Mid Devon Local Plan Viability Assessment: Our Stakeholder Submission
Mid Devon District Council recently commissioned the Dixon Searle Partnership (DSP) to conduct a Local Plan Viability Assessment. As an environmental consultancy, Southwest Environmental Limited was invited to participate as a stakeholder to help shape future planning policies and development strategies.
Because viability assessments cover a vast spectrum of real estate, economics, and environmental planning, not every question applied to our specific expertise. Below is a summary of the sections we provided detailed commentary on, the sections we chose to skip, and the reasoning behind our approach.
Part 1: What We Commented On (And Why It Matters)
As environmental consultants, our primary focus is ensuring that the environmental policies proposed by the Council are practical, properly costed, and sustainable. We grouped our responses into the following key chapters:
Chapter 1: Ecology and Biodiversity Net Gain (BNG)
Relevant Question: Q21 (Costs associated with 10% to 20% biodiversity net gain requirements).
Why we commented: Delivering and costing ecological mitigation is at the core of what we do. The financial viability of a site is heavily influenced by its baseline biodiversity and the subsequent habitat enhancements required to achieve statutory net gains. We provided evidence on how the physical characteristics of a site dictate the cost of delivering these improvements. If you are a developer looking to understand how this impacts your site, you can read more about our Biodiversity Net Gain (BNG) services.
Chapter 2: Water Management and Blue-Green Infrastructure
Relevant Question: Q22 (Overlapping solutions for open space, SuDS, and blue-green infrastructure).
Why we commented: Combining Sustainable Drainage Systems (SuDS) with public open spaces is a highly effective way to maximize land use while managing hydrological impacts. We supported the Council’s approach here, drawing on our extensive experience in hydraulic modelling and surface water management. Integrating these overlapping solutions is a critical strategy we use when conducting a flood risk assessment for new developments, ensuring that sites remain resilient to climate change without sacrificing developable land.
Chapter 3: Site Enabling Costs and Carbon Reduction
Relevant Questions: Q17 (Site enabling works and external works) & Q20 (Enhanced carbon reduction standards).
Why we commented: Strategic-scale greenfield developments and complex brownfield sites often require significant environmental site-enabling works, including land remediation, soil management, and initial ecological clearance. Furthermore, pushing for enhanced carbon reduction standards directly aligns with our environmental impact assessments. We provided commentary to ensure the Council accurately estimates the upfront environmental compliance costs developers face before a single brick is laid.
Part 2: What We Didn’t Comment On (And Why)
While the survey comprehensively covered the entirety of the property sector, several sections fell outside the purview of an environmental consultancy. We opted to leave the following sections blank to ensure the Council receives only the most accurate, expert-led data from the appropriate professionals:
- Residential and Commercial Market Conditions (Q6–Q13): Questions regarding buyer demand, sales rates, Build to Rent viability, and commercial yields. Why we skipped: These metrics are best answered by property agents, local developers, and real estate market analysts.
- Land Values and Owner Premiums (Q14–Q16): Discussions on Existing Use Values (EUV) and the premiums required to incentivize land release. Why we skipped: Land valuation and financial incentivization are strictly the domain of land agents and chartered surveyors.
- Plot Costs, Build Rates, and Developer Profits (Q18–Q19, Q23–Q24): Granular details on specific material costs, M4 accessibility housing standards, professional fee percentages, and developer profit margins. Why we skipped: As our focus is on environmental compliance and land viability, we do not dictate architectural accessibility standards or economic profit margins for structural builds.
By focusing our submission strictly on ecology, water management, and environmental compliance, Southwest Environmental Limited aims to help Mid Devon District Council formulate a Local Plan that is both economically viable and environmentally sound.






