20 October 1998

Dear John

REDEVELOPMENT OF CITY CENTRE TO PROVIDE SHOPPING, OFFICE, RESIDENTIAL AND CAR PARK AREAS; PRINCESSHAY & BEDFORD STREET (SITE BOUNDED BY HIGH STREET, PARIS STREET, POST OFFICE STREET AND CHAPEL STREET), EXETER CITY CENTRE: RAVENSEFT PROPERTIES LIMITED.

I refer to the above development proposals, to our meeting to discuss these on 21st September 1998, and to subsequent meetings between our officers.

I now write to confirm my officer comments on the scheme which, should the proposals remain unchanged, will be the basis for my report to the Development Control Committee when the County Council's formal views as strategic planning authority and highway authority are sought. I have endeavoured to relate these comments to the relevant policies of the approved Third Alteration (TA) and the emerging First Review (FR) of the Structure Plan. ·

Archaeology (TA CDEl4: FR C12) -
The archaeological assessment and evaluation work commissioned - by the applicant has identified that archaeological remains of national and county importance survive within the proposal area, albeit truncated and dissected by pre -and post war development. It is essential that this archaeology be investigated further, and to the highest standards, prior to as well as during demolition and construction phases. To this end the applicants should submit a detailed archaeological project design and method statement at this stage, prior to determination of the application.

Listed Buildings (TA CDE 6: FR C11) -
It is not proposed to demolish any listed buildings but the development would have a very considerable impact on the setting of the many listed buildings in the Cathedral Close and the Southernhay terraces as well as on the scheduled ancient monuments, the stretch of Medieval City Wall behind Broadwalk House and the ruins of St. Catherine's Chapel and Alms houses (see also detailed comments below).

Conservation Area (TA CDE8: FR C11) - and Enhancing The Urban Environment (FR C9) -
The Princesshay development site occupies the north east comer of the Central Conservation Area which was designated in 1992. The proposed area of redevelopment is entirely the product of the rebuilding of the 1950s & 60s after the extensive war destruction. 1t follows the proposals for the redevelopment of Exeter by Thomas Sharp ('Exeter Phoenix' 1946). Sharp's major achievement, outstanding in relation to large scale post war City Centre rebuilding elsewhere, was successfully to integrate the historic street pattern and surviving historic buildings with the new development. The proposed development would require the extensive demolition of this exemplar of post war planning. I understand that English Heritage has expressed grave concern at the scale and nature of the re-development, both in relation to its impact on the Sharp plan and the impact on the Cathedral, its setting and surrounding area. (See detailed comments below).

I have the following detailed comments as they involve the above policies and which require further consideration by the applicants:-

The scale of the department store would be quite disproportionate to any other building. It would dominate the entire area due to its height and bulk and would appear overwhelming from Southernhay, towering above the Georgian terraces. The store would be visible from Cathedral Close, especially from the higher ground at the west end and at close range at the east end by the entrance through to Southernhay. While this skyline is not in itself sacrosanct, the monolithic form and flat roof of the building would be wholly intrusive.

The department store would not be the only monolithic structure, there will also be the multi-storey car park which will occupy nearly the whole area from the store to the top of the new Mal1 on its east side. While the existing buildings present largely unattractive rear elevations to the City Wall they are broken up and not as talt as their proposed substitutes. As with the store, an excessively large and massive structure for the area would result in contrast to the relatively human scale of existing buildings. As with the store, an attempt has been made to mitigate the high blank side wall by constructing a terraced row of houses almost immediately in front of it, but the result is an incongruous contrast of scale and style.

There is significant concern at the overall loss of public pedestrian open space to accommodate the increased built floor area (see also Transportation Issues below). Bedford Street is a well used open space which enjoys a panoramic view of the north side of the Cathedral - a deliberate contrivance by Thomas Sharp. The store would occupy much of this area, leaving a considerably narrower view of the Cathedral, two thirds of the outlook would be lost. White the existing single storey shops on the south side are of a poor design their proposed replacements are also weak.

The proposed new Bedford Square is an inadequate substitute for the loss of the existing pedestrian space where Bedford Street joins High Street. This existing square is not only intensively used but is vital to breaking the otherwise continuous facades on the east side of High Street. The proposals would narrow this space down to no more than a narrow street width by building in front of the line of the existing facades, completely removing the existing attractive open effect. Existing planting along Bedford Street would be completely lost and the square would be dominated by the front elevation of the store on the east side and by the arched entrance to the Mall on the north.

