4 hectares (either housing or other buildings) or 200 houses should evaluate the potential for such systems and implement them where they are viable over the life of the developments in the locality. Consumer choice of energy sources will be retained when decentralised energy networks are developed. Project level Habitat Regulation assessments may be needed to ensure that any new infrastructure needs are met without adverse impacts on European sites.

Strategy 41 - Allowable Solutions: In some instances, on site provision of renewable technologies will not be desirable or appropriate. Where this is the case developments can meet requirements through contributing to ‘off site’ provision in the form of making ‘Allowable Solutions contributions’. Monies gathered will contribute to a ‘Community Energy Fund’ that will be used to pay for/contribute to energy conservation/renewable initiatives.

Devon-wide Landscape Advice for Renewable Energy104 This guidance promotes good siting and design of wind and solar PV development that takes account of the special qualities and distinctive characteristics of Devon’s landscape. The guidance aims to show how these development types may be accommodated whilst minimising harm to Devon’s landscape and protecting what people most value.

The following extracts are most pertinent here: The following provides some generic guidance on siting wind energy105 development in Devon, focussing on minimising landscape and visual effects. It is recognised that technologies need to be sited and designed to ensure a reasonable output. “In all cases the strategy for the relevant landscape character area within Devon’s landscape character assessments should be considered when choosing potential sites for wind energy development. The following guidance should be followed for siting any wind energy development, whether it comprises one small turbine or multiple large turbines: i. Site wind energy developments away from dramatic rugged landforms or valued distinct landform features (including prominent headlands). ii. Seek to avoid siting wind turbines where they would detract from the undeveloped character of the coast……. iii. Seek to avoid areas valued for their remoteness, areas free from human influence and perceived ‘untamed’ naturalness e.g. the upland moors. iv. Because of intrinsic historic landscape character significance, or potential for preserved archaeological evidence, avoid siting wind energy development on land recorded as the following within Devon’s HLC: rough ground with earlier remains, prehistoric fields, watermeadows, and fields with a medieval historic character type such as strip fields, enclosures (strips) and enclosures - medieval. Some more recent but discrete enclosed landscapes may also be sensitive, such as ‘barton’ fields, particularly when associated with a listed historic farmstead. v. Seek to avoid areas where ground level disturbance affects landscapes that are difficult to restore (e.g. deep peat or bog).

104 www.devon.gov.uk/devon-guidance-v6-june-2013-final-report.pdf 105 Para 2.17, Accommodating Wind and Solar PV Developments in Devon’s Landscape, Land Use Consultants, 2013

Rockbeare NP Strategic Framework page 92 vi. Ensure siting of turbines does not adversely affect the distinctive characteristics and special qualities of Devon’s National Parks, AONBs or Heritage Coasts….. vii. Ensure siting of turbines does not damage the special qualities of the landscape as recorded in the Devon Landscape Character Area descriptions. viii. It is generally less distracting to see a substantial part of a turbine rather than blade tips only – this may be a particular consideration for views from sensitive viewpoints or those frequented by a larger number of viewers. ix. Significant effects on views from important viewpoints (including views which are integral to the character of conservation areas and recognised /iconic views), popular tourist and scenic routes, and settlements should be avoided where possible or minimised through careful siting. x. Consider locations in association with business parks and reclaimed, industrial and man-made landscapes where other landscape sensitivities are not compromised. xi. Consider the landscape effects of transmission infrastructure when siting development, aiming for sites that will minimise the need for above ground transmission infrastructure, particularly through AONBs, National Parks and Heritage Coasts. Undergrounding cables may mitigate effects in sensitive locations. xii. Consider sites where areas of existing vegetation could screen ground-level features of wind energy developments (such as fencing, tracks and transformers). xiii. The visibility of turbines from valleys and lower ground may be reduced if they are located on high plateau with concave or steep wooded slopes. xiv. It is preferable to site turbines where they do not prevent the understanding and appreciation of historic landmarks features such as hilltop monuments or church towers. xv. Protect the character of conservation areas (including views integral to their character), the setting to listed buildings (where the character of the landscape is an important part of a listed building’s setting), the character of Devon’s Cultural Trails, and Registered/ local historic parks and gardens/battlefields (including views to and from, particularly designed views). xvi. When siting medium or large-scale wind energy development (i.e. those with multiple turbines over 50m tip height), select sites in simple, regular landscapes with extensive areas of consistent ground cover over landscapes with more complex or irregular land cover patterns, smaller field sizes and landscapes with frequent human scale features (subject to satisfying other sensitivities). xvii. When siting medium or large-scale turbines (i.e. those over 50m tip height), avoid selecting sites on important undeveloped or distinctive skylines, or skylines with important cultural or historic landmark features (including skylines of elevated coastlines and coastal headlands). xviii. When selecting sites consider potential effects of transporting turbines to site, and the possible limitations presented by winding narrow lanes bounded by Devon hedges. When siting single turbines the following guidance should be considered: xix. Consider siting turbines so they are perceived as part of other built development /in association with a building group where effects on amenity allow. For example, there may be some opportunity to site smaller single turbines in relation to farm buildings with larger scale single turbines sited in relation to larger businesses or community buildings - development should be commensurate with (or reflect) the scale of the associated buildings.”

