76m high Wind Turbine, Tatson Farm, Pyworthy – pending

We submitted an objection to Torridge District Council about this application on 17th April 2025.

3 dwellings, Land at Mill Road, Bradworthy – pending

1/0724/2925/OUT. We submitted the following objection to Torridge District Council on 25th September 2025.
Dear Sirs

Devon CPRE objects to the above planning application.

Although the Council cannot currently demonstrate a five-year supply of deliverable housing land (5YHLS), engaging the “tilted balance” under paragraph 11(d)(ii) of the National Planning Policy Framework (NPPF, December 2024), the adverse impacts of this proposal significantly and demonstrably outweigh the benefits when assessed against local and national policies taken as a whole. The proposal fails to meet essential criteria related to sustainable location, effective use of land, well-designed places, affordable housing, and climate change mitigation.

Sustainable Location

The site lies outside the defined settlement boundary of Bradworthy and extends into open countryside, conflicting with Policy ST07(4) of the Local Plan which restricts development in the countryside unless certain exceptions apply. The proposal also fails Policy ST21 (b) – the application is made in outline potentially decreasing the likelihood of the development coming forward in a timely manner, when compared with a full application. The development’s extension beyond the existing village edge, results in elevated, harmful sprawl rather than sustainable “rounding off,” undermining policy objectives.

Effective Use of Land

Policy ST14 of the Local Plan stresses the importance of enhancing environmental assets and conserving landscape character. The application fails to submit key technical assessments such as a Landscape Assessment, Arboricultural Impact Assessment (AIA), and agricultural land classification. Without these, it is impossible to assess impacts on landscape sensitivity, biodiversity, or best and most versatile (BMV) agricultural land, contrary to Local Plan Policy DM08A, DM08, ST04 and NPPF Paragraph 187 (b) and 136. The lack of such evidence means the site cannot be considered an effective or sustainable use of land – the developable area is yet to be determined.

Well-Designed Places

The proposed development does not respect the site’s topography or local character, contrary to Policy DM04. The visual prominence created by the 5-metre elevation rise along the site frontage (west to east) means the proposal would harm the village’s character and landscape setting. This fails the requirement for development to positively contribute to place-making and respect landscape sensitivities, as supported by NPPF Paragraphs 135 and 187.

Affordable Housing

While the delivery of housing can contribute to affordable housing supply in line with Policy ST18, the scale of this proposal ‘up to five dwellings’ not only side steps the obligation for affordable housing but is modest and does not outweigh the significant adverse environmental and landscape impacts identified.

Climate Change

The absence of any AIA and inadequate protection for mature trees and hedgerows conflicts with Policy DM08 and NPPF Paragraph 187(b), which seek to protect biodiversity. Green infrastructure plays a vital role in climate change mitigation and adaptation. The proposed development risks loss or damage to these assets, undermining local and national climate resilience objectives.

Until full levels and grading plans are submitted, along with an assessment of carbon impact from reprofiling, the proposal cannot be properly scrutinised against the requirements of Local Plan Policy ST14 and DM08 and the overarching principles of sustainable development in Paragraph 8 of the NPPF.

Conclusion

In applying the paragraph 11(d)(ii) “tilted balance” test, the adverse impacts arising from harmful landscape and visual effects, loss of potential BMV agricultural land, failure to safeguard biodiversity and green infrastructure, and unsustainable village expansion significantly and demonstrably outweigh the limited benefits of up to five new dwellings. The application does not comply with national or local planning policies and should be refused.

Yours faithfully

10 dwellings, Black Torrington – Pending

1/0664/2025/FULM 11th September 2025. We submitted the following objection:
Dear Sirs

Devon CPRE objects to this planning application.

The Planning Statement relies heavily on the economic benefits of housing delivery to justify this development; it fails to adequately demonstrate how the proposal aligns with the four key policy areas now central to National Planning Policy Framework (NPPF) Paragraph 11(d)(ii) assessment including:

1. Sustainable Location

The Planning Statement and Design and Access Statement (DAS) is vague on how the development supports sustainable transport, access to services, or low-carbon living.

No evidence of proximity to public transport, active travel infrastructure, or integration with existing settlements.

Local Plan Policy ST01 ‘Principles of Sustainable Development’ requires development to contribute positively to the social, economic, and environmental dimensions of sustainability.

2. Effective Use of Land

No density analysis or justification for spatial efficiency. Section 11 of the NPPF stresses sensitivity to context, safeguarding and improving the environment and ensuring safe and healthy living conditions, while encouraging higher densities. This balance is not addressed.

3. Well-Designed Places

The DAS lacks:

A design evolution narrative or concept rationale.

Analysis of local character, topography, or vernacular architecture.

Consideration of community input, legibility, or permeability.

Details on architectural quality, materiality, or place-making.

Section 12 of the NPPF calls for “Development that is not well designed should be refused”.

Local Plan Policy ST04 demands high-quality design that reflects local character, promotes legibility and permeability, and supports healthy lifestyles.

