BC 2nd Circulation NP Comments and Responses

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2nd Circulation NP Comments
Environment Agency
Appendix to Tim Spurway SA report
“Under Policy EN3 – Improving Flood Defences and Policy EN4 – Minimising Flood Risk, we
propose that the following sentence is added under these policies (particularly EN3): “Any flood
defence improvements will not only seek to address flood risk issues within Bishops Clyst but
will also look to maximise contribution to Policy EN1 in delivering any flood risk solution.” The
addition of these words (or similar) will strengthen recognition of the ecological and amenity
value of the River Clyst and its floodplain, which is clearly important to the Bishops Clyst
community.”
Simon Niles (DCC Education) email7.10.15
I think my only comment is whilst I acknowledge the aspiration that every child should be able
to attend the local school, I would point out that children moving into area during the academic
year may find securing a place difficult if the school has filled up from outside of catchment due
to its popularity. Places cannot be retained for children who may or may not move in.
Save Clyst St Mary – Residents group
Keith Williams email 30.9.15
“My only request is to include specific mention of the desirability of protecting and preserving
the Stable Club as a recreation facility. There is strong interest in the local community, and
there are potential groups who would take on this business as a going concern. This should
perhaps be linked to the benefit of such a facility to the potential residents of any housing
development at Friends Life, and thus to its value to developers.
Kate Walters email to GK 30.9.15
Just noticed a crucial glaring mistake in Bishops Clyst neighbourhood plan on page 26 Under the
heading HOUSING :Introduction
The old village of Clyst St Mary is largely a mixture of 19th and early 20th century
development with the addition of Manor Park, built in the 1960s and small numbers of
modern infill developments.
Most of the rest of the built up area consists of Winslade Park, a garden estate built in the
1970s, to the south of the Sidmouth Road.
Planning permission for 80 dwellings was given in December 2013 to Cavanna Homes for a
site to the east of the Village Hall alongside the Sidmouth Road. Also Bridge House, in the
centre of the village, is currently being redeveloped with planning permission for 13
Response
Action Taken
dwellings. The site containing Winslade House and Clyst House has been allocated in the
draft Local Plan as a site for future development with a provision of around 150 houses.
The estate was actually built in the mid 60's (1964/5 to be precise .... Somewhere we have
copies of the original sales brochures
Clyst Valley AFC –Letter from PC 7.10.15
The document is excellent and very comprehensive, though our comments are restricted to
aspects pertaining to Sports and Recreation. In that regard we fully support all of the comments
and recommendations, however we do not think the statements made about Clyst Valley AFC
accurately reflect the information we provided in 2014.
You are correct in stating that Clyst Valley is one of the oldest clubs in Devon, 124 years old,
always in Clyst St Mary. We think you could add that the club has been on its current ground
since 1957, a ground that is held in a trust in perpetuity for the benefit of the football club. The
football ground is also used extensively by the village school for its sport activities. The club
does currently run three teams but is surviving rather than thriving. In order for the club and
the ground to have a long term future for the benefit of itself and the school, investment is
urgently needed to provide an additional pitch and to bring the changing room facilities in to
the 21st century. The Football Association is looking for clubs to become “Community Clubs”
running teams for all age groups and both sexes and currently that is impossible with the
current facilities. The changing rooms are not even adequate for the school and certainly not
good enough for the school to arrange home fixtures for visiting teams, which is something
they would like to do. The pitch itself also needs investment to meet new minimum standards.
Without investment, it is difficult to foresee how long the club can remain within the village.
Short Mat Bowls J&I Smith email 29.9.15
What a comprehensive document! The only addition I would suggest is that the community
would like a bus connection to Topsham as the local Doctor’s Surgery is there.
Badminton Club M Macmillan email 29.9.15
I have not yet read every word of what is a very impressive document - well done to the
team.
Just a couple of points i've noticed so far.
(1) On p.5 (and p.25) Draftr says that the garden estate of Winslade Park was built in the
1960's. Our house 15 WPA - one of the first - was built in 1963. The upper part of Manor
Park was built in the early 1970's; the lower part (around the 'square') was earlier so
possibly late 1960's.
(2) p.26 Point 3, line 3. "If a garage is provide ...." Should be 'is to be provided' or just 'is
provided'.
Sports & Rec Committee PC letter 7.10.15
Many thanks for inviting the Club to comment on the excellent document that has been
formulated by the Neighbourhood Planning Group. Unfortunately we shall not be holding a
committee meeting before the end of the month in order to discuss the document and agree a
response, additionally of course the club is still in an embryonic state in that at present it does
not as yet manage any sport or recreational activities. However, on behalf of the club I would
like to make the following comments.
It is good to read that the requirements for leisure facilities as required by respondents to the
Community Questionnaire 2014 have been fully documented and that the much needed
recreational ground on the Friends Life site at Winslade Park is under threat of development.
With regard to that latter point the statements made under Policy SR2 – Protecting Existing
Sports Facilities are most welcome.