When siting multiple turbines the following guidance should be considered: “xx. Locate turbines on the most level part of a site or following contours to avoid a discordant variation of turbine heights. xxi. Ensure the size and grouping of turbines responds to landscape character, reinforcing the difference between distinct landscape character types. xxii. Seek to keep a turbine group within one landscape character type (particularly as perceived in sensitive views) so that turbines do not span across marked changes in character on the ground, such as changes in topography.”

Rockbeare NP Strategic Framework page 93

Generic Guidance on Siting Solar PV Developments106 The following provides some generic guidance on siting solar PV development in Devon focussing on minimising landscape and visual effects. It is recognised that technologies need to be sited and designed to ensure a reasonable output. “i. Site solar PV development on lower slopes/within folds in gently undulating lowland landscapes or on flat plateau sites rather than on upper slopes or coastal headlands. ii. Any PV development on plateau landscapes should generally be set back from edges to minimise effects on views from surrounding areas. iii. Site development in landscapes with a sense of enclosure (e.g. provided by woodland or high hedges) rather than in open and unenclosed landscapes. iv. Consider views from local viewpoints, popular routes, recognised /iconic views, and designated landscapes when considering the siting of solar PV development in the landscape - site panels in areas where they can be well concealed or integrated into sensitive views. v. When siting development, consider the appearance of the development as viewed from the ‘backs’ and ‘sides’ (where frames will be more visible) as well as from the ‘front’. vi. For sites that are overlooked by higher ground the design of the site and how it integrates with the landscape will be particularly important. vii. Prehistoric enclosures and medieval enclosures (including strip fields) are likely to be more sensitive to the introduction of solar PV development than more modern fields. viii. Because of intrinsic historic landscape character significance, or potential for preserved archaeological evidence, avoid siting solar PV development on land recorded as the following: rough ground with earlier remains, prehistoric fields, water meadows, and fields with a medieval historic character type….. ix. Ensure sites do not span across marked changes in character on the ground. x. Site field-scale PV development away from areas of ‘undeveloped coast’. xi. Site field-scale PV development away from areas valued for their remoteness…. e.g. the upland moors. xii. Significant effects on views from important viewpoints (including views which are integral to the character of conservation areas and viewpoints in sensitive areas including recognised /iconic views), popular tourist and scenic routes and settlements should be minimised. xiii. Sites in naturalistic landscapes will be more sensitive than sites in areas containing existing hard surfacing or built elements (e.g. urban areas, brownfield sites or large-scale horticulture). xiv. Consider providing enhanced management of landscape features, habitats and historic assets as part of a development, including contributing to wider landscape scale targets and projects in Devon’s Biodiversity Action Plan, guidelines in Devon’s Landscape Character Assessment, and landscape management objectives set out in local landscape character assessments. xv. Consider how panels will be transported to site – many rural lanes are very narrow and have high hedges either side. Damage should be avoided, but if damage occurs reinstatement will be required. xvi. Ensure siting of solar PV development does not adversely affect the distinctive characteristics and special qualities of Devon’s National Parks or AONBs or Heritage Coasts….. - the more visible a development is in the landscape, the higher the risk that it may affect scenic quality/natural beauty. xvii. Ensure siting of solar PV development does not harm the special qualities of the landscape as recorded in Devon’s landscape character area descriptions. xviii. Protect the character of conservation areas (including views integral to their character), the setting to listed buildings (where the character of the landscape is an important part of a listed building’s setting), the character of Devon’s Cultural Trails, and Registered/ local historic parks and gardens/battlefields (including views to and from, particularly designed views).”