Contrary to both DM05 and NPPF Paragraph 96. The development fails to demonstrate safe and well-connected pedestrian and cycle routes to facilities beyond the site. With no mention of active travel infrastructure, permeability, or sustainable transport links.

Local Plan Policy DM04 highlights that development should demonstrate quality through layout, scale, massing, and detailing. No Building for a Healthy Life (BfL12) assessment is provided, and the DAS lacks the depth, evidence, and design rationale expected under both NPPF and the Local Plan, to ensure delivery of high quality placemaking.

Sustainability

No quantified energy performance targets (e.g. EPC ratings).

No lifecycle carbon analysis or commitment to standards like Passivhaus or Future Homes Standard.

No strategy for resilience, renewables, or carbon reduction.

Local Plan Policy ST02 Requires development to reduce carbon emissions and promote energy efficiency.

This is not portrayed as a forward-facing development.

Insufficient detail

1)The absence of a Landscape and Visual Impact Assessment (LVIA) or Landscape Visual Appraisal (LVA) is a significant omission, especially given the Conservation Officer’s comments and the sensitivity of the site within LCT 1F: Farmed Lowland Moorland & Culm Grassland and DCA 36: High Torridge Culm Plateau.

The DAS and Planning Statement do not adequately assess landscape impact for a site in such a sensitive location. Without an LVIA or at least an LVA, the application lacks the necessary evidence to weigh visual harm against planning benefits. There is no structured assessment of viewpoints, receptors, or magnitude of change, essential for a site in a sensitive landscape. The DAS doesn’t explain how the layout, massing, or orientation of buildings responds to the landscape’s form or character.

2)The Planning Statement notes the site’s slope and visibility, suggesting visual impact. But there are no cross sections or contextual drawings showing the development in context with properties to the north and west. There appears to be a 3.5m level difference, from 107.25m at the road to 110.75m at the top of the site, this is quite significant, especially in a rural or edge-of-settlement context. Without site sections, the application lacks a critical tool for understanding how the proposed development will sit within the landscape and how visible or intrusive it might be.

NPPF paragraph 187 requires planning decisions to protect and enhance valued landscapes. Without an LVIA/LVA and sections, it’s difficult to demonstrate compliance. Local Plan policies including DM08A and ST14 require development to respect landscape character and visual amenity, the submission documents fail to provide robust evidence to demonstrate this.

3) The NPPF encourages early engagement and transparency. Referring to the Pre-application response FPEG/0106/2025 without sharing it runs counter to this advice.

4)There is no reference to agricultural land classification, which is a material planning consideration and both the NPPF and Local Plan discourage development on best and most versatile agricultural land (Grades 1, 2, and 3a).

5)No BfL12 assessment has been submitted, the application falls short of validation and Local Plan Policy DM04 requirements, and fails to demonstrate design quality, especially under Paragraph 11(d)(ii) of the NPPF, which now places explicit weight on securing well-designed places.

Summary

Under the NPPF, the adverse impacts, including lack of design quality, poor sustainability credentials, insufficient details (including landscape visual assessment/sections) significantly and demonstrably outweigh the economic benefits of housing delivery. The proposal does not convincingly meet the enhanced criteria of Paragraph 11(d)(ii) and therefore may not benefit from the presumption in favour of sustainable development.

Yours faithfully

Slurry Lagoon, Land at Rhode Farm, Tiverton, Mid Devon – pending

25/00961/MFUL We have submitted the following objection to Mid Devon District Council

20th January 2026

Dear Sirs

Devon CPRE objects to this application.  We are concerned that the application lacks critical information on environmental, odour, and visual impacts, and therefore it is not possible to determine whether the development would be acceptable. Additional information should be provided before any decision is made.

EIA Screening

The proposed development site exceeds 0.5 hectares and appears to fall within Schedule 2, Column 1 Agriculture and Aquaculture (a) –Projects for the use of uncultivated land or semi-natural areas for intensive agricultural purposes of the Environmental Impact Regulations (EIA) 2017.

Under the EIA Regulations 2017, the council should screen the development to determine if a full Environmental Impact Assessment is required. No evidence of such screening has been provided.

Visual Impacts

The plans, topographical survey, and cross-sections do not adequately show the lagoon and associated works (including access track, earth bund (Minimum height 250mm), and 1.5 m high fence) relationship to landform, field boundaries, or nearby buildings.

Odour Impacts

An Odour Management Plan has been submitted, but there is no dedicated Odour Assessment. The submitted Air Quality Assessment (Greenavon Ltd) focuses on e.g NH₃ concentrations and nitrogen deposition for ecological receptors. It does not address odour events, operational activities (e.g., pumping, emptying, cover removal), the composition of the slurry is not clearly defined, nor impacts on nearby residents. This limits the reliability of the assessment in terms of odour impact on living conditions, and determining whether the management plan is acceptable.

Devon CPRE are aware that there is significant local objection to the proposal based on a number of material planning considerations.