We also welcome the comments proposing that support should be given to the Club in running
any leisure facilities as quoted in the East Devon Playing Pitch Strategy 2015 document. In truth
however the club is more interested in running a facility rather than owning it. Our preferred
view with regards to ownership is that any land set aside for sports and recreation should be
held in a trust by the Parish Council.
Roger Taylor (NP Group member)
County Geological Site – Clyst St. Mary
With deletion of the statement on local geology given in the first outline of the neighbourhood
plan (obviously not really a planning matter), the presence of the County Geological site in Clyst
St Mary in parts of the old sandpit (occupied by the Village carpark and Rydon motors) has been
omitted from the circulation drafts 1& 2.
Quote -“Part of the old sandpit and sand outcrop beside the entrance to the Upper village car
park are designated as a County Geological Site because they provide a good and safe display of
significant geological features of the Dawlish Sandstone”
Would it be possible to reinstate this item in the environmental section of the plan and possibly
indicate its location on Map 2 Key Diagram – Ecological Areas?
Geological conservation is covered by ED Local Plan Strategy 47.
I must apologise for not spotting this omission earlier.
Tim Spurway (EDDC NP Officer) email 2.10.15
I sent the previous version to development management and they didn’t come to me with any
further comments at this point in time. Please note that we may have additional comments on
the plan once you undertake your formal pre-submission consultation.
I’ve just realised looking through the plan that I didn’t include number references in the map of
areas you wish to designate as Local Green Space. I have attached a revised version if you wish
to replace it. Also, you have titled it Map 7 but referred to it as Map 5 in policy SR1, you might
want to amend that.
Natural England – response to TS SEA Screening
There may be opportunities through the Neighbourhood Plan to identify suitable areas for the
creation and enhancement of Priority Habitats which would demonstrate how planning
applications could contribute to and restore the overall biodiversity network within the Parish.
We recommend that you make reference to the Devon Biodiversity Action Plan
Tim Spurway – email 20.8.15
Although I didn’t mention this in our initial feedback, I’ve had another look at this policy and
cannot see a particular reason for you specifically isolating the Sowton Conservation area and
the Cat & Fiddle residential park in the policy. I could understand it if you had an additional
policy allowing or otherwise preventing development in these two areas but I cannot see one in
your plan
Environment Agency – letter from Marcus Salmon 29.10.15
We welcome the inclusion of policies covering biodiversity/wildlife, improving flood defences
and minimising flood risk although we have some recommendations to improve the proposed
policies. We also consider that the draft plan should include policy which seeks to protect and
enhance the water environment within the parish.
Policy EN1 (Protect and enhance biodiversity)
We welcome the inclusion of this policy. We would, nonetheless, recommend that part (a) of
the policy also includes reference to priority species and habitats.
We also note that part (f) of the policy supports the use of sustainable drainage systems (SuDS)
but the restriction of storage lagoons. Attenuation of surface water is a central element of
SuDS schemes. Surface attenuation features and other elements of SuDS not only help to
reduce flood risk but can also help protect/enhance water quality and biodiversity.
It should also be noted here that this area could, in the future, form an important part of the
planned Clyst Valley Regional Park.
Policy EN3 (Improving flood defences)
We welcome inclusion of this policy which commits to supporting proposals to improve flood
defences for Clyst St Mary. The supporting text notes that our capital investment programme
includes plans to improve flood protection around Clyst St Mary. The plans are still in
development and various options for improving the standard of protection are being
investigated.
Policy EN4 (Minimising flood risk)
We support the first sentence of this policy to minimise flood risk. We do not, however,
support the second sentence which appears to contradict the first. The Planning Practice
Guidance (Ref. ID 7-080-20150323) illustrates the drainage hierarchy which states that the
preference is to control surface water and discharge it as high up the hierarchy as possible. The
first preference is to discharge to ground (infiltration), the next is to a watercourse, then to a
surface water or highway drain and finally as a last resort to a combined sewer.
As highlighted above, attenuation is crucial to delivering SuDS schemes. Surface water
attenuation features discharging to watercourses can deliver many benefits including flood risk,
water quality and biodiversity.
Water quality and the Water Framework Directive
We strongly recommend that the plan makes reference to and includes policy addressing water
quality issues.
With regard to the objectives of the Water Framework Directive:
 The lower River Clyst is currently at Moderate Ecological Status. The water-body is
failing with regard to surface water;
 The Aylesbeare Stream is at currently at Poor Ecological Status. The water-body is
failing with regard to fish (sediments), macrophytes and phytobenthos combined, and
phosphates (primarily from agricultural sources);
 The Grindle Brook is currently at Moderate Ecological Status. The water-body is failing
with regard to fish (barriers to migration) and macrophytes and phytobenthos
combined.
It is the target for these water-bodies to meet Good Ecological Status by 2027. Therefore, any
new development within the parish must not cause deterioration from present status and the
Neighbourhood Plan should seek opportunities to meet the desired status.
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