106 Para 3.17, Accommodating Wind and Solar PV Developments in Devon’s Landscape, Land Use Consultants, 2013 Rockbeare NP Strategic Framework page 94

Minerals and Waste This section seeks to provide relevant extracts from the strategic framework and the local policies that are already in place or ‘emerging’ from recent reviews.

Responsibilities for planning for minerals and waste planning Devon County Council (DCC) is the Minerals Planning Authority responsible for determining the following types of development: including mineral exploration, extraction, processing, tipping of mineral waste, construction or erection of plant or buildings at a minerals site, oil and gas exploration and development, variation 3 of conditions attached to a minerals consent, consolidation of one or more planning permissions, review of old mineral permissions. As the MPA it also produces the Minerals DCC is also the Waste Planning Authority (WPA) responsible for determining the following types of development: including scrap yards, clinical and other types of waste incinerator, landfill and land raising sites, waste storage facilities, sewage treatment plants, dredging tips, recycling and waste reception centres, GRP kiosks which house equipment for sewage undertakers, composting schemes, waste processing and composting plant, concrete crushing and blacktop reprocessing facilities. As WPA it is also responsible for producing the Waste Local Plan.

Minerals National Planning Policy Framework “Minerals are essential to support sustainable economic growth and our quality of life. It is therefore important that there is a sufficient supply of material to provide the infrastructure, buildings, energy and goods that the country needs. However, since minerals are a finite natural resource, and can only be worked where they are found, it is important to make best use of them to secure their long-term conservation.”107

“When determining planning applications, local planning authorities should:  give great weight to the benefits of the mineral extraction, including to the economy;  as far as is practical, provide for the maintenance of land-banks of non-energy minerals from outside National Parks, the Broads, Areas of Outstanding Natural Beauty and World Heritage sites, Scheduled Monuments and Conservation Areas  ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety, and take into account the cumulative effect of multiple impacts from individual sites and/or from a number of sites in a locality  ensure that any unavoidable noise, dust and particle emissions and any blasting vibrations are controlled, mitigated or removed at source,31 and establish appropriate noise limits for extraction in proximity to noise sensitive properties  not grant planning permission for peat extraction from new or extended sites;  provide for restoration and aftercare at the earliest opportunity to be carried out to high environmental standards, through the application of appropriate conditions, where necessary. Bonds or other financial guarantees to underpin planning conditions should only be sought in exceptional circumstances  not normally permit other development proposals in mineral safeguarding areas where they might constrain potential future use for these purposes;  consider how to meet any demand for small-scale extraction of building stone at, or close to, relic quarries needed for the repair of heritage assets, taking account of the need to protect designated sites

107 Page 32, para.142, National Planning Policy Framework, DCLG, 2012 Rockbeare NP Strategic Framework page 95

 recognise the small-scale nature and impact of building and roofing stone quarries, and the need for a flexible approach to the potentially long duration of planning permissions reflecting the intermittent or low rate of working at many sites”108