Yours faithfully

120 dwellings, Callington Road, Tavistock, West Devon – pending

We have submitted the following objection to this application – 3771/25/OPA – Land at Callington Road, Tavistock, outline application for up to 120 dwellings.

Dear Sirs

Five-Year Housing Land Supply and the Presumption in Favour of Sustainable Development

It is acknowledged that the Council cannot currently demonstrate a five-year supply of deliverable housing land, and that the presumption in favour of sustainable development is therefore engaged. However, even where this presumption applies, it does not override policies within the National Planning Policy Framework (NPPF) that protect assets of particular importance, including Best and Most Versatile Agricultural Land (BMVAL) and policies that require development to be delivered in sustainable locations and to achieve high-quality design. In this case, the harm arising from the proposed development engages these policies directly.

Best and Most Versatile Agricultural Land (BMVAL)

Approximately 91% of the site is classified as Grade 3a agricultural land, which constitutes BMVAL. This land is capable of consistently producing moderate to high yields of a wide range of crops and is therefore a finite and valuable resource.

The current NPPF(December 2024) is clear that significant weight should be given to the protection of BMVAL, and that where development of such land is proposed, lower quality land should be used in preference. The loss of BMVAL should only be justified where there is a clear and overriding need and where no reasonable alternatives exist.

The proposed development would result in the permanent loss of BMVAL, with no scope for reinstatement. This loss must be considered cumulatively, not only in isolation but in the context of:

Local availability of BMVAL
Regional agricultural capacity
National food security and resilience
Incremental erosion of BMVAL risks reaching a cumulative tipping point, contrary to the objectives of sustainable development set out in the NPPF. The irreversible nature of this loss weighs heavily against the proposal and conflicts with both national and local planning policy.

Sustainability of Location and Accessibility

The Planning Statement claims that the site represents a “suitable and sustainable location” for residential development, the Design and Access Statement showing proximity to a school within 800 metres, providing limited detail on active travel connectivity to nearby services and facilities. This distance appears to be measured as the crow flies, rather than reflecting actual, safe, and convenient walking routes.

Both versions of the NPPF (December 2024 and draft December 2025) support walking, cycling and public transport and aim to reduce reliance on the private car. At present, there is insufficient evidence to demonstrate that:

Safe pedestrian routes exist or can be delivered to connect the site to Tavistock’s services and facilities.
Gradients and crossings are suitable for all users.
Routes are legible, overlooked, and usable year-round.
Without clear evidence of real-world accessibility, the site cannot reasonably be described as sustainable in NPPF terms.

Design Evolution, Movement, and Placemaking

The Design and Access Statement (Section 5.2) demonstrates that vehicular movement has been the primary driver of the site layout. In contrast, walking, wheeling, and cycling connectivity appear secondary and inadequately resolved (as highlighted above).

The scheme prioritises internal car movement over:

Connectivity to Tavistock.
Permeability within the site.
Creation of walkable neighbourhoods.
Although Building for a Healthy Life is referenced, no assessment against its criteria has been provided, contrary to best practice and Local Plan expectations for demonstrably high-quality residential design.

Incidentally,the draft NPPF(December 2025) appears to make it more explicit that design quality isn’t optional or supplementary, but an integral part of the NPPF’s structure. The draft NPPF emphasis on design quality throughout (with less room for late‑stage remediation) represents a higher bar for demonstration of design justification and placemaking rationale at this stage.

Landscape, Topography, and Development Capacity

The Landscape and Visual Impact Assessment (LVIA) confirms that the site slopes from approximately 115m AOD in the south-east to 100m AOD in the north-west. This topography is a defining characteristic of the site and places clear constraints on its development capacity.

While the Design and Access Statement commits to “working with the existing topography and landform where possible”, there is insufficient evidence at outline stage to demonstrate how this principle would be achieved.

The NPPF requires that development:

Is sympathetic to local character and landscape.
Responds positively to local context.
Accommodating development at the scale proposed is likely to require:

Extensive cut-and-fill operations.
Stepped building forms.
Raised platforms or engineered retaining structures.
These interventions would:

Increase visual and spatial impacts.
Erode the rural character of the area.
Risk unacceptable harm being deferred to later reserved matters stages.
Given the sensitivity of the site, the design response to topography must be tested and demonstrated at outline stage, in accordance with the NPPF’s emphasis on early design quality. This should include:

Test blocks.
Indicative street sections.
Illustrations showing how streets and plots traverse changes in level.
In the absence of this information, the proposal fails to provide sufficient certainty that landscape and character impacts can be adequately mitigated.

Density

The scheme’s absence of a design‑led justification for the proposed 34 DPH, including why this density is appropriate relative to connectivity, site constraints, and local character means the proposal does not demonstrably align with either the current NPPF’s emphasis on efficient land use and well‑designed places, or the draft NPPF’s heightened expectations that schemes make the most of site potential consistent with connectivity and sustainable travel.

Conclusion

Without evidence that design quality has genuinely been tested and justified in this application, it is not possible to conclude that the proposal satisfies national policy (either current or draft) for high‑quality placemaking. This shortcoming weighs against the application when considering design, connectivity, and liveability key policy criteria at both national and local levels.