The pedestrian link made by Catherine Street from Bedford Street to Cathedral Close would be entirely lost by the construction of a new building along the south side of Bedford Street: At the moment this street is an important desire line as well as presenting a most enticing view towards St. Martin's Church tower and the Close beyond. The store would black the major pedestrian route to Princesshay' arid High Street along Bedford Street, leaving only a narrow "canyon" f1anked by public WCs. This must be seen as a major interference with this established route. The Eastgate approach from High Street to the top of Princesshay will be narrowed to half of its existing width. As with the narrowing of Bedford Street this will not only remove pedestrian space but will also have considerable effect on High Street, increasing the sense of enclosure and reducing its interest as a series of linked spaces of different sizes and disrupting the existing coherent rhythm of the post war architecture to be retained.

The above concerns are, 1 believe, of a sufficient scale and concern, that unless resolved by the submission of revised details, they could lead to a recommendation of objection by the County Council under the above identified Structure Plan policies.

Strategic Shopping Implications (TA SHP1, SHP 2 and SHP3: FR E20, E21) -
It is considered that this proposal is in general accordance with the relevant Structure Plan policies except in respect of policy SHP1 (5) as this involves the environmental considerations detailed above.

Transportation Issues (TA TRN 1, TRN 7, TRN 11, TRN 16, TRN 27, TRN 25: FR T2, T3, T5, T9, T10, T14, T19) -
I have made some initial comments on the transportation aspects of the proposed development direct to WSP Graham Development Ltd. I share your concern at the lack of progress being made by WSP in identifying a suitable package of transportation measures which will successfully mitigate the impact of the proposal. As you are aware I received a copy of the car parking study which accompanies the Impact Assessment on 2nd October, 1999. This document forms one of the inputs into the Impact Assessment, as such it forms a key determinate of the transportation requirements of the development. I am in the process of preparing my comments on this document.

Notwithstanding the serious and potentially fundamental concerns associated with the numerical analysis in the Impact Assessment (a fact which I find most disturbing given the length of time spent in preparing the document), there are a number of more general areas of concern.

The proposal reduces the provision made for pedestrians in two key areas. First the extent of the proposed public areas represents a reduction on the current level. Second the network of proposed pedestrian routes lacks the permeability and convenience of the current network. Given that the proposal will increase the overall level of pedestrian activity this reduction in provision is most concerning. It is important that the level of demand on a number of key routes is not underestimated, for example that linking Southernhay with the City Centre and which is heavily used at lunchtimes and during peak periods.

On an associated issue there appears to be little to be gained for the public good from the proposed walkways agreement. I understand that the suggestion for such an agreement has originated from Land Securities. In my view it may be more productive to start from the premise that the public areas will be public highway and then consider how any concerns Land Securities might have might be met within that framework.

I have already set out my serious reservations about the provision made for cyclists and public transport in my letter to WSP of 12th September 1998. In the absence of any additional information from the consultants I have no further comments to make on the subject at this stage.

The provision made for community transport services (i.e. Shopmobility, Ring and Ride, voluntary car service, taxi-card) is an area that needs further consideration. In particular the location of the facilities, their relationship with dedicated parking areas, the access route to the main shopping area, and the location of drop-off and layover facilities for Ring and Ride buses are all key issues in ensuring that community transport services are provided for adequately.

The issue of car parking provision remains a key area of the development proposal. As you are aware I remain to be convinced that sufficient justification has been made in support of the proposed level of car parking.

Although my comments on transportation have naturally focused on the provision for non-car modes I think we are agreed that the Impact Assessment must include a complete assessment of the impact of the development on the highway network. In this context the assessment must extend out to include all junctions upon which the impact arising from the proposal is material. On the information currently available it appears that the assessment is too narrow in its focus.

Planning Obligations (FR S6) -
Notwithstanding my concern at the apparent inability of WSP to identify a suitable package of measures to mitigate the impact of the development proposal, I have given some thought as to what might be suitable. I enclose a schedule of that package of proposed transportation requirements of the Section 106 Agreement which I consider should be attached to any forthcoming planning consent. In preparing the package I have been mindful of the need to be realistic and to ensure that the measures included are relevant and appropriate to the development. I think it important to acknowledge that the proposed development will be one of the most significant developments in Exeter for a generation. This will be reflected in the extent and scale of the mitigation measures associated with the proposal.

Waste Arising Disposal (FR C21) -
Proposals for the management, re-use or disposal of the waste generated from the proposed redevelopment are still required

I hope you find these comments helpful. I will be pleased to discuss these further with you, and to be involved in any future discussions with the developers on these issues.

Yours sincerely,

Edward Chorlton

County Environment Director