National Planning Practice Guidance Planning Practice Guidance, published by DCLG, provides supplementary guidance to the NPPF109. A number of recent and relevant revisions to the guidance regarding mineral extraction and the planning process have been published. These include guidance specifically about hydro-carbon extraction: “The exploratory, appraisal or production phase of hydrocarbon extraction can only take place in areas where the Department of Energy and Climate Change have issued a licence under the Petroleum Act 1998 (Petroleum Licence).”110 “Planning permission is required for each phase of hydrocarbon extraction, although some initial seismic work may have deemed planning consent under Part 2 of Schedule 2 to the Town and Country Planning (General Permitted Development) Order 1995.”111 “The exploratory phase seeks to acquire geological data to establish whether hydrocarbons are present. It may involve seismic surveys, exploratory drilling and, in the case of shale gas, hydraulic fracturing.”112

Devon Minerals Plan In 2012 Devon CC began the process of producing a new Devon Minerals Plan (previously called the Minerals Core Strategy). Once adopted, this will replace the current Minerals Local Plan (2004) and become the new basis for protecting our mineral assets, enabling appropriate mineral development and determining minerals planning applications.

National minerals planning policy requires that one of the key issues to be address in the Devon Minerals Plan is a forecasted shortage in sand and gravel aggregates in the period to 2031. Maintaining a supply of aggregates is essential for the construction industry and to Devon’s future economic prosperity.

The new Minerals Plan went through a pre-submission consultation in 2015113. A submission version is expected in 2016. The Devon Minerals Plan is a local plan within the terms of the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended), and provides a comprehensive set of core and development management policies and site-specific proposals. On its adoption, the Devon Minerals Plan will replace all of the saved policies of the Devon County Minerals Local Plan (2004) (as identified in Appendix D) and, as a development plan document, will form part of the statutory development plan for both tiers of planning authority in Devon. Whilst the Devon Minerals Plan should be considered as a whole, with any single policy being read in conjunction with the Plan’s other policies, rather than individual policies being taken in isolation; we have included those “core” policies most relevant to Rockbeare Parish, because of its proximity to the Budleigh Salterton Pebble Beds, which is the major source of sand and gravel in Devon, accounting for 87% of the County’s production in 2013. The Budleigh Salterton Pebble Beds of Triassic age occur as a series of outcrops running north from Budleigh Salterton to the Somerset border near Burlescombe, as illustrated on the map overleaf.

Policy M11: Landbanks for Land-won Aggregates commits to the maintenance of minimum landbanks for crushed rock and sand and gravel, and provides criteria for allowing new resources. The adequate and steady supply of land-won aggregates will be secured through the maintenance of landbanks equivalent to a minimum of ten years for crushed rock and a minimum of seven years for sand and gravel,

108 Page 34, para.144, National Planning Policy Framework, DCLG, 2012 109 NPPF = National Planning Policy Framework 110 Planning Practice Guidance Para: 104 Ref ID: 27-104-20140306 Revision date: 06 03 2014 111 Planning Practice Guidance, Para:093 Ref: 27-093-20140306 Revision date: 06 03 2014 112 Planning Practice Guidance, Para:095 Ref: 27-095-20140306 Revision date: 06 03 2014 113 https://new.devon.gov.uk/planning/planning-policies/minerals-and-waste-policy/devon-minerals-plan Rockbeare NP Strategic Framework page 96 calculated using the respective rates of supply provided in the annual Local Aggregate Assessment. Where a landbank is close to or below the minimum duration, proposals will be permitted for new or extended sites that would provide the resources required for maintenance of the minimum landbank subject to compliance with the Minerals Plan’s Spatial Strategy. Where a landbank significantly exceeds the minimum duration, proposals for new or extended sites will be permitted where:…….

Policy M12: Land-won Sand and Gravel Supply seeks to maintain supply through existing reserves, new resources at two sites in the Budleigh Salterton Pebble Beds and small-scale working around Newton Abbot and Exeter. The adequate and steady supply of land-won sand and gravel to meet the requirements of Policy M11 will be met through: (a) the extraction of remaining reserves at existing quarries; (b) the development of further sand and gravel resources within the Budleigh Salterton Pebble Beds at the following locations illustrated on the Policies Map, subject to the mitigation measures identified in Appendix C: (i) Straitgate Farm, Ottery St Mary (Specific Site) through working only above the maximum water table; and (ii) West of Penslade Cross, Uffculme (Preferred Area); and (c) small-scale working within the Exeter and/or Newton Abbot areas through the extension of existing quarries or development of new sites in those localities.