Yours faithfully

9 dwellings, Land adjacent Eastacombe Rise, Heanton Punchardon, North Devon – pending

4th February 2026. We have submitted the following objection ref application 81297 to North Devon District Council:

Dear Sirs

Devon CPRE objects to this planning application.

Five-Year Housing Land Supply and the Presumption in Favour of Sustainable Development
It is acknowledged that the Council cannot currently demonstrate a five-year supply of deliverable housing land and that the presumption in favour of sustainable development is therefore engaged. However, in the context of a Permission in Principle application, the operation of the tilted balance is necessarily limited to the consideration of location, land use and amount of development.
The presumption does not override policies within the National Planning Policy Framework (Framework) that protect areas or assets of particular importance, including heritage assets and their settings, valued landscapes, protected trees and ecological networks. In this case, the harm arising from the proposed amount of development engages these policies directly.
Furthermore, when assessed against the Framework as a whole, the adverse impacts of granting Permission in Principle for up to nine dwellings would significantly and demonstrably outweigh the limited benefits arising from an in-principle approval, particularly given the uncertainty as to whether development of this scale can be achieved without unacceptable harm.
Principle of Development and Landscape Character
The site is bounded by established hedges and hedgebanks and is subject to a Tree Preservation Order, all of which require a generous spatial setting in order to retain the existing landscape character. The site lies within Landscape Character Area 5c: Downland, which includes valued landscape attributes such as wildlife habitat within farmland and the associated hedge network. These characteristics are highly sensitive to intensification and suburban forms of development.
The site is also constrained by its topography (ref. topographic survey taken from application ref. 74661). There is an approximate 4metre rise in levels across the site from west to east, from approximately 63.14 metres to 66.89 metres. In addition, there is a significant level difference between the site and the existing dwellings to the south (“The Small House”), which e.g. sits at approximately 69.01 metres, compared with site levels of approximately 65.24 metres in the area identified as plots 5, 6 and 7.
This topography is a defining characteristic of the site and places clear limits on its development capacity. Accommodating development of the scale proposed would be likely to require engineered solutions, stepped building forms or raised platforms, all of which would increase visual and spatial impacts and further erode the rural character of the area.
The proposal seeks Permission in Principle for up to nine dwellings on a site of approximately 0.486 hectares (equating to a density of 18.5 dwellings per hectare). This level of development represents a significant intensification that would erode the loose-knit, rural character of this part of the village.
Relationship to Previous Appeal Decision (Ref: 3301506)
The Inspector noted the presence of a variety of detached houses and bungalows set within generous gardens, creating a spacious and rural character, and concluded that two dwellings would not significantly harm the setting of nearby listed buildings.
The current proposal, however, seeks Permission in Principle for up to nine dwellings, a substantial increase in scale and intensity. The conclusions of the earlier appeal cannot reasonably be extended to justify development of this magnitude, particularly when the site’s topography and level changes are properly taken into account. Indeed, the character relied upon in that decision would be fundamentally altered by the level of development now proposed.
Amount of Development and Uncertainty at Permission in Principle Stage
Whilst it may be reasonable to assume that no more than nine dwellings could physically be accommodated within the site boundary, it cannot be assumed with the same certainty that the site is sufficiently scaled to accommodate nine dwellings appropriately, given the constraints present.
At the Permission in Principle stage, the Council must be satisfied that the proposed amount of development is suitable in principle. In this case, there is insufficient detail to demonstrate that nine dwellings could be delivered without unacceptable harm to the landscape character, changes in landform, effects on neighbouring amenity, protected trees, hedgebanks, biodiversity interests, and the rural setting of nearby listed buildings.
The illustrative drawings indicate that terraces, semi-detached dwellings, parking courts and small plots would be required to deliver the stated quantum of development. On a sloping site, such forms would intensify built mass and introduce suburban characteristics that are at odds with the established loose-knit pattern of development. Such harm would arise directly from the scale of development proposed and cannot be deferred to the Technical Details Consent stage.
Impact on Residential Amenity
The relationship between the proposed development and the existing dwellings to the south is of particular concern. The difference in levels, approximately 3.77 metres between the existing dwelling at 69.01 metres and the site levels around plots 5, 6 and 7 at approximately 65.24 metres, creates the potential for significant amenity impacts.
In order to accommodate the proposed quantum on a sloping site, development is likely to involve increased building heights, stepped forms or altered ground levels. These interventions would exacerbate the potential for overlooking, loss of privacy and overshadowing. These impacts arise directly from the amount and intensity of development proposed and cannot be adequately mitigated at the Technical Details Consent stage if Permission in Principle is granted for nine dwellings.
Heritage Setting
Although the nearest listed buildings lie some distance from the site, they are experienced within a wider rural and landscaped context. The introduction of development at the scale proposed, particularly where level changes may increase visual prominence, would result in harm to their setting through the erosion of the spatial and rural qualities previously identified as important.
Conclusion
Taking into account the site’s sensitive landscape context, sloping topography, the presence of existing dwellings, protected trees and hedges/hedgebanks, the contribution the site makes to the rural setting of nearby listed buildings, and the uncertainty surrounding the suitability of the proposed amount of development, it is not evident that the site is suitable for residential development in principle at the scale proposed.
Yours faithfully