Rockbeare NP Strategic Framework page 97

Based on the pre-submission draft, the Mineral Plan’s development management policies are likely to have development management policies that will provides the policy framework for decisions by Devon County Council on planning applications for mineral development over the period to 2033, together with decisions on non-mineral development by other planning authorities that may affect mineral resources. The development policies cover the following matters (Nb. the detailed criteria to be applied for each policy have not been included in this summary). Policy M16: Green Infrastructure Mineral development will maintain and enhance the quality, extent and connectivity of Devon’s green infrastructure. Development proposals will, as appropriate to their scale and nature, ensure no net loss of green infrastructure function and connectivity throughout the lifetime of the mineral site…….. Policy M17: Biodiversity and Geodiversity Mineral development will protect and enhance wildlife and geodiversity through its layout, design and operational practices. Protection of sites and species will be commensurate with their status and the contribution that they make to Devon’s ecological networks……………. Policy M18: Landscape and Visual Impact The scale, design layout and operational practices of all mineral development will be sympathetic to the valued or special qualities, distinctive character and features of the landscape. Development proposals must be supported by Landscape and Visual Impact Assessment that reflects the nature, scale and location of development………. Policy M19: The Historic Environment Mineral development will conserve and enhance Devon’s historic and cultural environment through its location, design, landscaping and the arrangement of buildings and structures on site. Development proposals must include an assessment of the presence and significance of heritage assets that may be affected………… Policy M20: Sustainable Design Mineral development will contribute to the achievement of sustainable development, climate change resilience and mitigation, and the conservation and enhancement of Devon’s distinctive character and environmental quality. Proposals must demonstrate how the site design, layout, operation and, where relevant, any new infrastructure will, where consistent with the scale and type of development: …………… Policy M21: Natural Resources The sustainable development of minerals will conserve and enhance other natural resources, …….. Policy M22: Transportation and Access Within geological constraints, mineral development will minimise the distance that minerals are transported while maximising opportunities for sustainable transportation and access by a variety of modes..…….. Policy M23: Quality of Life Peoples’ quality of life, health and amenity will be protected from the adverse effects of mineral development and transportation……….. Policy M24: Flooding Mineral development must be resilient to the impacts of flooding and not lead to an increased risk of fluvial, surface water or groundwater flooding. This will be achieved through application of a sequential approach that favours the location of development in Flood Zone 1………. Policy M25: Land Stability Proposals for mineral development will be permitted if it can be demonstrated, including through submission of a land and slope stability risk assessment where appropriate, that they will not have an adverse effect on the stability or safety of surrounding land, buildings and watercourses during and following cessation of mineral operations. Policy M26: Cumulative Effects Proposals that accord with the other policies of the Devon Minerals Plan will be permitted where it can be demonstrated that they will not result in an unacceptable level of cumulative impact…….. Policy M27: Restoration and Aftercare Applications for mineral development will be permitted where they provide for the restoration and aftercare of the site in a phased manner during its operation at the earliest opportunity……..