150MW BESS, Land south of Hazelhurst, Raymonds Hill, Axminster – At Appeal

24/0096/MFUL – Land Just South Of Hazelhurst Raymonds Hill Axminster. Proposed construction, operation and maintenance of a Battery Energy Storage System (BESS) with associated infrastructure and works including highway access, landscaping and biodiversity enhancements. We submitted two objections to this proposal, situated close to the parish of Hawkchurch in East Devon. The application is now at appeal (ref 3369854). There will be an inquiry, scheduled to start on 10 March 2026 lasting for 4 days and will be a cojoined inquiry – heard together with the appeal for the BESS at Land west of Wareham Road, Scouse Farm, Axminster (ref 3369953).

50MW BESS – Land to west of Wareham Road, Scouse Farm, Axminster – Appeal dismissed

24/2067/MFUL. The installation of 50MW battery clusters with ancillary equipment, including inverter units, 132kV transformer compound, site welfare and switch room, and two water tanks to provide standby, emergency electricity. November 2025. The appeal has been withdrawn. We had objected to the original planning application.

80MW BESS – Land at Newlands Farm, Axminster – At Appeal

Our objection submitted on 30 January 2025 to East Devon District Council ref 24/2650/MFUL. An appeal has now been lodged, (January 2026) and an Inquiry will be held. The Inquiry is currently scheduled to commence on 12 May 2026 and is expected to be take place over 4 days.  Comments can be made online a acp.planninginspectorate.gov.uk. Quoting appeal reference: 6003095
The deadline is 25 February.

Installation and operation of a solar farm, variation of condition, Shebbear – Pending

1/0924/2025/FULM We submitted the following objection to Torridge District Council on 16th January 2026.

Dear Sirs

Devon CPRE objects to planning application 1/0924/2025/FULM.  

The application seeks to extend the solar farm life indefinitely or failing that, to 55 years.  This goes against the ethos originally behind all renewable energy schemes, which was that they were temporary blights on the landscape, typically a generation or about 25 years.  

As the solar panels age they become less efficient, the efficiency typically falling by between ½ and 1% per year.  Thus after about 30 years the benefit from the solar farm would have fallen to such an extent that it would no longer outweigh the harm to the landscape and the loss of productive farmland.

Yours faithfully

140 dwellings – Land Adjacent To Gerway Nurseries, Ottery St Mary – Pending

Ref: 25/2468/MOUT. Our objection dated 11th december 2025 is below:

Dear Sirs

Devon CPRE objects to this application.

Principle of development

The site is rural in character and lies within the countryside, outside any ‘Built Up Area Boundary’. Development here is contrary to Strategy 1 (Spatial Strategy for Development in East Devon) and Strategy 7 (Development in the Countryside), both of which strictly control new countryside development. The Council cannot currently demonstrate a 5-year housing land supply, however, the harm caused by development outside defined boundaries must still be weighed heavily in the planning balance.

It is noted that the site is subject of a smaller draft allocation Otry_21 (see below) and this proposal should be refused in favour of more sustainable, plan-led alternatives.

Departure from East Devon Local Plan 2020-2042 Site Selection Ottery St Mary (Otry_21)

The proposal’s inclusion of previously discounted land (Area GH/ED/29b) is not justified.

The boundary extension effectively creates a much larger development footprint, contrary to the Site Selection Report https://eastdevon.gov.uk/media/swaltw2u/sal-035-ottery-st-mary-site-selection-report.pdf recommendation that only part of the wider GH/ED/29 (19.32 hectares) land parcel should be allocated (Otry-21), and subject to further highways and archaeological assessment.

The proposal departs from the Local Plan evidence base and undermines the rationale for a limited, tightly-defined allocation. (Extract below taken from Landscape Visual Impact Assessment p10 showing draft allocation and wider site boundary).Screenshot 2025-12-10 at 11.46.37.png

Landscape impact and inconsistent density calculations

National policy requires density to be derived from a design-led assessment of the specific site context, including landscape sensitivity and settlement edge character. It should be noted that the view points assessed within the Landscape Visual Impact Assessment do not appear to have been agreed with the Local Planning Authority or National Landscape Team. ‘GLVIA3 (Landscape Institute & IEMA, 2013)’ clearly recommends consultation on LVIA scope, which includes viewpoints.

The density of the now enlarged site conflicts with both:
(a) the density implied by the original policy allocation Otry_21 (GH/ED/29a) (2.37 hectares for 70 dwellings), and
(b) the density that would be expected on a sensitive settlement edge.

Original allocation:

70 dwellings on 2.37 ha = 29.5 dwellings per hectare (dph).