Rockbeare NP Strategic Framework page 98

Waste & Recycling EU Targets EU Legislation has laid down a whole series of targets, via EU directives, for the reduction of waste and recycling. Landfill Directive (1999/31/EC) This Directive - Aims to prevent or reduce the adverse effects of the landfill of wastes on the environment. Targets - Reduce the amount of biodegradable waste sent to landfill (UK) by: 50% by 2013 75% by 2020 Waste Framework Directive (2008/98/EC) This Directive - Aims to protect the environment and human health through the prevention of harmful effects of waste generation and waste management. Targets: Household Waste: 50% by weight recycled by 2020 Construction and Demolition Waste: 70% by weight recycled by 2020 WEEE Directive (2002/95/EC) This Directive - Aims to prevent Waste Electrical and Electronic Equipment and in addition; to encourage reuse, recycling and other forms of recovery of such wastes to avoid disposal. Targets - Producer responsibility targets have been set for all categories of WEEE noted in the implications column. Targets for household appliances are shown below; Minimum annual recovery targets: 80% - Large household appliances 70% - Small household appliances Minimum annual recycling and reuse targets: 75% - Large household appliances Batteries Directive (2006/66/EC) This Directive - Prohibits certain batteries from the market place where they contain a certain mercury or cadmium content, and establishes rules for the collection, recycling, treatment and disposal of batteries and accumulators. Targets for EU Member States Must achieve a collection rate for portable batteries of: 45% by 2016 A recycling rate (for collected batteries) of between 50% - 75% depending on the type. UK targets (collection): 25% by 2012 (as EU target) Waste Incineration Directive (2000/76/EC) This Directive - Aims to prevent or reduce, air, water and soil pollution, as well as any risk to human health, resulting from the incineration of waste. Targets - This Directive does not contain a specific target but does impose operating and emissions limits. Packaging & Packaging Waste Directive (1994/62/EC) This Directive Aims: to limit the production of packaging waste and promote reuse, recycling and recovery regardless of origin i.e. households, commercial or industrial. Targets: By 2008, between 55% & 80% by weight of packaging recycled of which: 60% - Glass paper and board 50% - Metals 22.5% - Plastics 15% - Wood

Rockbeare NP Strategic Framework page 99

Waste Management Plan for England In 2013 the Government published a new Waste Management Plan for England that fulfilled the requirement in Article 28 of the revised EU Waste Framework Directive2 (WFD). Article 28 requires that Member States ensure that their competent authorities establish one or more waste management plans covering all of their territory. “The Waste Management Plan for England is a high level document which is non–site specific. It provides an analysis of the current waste management situation in England, and evaluates how it will support implementation of the objectives and provisions of the revised WFD.”114 Most pertinent perhaps of this Plan is the objective for:

Measures to be taken to ensure that by 2020: “(a) at least 50% by weight of waste from households is prepared for re-use or recycled (b) at least 70% by weight of construction and demolition waste is subjected to material recovery”115

The National Planning Policy for Waste was published in 2014. It sets out detailed waste planning guidelines for the waste authorities and local planning authorities. It includes guidance on:  ensuring that the planned provision of new capacity and its spatial distribution is based on robust analysis  identifying sufficient opportunities to meet the identified needs of their area for the management of waste streams  identifying, in their Local Plans, sites and/or areas for new or enhanced waste management facilities in appropriate locations.  Determining planning applications

Paragraph 8 of National Planning Policy for Waste, requires local planning authorities to ensure: • there is not an unacceptable impact of proposed non-waste development on existing waste management facilities that would prejudice the operation of the facility or the implementation of the Waste Hierarchy; • non-waste development makes sufficient provision for waste management and promotes good design to secure the integration of waste management facilities or local landscape. This includes adequate storage facilities for residential dwellings; and • the operation of development maximises opportunities for the reuse and recovery or materials which minimises off-site disposal, or treatment.

114 Page 2, Waste Management Plan for England, DEFRA, Dec 2013 115 Page 4, Waste Management Plan for England, DEFRA, Dec 2013 Rockbeare NP Strategic Framework page 100