Wider site density now proposed:

140 dwellings on 7 ha ≈ 20 dph.

This illustrates two critical issues:

The enlarged site significantly reduces the overall density, creating scope for a much looser, more dispersed form of development that risks excessive land-take into open countryside.

The Council’s original evidence supported a higher density on the smaller, more contained site, not a large low-density expansion into GH/ED/29b

Best and most versatile (BMV) agricultural land and biodiversity net gain (BNG)

The site comprises Grade 2 and 3 BMV agricultural land, and development would result in the irreversible loss of high-quality farmland contrary to National Planning Policy Framework (NPPF) paragraph 187(b).

The applicant intends to deliver 10% BNG onsite, meeting only the national minimum. Emerging Local Plan Policy 87 requires 20% BNG, reflecting the district’s high sensitivity and the aim to go beyond national minimums. In this case, the planning balance weighs against this proposal.

Heritage

Emerging Local Plan Policy SD04 and the Site Selection Report for Ottery St Mary clearly highlight that the allocation is only acceptable subject to archaeological assessment. The conclusion of the ‘Historic Environment Desk- Based Assessment’ (p37) states that it is: “highly unlikely” that the remains would preclude development, this is not evidence-based, because this statement is made without excavation, trial trenching, or dating of the identified anomalies. This falls short of NPPF and Local Plan requirements for proportionate, pre-determination evaluation where heritage sensitivity is known(Paragraph 207 NPPF).
The assessment confirms that remaining hedgerows may qualify as “important” under the 1997 Hedgerow Regulations. Hedgerows are noted within the site selection assessment and form part of:

the historic landscape pattern,

the medieval/post-medieval field system,

and the wider heritage narrative of the site.

However, the assessment only states that “suitable notice” must be given to the Council if removal is proposed, which does not constitute an assessment of the historic or archaeological value of these boundaries, nor does it evaluate significance as required by policy.

Design and Local Distinctiveness Concerns

A ‘Building for a Healthy Life’ assessment, advocated in emerging Policy DS01, has not been considered in the Design and Access Statement.
The site slopes with the lowest point at 38m AOD (north edge) to 62m AOD ( south eastern boundary).The sloping nature of the site will require bespoke design responses such as levelling and retaining works, yet these have not been fully considered (cross sections are limited). Slopes may influence drainage, building heights (noting height parameter plan), and visibility, particularly toward flood zones. Crucially, the carbon impact of extensive levelling and re-profiling has not been assessed. Such works involve significant earth movement, machinery use, and embodied energy, which directly conflict with sustainability objectives. A landscape-led approach will be important to ensure housing integrates with existing topography.

Emerging Policy DS02 states: “Proposals for major development schemes developments of 50 or more dwellings and those in environmentally or heritage sensitive locations especially in or adjacent to a National Landscape will be required to be supported by a design code agreed with or produced by the council as planning authority. Codes, amongst other matters, may specify density recommendations for key allocations.” Whilst the preamble to Chapter 10 of the emerging Local Plan highlights: “Design codes will guide future proposals, ensuring new development is resilient and well-integrated into the environment”. This development would benefit from a design code.
Summary

The community has highlighted a number of additional concerns, including drainage and highway safety and it is noted that the statutory consultees have yet to respond on these points

While the Council cannot currently demonstrate a five-year housing land supply, the presumption in favour of sustainable development and the provisions of paragraph 11(d)(ii) of the NPPF requires that permission should be granted unless “any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.” In this case, the identified harms including encroachment into open countryside, loss of BMV agricultural land, inadequate assessment of heritage significance, departure from the emerging plan-led spatial strategy and site selection evidence, unresolved design and density concerns, and landscape/visual harm arising from unjustified boundary expansion collectively amount to significant and demonstrable adverse impacts. These clearly outweigh the benefits of the proposal.

Yours faithfully

151 dwellings, Land north of Hulham Road, Exmouth – Pending

Our objection to this planning application, Ref 25/2221/MOUT, which we submitted to East Devon District Council on 2nd December 2025, is below:
Dear Sirs

Devon CPRE objects to this application.

Principle of development
The site is rural in character and lies within the countryside, outside any ‘Built Up Area Boundary’. Development here is contrary to Strategy 1 (Spatial Strategy for Development in East Devon) and Strategy 7 (Development in the Countryside), both of which strictly control new countryside development.

Although the Council cannot currently demonstrate a 5-year housing land supply, the harm caused by development outside defined boundaries must still be weighed heavily in the planning balance.

Furthermore, the site is not a preferred residential allocation in the Regulation 19 Draft Local Plan, which has already been considered and adopted by the Strategic Planning Committee.

Built Up Area Boundary
Unlike recently approved application 25/0007/MOUT, this site is not contiguous with the built up area boundary of Exmouth as defined in the current Local Plan. Only the smaller first site is adjacent to the emerging built up area boundary (west of Sowden Break). The remainder of the site is detached, reinforcing its unsuitability for residential expansion.