Devon Waste Plan 2013-2031116 The Devon Waste Plan envisages that Devon will lead the way in sustainable waste management by working towards a zero waste economy. The Plan follows national policy in implementing the waste hierarchy and, where waste cannot be prevented, aims for 90% of Construction, Demolition and Excavation Waste and 64% of Local Authority Collected Waste and Commercial and Industrial Waste to be reused or recycled. The Plan has the following objectives that will achieve sustainable waste management in Devon: Objective 1: Management of Waste To treat waste as a valuable resource through the sequential application of the waste hierarchy in the implementation of the Waste Plan, in development management decisions and through the actions of everyone involved in the generation and management of waste. This will result in achievement of the following targets by 2031: Local Authority Collected Waste and Commercial & Industrial Waste • the reuse or recycling (including composting) of at least 64% of waste, and • the recovery of energy from the residual non-recyclable waste to enable all waste to be reused, recycled or recovered. Construction, Demolition & Excavation Waste • the recycling of at least 90% of waste. Objective 2: Meeting our Capacity Needs To ensure the provision of the necessary waste management capacity through: • a countywide network of facilities supporting the re-use and recycling of waste located at or close to Devon’s market and coastal towns, and • a network of strategic recovery and disposal facilities accessible to the major sources of waste generation. Objective 3: Climate Change To tackle climate change by reducing the carbon footprint of waste management, encouraging the substitution of raw materials by re-use and recycled waste, enabling waste management to contribute to delivery of low- carbon energy, and ensuring that waste management facilities are resilient to the effects of climate change and improve Devon’s capacity to adapt to those effects. Objective 4: Supporting Devon’s Communities and Businesses To support Devon’s local communities and businesses in their sustainable management of waste through the availability of sufficient and accessible facilities, while ensuring that waste management development avoids harm to, and where possible improves, peoples’ quality of life, and assists economic growth through the generation of waste-derived resources. Objective 5: Conserving and Enhancing Devon’s Environment To ensure that waste management development conserves and enhances Devon’s landscapes, biodiversity, heritage assets and natural resources, taking opportunities to protect and improve Devon’s green infrastructure network for the benefit of people and wildlife.

Devon Waste Management and Infrastructure Supplementary Planning Document (SPD) 2015117 The SPD aims to provide clear and practical guidance on the policies contained within the Devon Waste Plan that are of particular relevance to other organisations. These are the policies that the waste planning authority is relying on the local planning authorities to implement and “non-waste” developers to achieve. Therefore, this SPD supports the policies that will be relevant in determining all “non-waste” planning applications across Devon. The SPD is intended to provide guidance for developers who are preparing a planning application and for local planning authorities who are determining the applications.

In terms of non-waste policies, the key objectives of the Devon Waste Plan are: Policy W4: Waste Prevention places responsibility on the applicant to reduce the amount of waste produced throughout the lifecycle of their development and ensuring that waste is managed in line with the waste

116 https://new.devon.gov.uk/planning/planning-policies/minerals-and-waste-policy/devon-waste-plan 117 https://new.devon.gov.uk/planning/planning-policies/minerals-and-waste-policy/supplementary-planning-document Rockbeare NP Strategic Framework page 101 hierarchy. The policy requires a waste audit statement to accompany a planning application for major development to demonstrate how waste is prevented and managed at all stages of the development. Policy W10: Protection of Waste Management Capacity ensures the protection of waste management facilities, from non-waste development, that contribute to the achievement of managing Devon’s waste in accordance with the principles of the waste hierarchy, self-sufficiency and the proximity principle. Policy W21: Making Provision for Waste Management requires developers to make provisions to mitigate the impacts of their development on waste management infrastructure and to ensure that the development includes adequate provision for the management of its anticipated waste arisings.

The SPD makes it clear that although waste planning is a county matter and Local Plans and Neighbourhood Plans may not make the provision for waste development, they may complement the objectives of the Devon Waste Plan, as outlined in the Planning Practice Guidance. This can be by making the integration of local waste management facilities an integral part of promoting good urban design, including the provision of facilities for the storage and regular collection of waste. Policies in these plans could also promote sustainable design through promoting the use of recycled materials. Local plans and neighbourhood plans may potentially constrain waste management facilities in allocating sites for other uses either on, or near, an existing waste management site. The plans should therefore ensure any proposed development does not constrain operations. The Waste Consultation Zones published by the County Council can aid this site selection process, informing those preparing a plan of the site’s presence. The map below shows their proximity (in blue) to Rockbeare. Waste Consultation Zones have been introduced. These provide a buffer surrounding the site that trigger the need for local planning authorities to consult the waste planning authority.