Design and Local Distinctiveness Concerns
The Building for a Healthy Life assessment, advocated in emerging Policy DS0 (Design and Local Distinctiveness), has not been addressed in the Design and Access Statement.

The gently sloping nature of the site will require bespoke design responses such as levelling and retaining works, yet these have not been fully considered. Crucially, the carbon impact of extensive levelling and reprofiling has not been assessed. Such works involve significant earth movement, machinery use, and embodied energy, which directly conflict with sustainability objectives.

Density. The statement that the scheme’s density “complements the local area and recently approved/constructed developments to the south”. (Design and Access Statement (DAS) p13) is not a valid justification for the proposed density. National policy requires density to be derived from a design-led assessment of the specific site context, including landscape sensitivity, settlement edge character, and emerging policy designations. This site occupies a far more sensitive position on the rural edge of Exmouth and within an area identified for future designation as a Coastal Preservation Area, where a softer, lower-density transition is essential. Simply replicating suburban densities from development on the southern side, located within the established urban fabric and subject to different constraints, fails to demonstrate that an average density of 34 dph is appropriate here. The DAS therefore does not provide an adequate or context-responsive justification for the proposed density.

Emerging Policy DS02 (Housing Density and Efficient Use of Land) states: “Proposals for major development schemes developments of 50 or more dwellings and those in environmentally or heritage sensitive locations especially in or adjacent to a National Landscape will be required to be supported by a design code agreed with or produced by the council as planning authority. Codes, amongst other matters, may specify density recommendations for key allocations.” Whilst the preamble to Chapter 10 of the emerging Local Plan highlights: “Design codes will guide future proposals, ensuring new development is resilient and well-integrated into the environment”. This development would benefit from a design code.

These omissions undermine the quality, distinctiveness, and environmental responsibility of the proposed development.

Availability of Brownfield Alternatives
According to latest research from CPRE, Exmouth has 27 brownfield sites suitable for housing development, contributing to over 16,700 potential homes across Devon. https://www.cpredevon.org.uk/more-than-16700-new-homes-in-devon-could-be-built-on-brownfield-land-october-2025/ Prioritising greenfield countryside development over available brownfield land is inconsistent with sustainable planning principles and the national policy emphasis on brownfield-first development.

Additional Objections from Exmouth Site Selection Report (East Devon Local Plan 2020–2040)

· Dependence on Southern Land Development

Both Lymp 09 and Lymp 10 were only considered credible if land to the south is developed first. Report wording explicitly states:

“Lymp 09 credible if land to the south was also developed (and done so before this site).”
“The site would only appear credible as an allocation for development if land to the south was also developed (and done so before this site).”
This sequencing requirement highlights the independent deliverability of these sites, making them speculative.

· Agricultural Classification Not Assessed
Both sites are described as comprising gently sloping fields in agricultural use, but the report omits any reference to agricultural land classification. This is a critical gap, as national and local planning policy requires assessment of agricultural quality before considering land for development. (Note the agent fails to address whether the sites are considered Best and Most Versatile Agricultural Land in the Planning Statement).

· Access Constraints and Tree Preservation Orders (TPOs)
HELAA panel findings state (Parcel 10):
“Probably unachievable due to TPO coverage limiting necessary improvement to Hulham Road – to provide improved pedestrian access to this site.”

The allocation recommendation was made speculatively, assuming constraints can be overcome. (Note, arboricultural assessment has yet been undertaken by the Council’s specialist to consider whether this constraint has been overcome within this submission).

Trees and Hedgerows
The justification for removal of two category B trees which are specifically recognised as contributing to the local environment and should be retained wherever possible. This is to create vehicular and pedestrian access and suggests the layout has been prioritised for convenience rather than genuine landscape protection. Have alternative access arrangements been explored to avoid tree and hedge loss? Policies D2 (Landscape Requirements) and D3 (Trees and Development Sites) of the East Devon Local Plan require development to conserve and enhance trees and hedgerows. The removal of category B trees and sections of hedgerows is inconsistent with these policies, especially where alternatives could have avoided loss?

The National Planning Policy Framework(NPPF) also emphasises protecting biodiversity and valued landscapes, this proposal undermines those principles.

Proposed Coastal Preservation Area (CPA)
Residents experience the site as part of the wider landscape setting of Exmouth, and its contribution to local amenity. Development here would introduce built form into an area that currently provides relief from urbanisation.

While the adopted Local Plan did not include this site within the CPA, the emerging Local Plan rightly proposes its inclusion. The NPPF emphasises conserving and enhancing valued landscapes. Strategy 46 of the East Devon Local Plan supports protection of landscapes, not their loss.

Furthermore, as an area proposed in the emerging Local Plan for designation as a CPA, then the LVIA should have recognised this as part of the policy baseline. A CPA is specifically intended to protect open landscapes, undeveloped coast, skyline settings and views, failure to consider it risks under-representing the sensitivity of the area. CPAs are designated precisely because cumulative loss of edges and even “well-related extensions” can erode important coastal setting. Therefore, omission of a forthcoming CPA could materially skew the judgement of sensitivity and significance.