Part 2 of Policy W10 states that non-waste development planning applications adjacent or close to a waste management site will be permitted where the applicant can demonstrate one of the following criteria: (a) the proposal will not prevent or restrict the operation of the existing or permitted waste management facility; or (b) any potential impacts on the operation of the waste management facility can be adequately mitigated by the applicant; or (c) there is no longer a need for the waste management facility, having regard to the availability of equivalent capacity within Devon; or (d) a suitable and deliverable alternative location can be provided for the waste management facility; or Rockbeare NP Strategic Framework page 102

(e) the proposal is in accordance with a site allocation in an adopted Local Plan

As regards the waste generated by new development Policy W21 requires applicants for non-waste development to demonstrate that they meet one of the following criteria: (a) the development includes adequate provision for the management of its anticipated waste arisings; or (b) the development makes financial of other provision for the off-site management of its anticipated waste arisings; or (c) the existing waste management infrastructure serving the development is adequate.

The SPD provides a checklist that seeks to ensure that the development proposal should provide sufficient evidence that it will achieve the lowest possible amount of waste generated and provide for the management of waste in accordance with the waste hierarchy.

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Appendix A The following strategy documents have been referred to in the preparation of this report:

A Sporting Future for the Playing Fields of England – Planning Policy Statement, Sport England, 2014 A Strategy for Growth 2013 – 2020, Devon County Council, 2013 Accommodating Wind and Solar PV Developments in Devon’s Landscape, Land Use Consultants, 2013 Devon Biodiversity and Geodiversity Action Plan, Devon County Council, 2009 Devon Minerals Plan 2011 – 2031, pre-submission version, Devon County Council, 2015 Devon Education Infrastructure Plan 2013-2031, Devon County Council, 2013 Devon Waste Local Plan 2011-2031, Devon County Council, 2014 East & Mid Devon Community Safety Partnership, 2012 East Devon Annual Monitoring Report, East Devon District Council, 2013 East Devon area Profile produced for Devon County Council, SERI Ekosgen, 2014 East Devon Draft Infrastructure Delivery Plan, East Devon District Council, 2013 East Devon Economic Development Strategy 2005/06 – 2008/09, East Devon District Council, 2005 East Devon Housing and Employment Study Final Report for East Devon District Council, Roger Tym, 2011 East Devon Open Space Study for East Devon District Council, Belap/JPC, 2011 East Devon Open Space Study Review, East Devon District Council, 2014 East Devon Strategic Housing Land Availability Assessment 2012 (Update 2013), East Devon District Council, 2013 East Devon Sustainable Community Strategy 2006-026 (up-dated 2010), East Devon Local Strategic Partnership East Devon Tenancy Strategy, East Devon District Council, 2012 Exe Catchment Flood Management Plan, Environment Agency, 2012 Exeter International Airport Masterplan, Exeter International Airport, 2010 Exeter International Airport Masterplan Addendum, Exeter International Airport, 2011 Exeter Housing Market Area Strategic Housing Market Assessment Final Report 2014/15, DCA, 2015 Good Practice Advice on Neighbourhood Planning and the Historic Environment, English Heritage, 2014, Homes and Communities Plan 2012–16: Living in this outstanding place, East Devon District Council, 2012 Housing Aspirations of Older People Living in Rural Devon, Community Council of Devon, 2011 Joint Health and Wellbeing Strategy for 2013-2026, Devon Health & Wellbeing Board, 2013 Landscape Character Assessment & Management Guidelines, East Devon District Council, 2008 Local Plan, East Devon District Council, 2016 Local Transport Plan 3, Devon and Torbay Strategy 2011 – 2026, Devon County Council, 2011 National Planning Practice Guidance, DCLG, 2015 National Character Area Profile, 148 Devon Redlands, Natural England, 2014 Neighbourhood Planning Roadmap, Locality, 2013 National Planning Policy Framework, Department for Communities and Local Government, 2012 Planning Policy Statement 10: Planning for Sustainable Waste Management, DCLG, 2011 Strategic Economic Plan 2014-2030 Final Submission: 31st March 2014, Heart of the SW LEP, 2014 Update on the Joint Health and Wellbeing Strategy for 2013-2016, Devon Health & Wellbeing Board, Sep 2013 Update on the Updated National Waste Planning Policy - Consultation Document 2013, DCLG, 2013 Waste Management Plan for England, DEFRA, 2013

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