The landscape sensitivity is higher than the LVIA asserts because the emerging CPA designation would expressly seek to protect the rural, open and undeveloped setting of Exmouth and the coastal hinterland. This conflicts directly with the LVIA conclusion of only ‘minor’ or ‘negligible’ effects.

Once the emerging CPA designation is factored in, the assessment of magnitude of change and significance of effects must be reconsidered. A location proposed for strategic landscape protection cannot reasonably be assessed as subject to only negligible harm.

In addition, reliance on future mitigation planting to reduce visibility is inconsistent with the purpose of a CPA , which aims to conserve the existing landscape character and openness, not a screened or visually modified future condition.

Heritage Impact
The archaeological evaluation is not yet complete, so it is premature to determine the application. Even limited anomalies could represent heritage assets of local importance, and until they are fully understood, granting permission risks irreversible loss. The NPPF requires that heritage assets be conserved in a manner appropriate to their significance. Without full evaluation, significance cannot be properly assessed.

Summary
The proposal is unsustainable, speculative, and contrary to adopted and emerging Local Plan strategies. It lacks agricultural land classification, heritage impact and CPA assessment, faces unresolved access constraints due to loss of trees and hedgerows, and fails to address design quality standards, including density, the omission of bespoke responses to site topography and the carbon impacts of levelling and reprofiling.

With significant brownfield opportunities available in Exmouth, this countryside site should be refused in favour of more sustainable, plan-led alternatives.

Yours faithfully

50MW BESS, Land At Higher Bagmore Farm, Woodbury, East Devon – Pending

We have objected to this application for a 50MW BESS on Land at Higher Bagmore Farm, Woodbury, East Devon – ref 25/1338/MFUL

Land west of Escot Park Estate, Talaton, East Devon – 147 acre solar farm – Pending

We have objected to this application for a 147 acre solar farm in East Devon.

Bulworthy Farm, Alverdiscott – 279 acre solar farm and BESS. Pending

We have submitted a comprehensive objection to this proposal, supporting the local community who are opposed to this massive development in the countryside. The application lies in two districts – North Devon & Torridge, who will be combining to make their decision.

99.4MW BESS at Woodtown, East the Water

January 2026. We have submitted an objection to this Battery Energy Storage System (BESS) in the Alverdiscott area of Torridge. Ref: 1/0939/2025/FULM Our objection can be viewed below.

24 dwellings, Land at Canal Rise, Bridgerule – Pending

We submitted the following objection to Torridge District Council, on 16th January 2026:
Ref: 1/0938/2025/OUTM
Dear Sirs

Devon CPRE objects to this planning application.

Without the following:
1) Arboriculture Survey (trees acknowledged to be on site in the application form),

2) Heritage Assessment (the site contains sections of the Bude & Launceston Canal, which is a heritage asset (previously highlighted in application 1/0624/2017/OUT)

3) Agricultural Land Classification assessment (it is impossible to determine whether best and most versatile land would be affected)

4) Requested details on access and drainage (the Highway Authority and Lead Local Flood Authority have raised concerns about the lack of information)

5) Building for a Healthy Life assessment (required by Policy)

the proposal cannot demonstrate compliance with up-to-date policies. Taken together, these factors constitute a clear reason for refusal under National Planning Policy Framework Paragraph 11(d)(ii) and Footnote 7, as the impacts on heritage, biodiversity, and natural resources are unknown. Approval at this stage would be premature and contrary to national and Local Plan policies including DM05, DM07, ST14, DM08, ST10, and DM04.

Yours faithfully

Woodland Farm, West Anstey Wind Turbine – Permitted

Planning Application Number: 53235 Site Address: LAND AT WOODLAND FARM WEST ANSTEY DEVON EX36 3NZ Description: ERECTION OF ONE 11kW WIND TURBINE (HEIGHT TO HUB…

Woodterrill Farm, Hollocombe, Chulmleigh Wind Turbines – Permitted

Planning Application Ref. No: 1/0653/2013/FU Location Woodterrill Farm Hollocombe Chulmleigh Devon EX18 7QF Description Installation and operation of 2x 250kW (30m to hub and 45m…

Wortham Farm, Lifton Wind Turbine – Permitted. Operational

Permitted at appeal. Application number: 00300/2013 Click for further details Description: Erection of a single wind turbine (estimated output of 500 kilowatts) with 50 metre hub…

Youldon Sutcombe Wind Turbine – Permitted

Allowed at appeal  2nd Dec 2014 Planning Application Ref. No: 1/0637/2013/FUL Location Land At Youldon Sutcombe Holsworthy Devon EX22 7QP Description Erection of a single…

Warleigh Barton, Tamerton Foliot Solar Farm (8.2 acres) – Permitted

04/0770/11/F Application Description: Solar Farm, comprising the erection of solar arrays, equipment housing and ancillary/associated equipment. Continued use of land for agricultural purposes (grazing) Application…