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Wiltshire 2026 – Planning for Wiltshire’s
Future
Consultation document to inform the Wiltshire Core Strategy October 2009
Representations on behalf of Gleeson Strategic Land
Land north and northeast of Malmesbury
December 2009
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Contents
1.0 Introduction
2.0 Options for Growth in the former North Wiltshire area
3.0 Representations
Response to Questions
1. Do you agree with the proposed vision for Wiltshire and the strategic objectives set out in Section 2? If not, how would you change them and why?
2. Do you agree with the issues and opportunities identified within your community area? If not, how would you change them and why?
3. Do you agree with the descriptions of how we expect your community area to change by 2026 and what the Core Strategy should deliver within this period? If not, how would you change them? Are there any aspects of the community area (for example the need for particular facilities) which should be added?
4. Do you agree with the preferred strategic site option proposed for your community area? What could be done to improve the preferred option? Is there an alternative option you would suggest?
5. Do you agree with the settlement hierarchy in Section 4, which sets out the difference between strategically significant towns, market towns and smaller towns and villages? If not, what would you change and why?
6. Do you agree with the overall distribution of housing numbers between the community areas, as shown in Table 4.2? If not, what would you change and why?
Benefits of an increased housing allocation to Malmesbury
Former North Wiltshire Market Towns Comparative Matrix
Defining the growth potential at Malmesbury Town
Whychurch Farm site as a preferred option
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1.0 Introduction
Broadway Malyan makes this submission to the Wiltshire 2026: Planning Wiltshire’s Future
(Consultation document to inform the Wiltshire Core Strategy October 2009 ) on behalf of
Gleeson Strategic Land Ltd. This submission is associated with land to the north and northeast of Malmesbury, referred to as Reeds Farm [SHLAA Ref. 496] and Whychurch Farm
[SHLAA Ref. 649] respectively.
This submission specifically considers the options for growth within the former North Wiltshire area, highlighting the potential of Malmesbury town as a key local service centre serving the
Malmesbury Community Area.
The submission is based on a review of the available background evidence documents, which include the following:
• Vision and Strategic Objectives October 2009
• Spatial Strategy October 2009
• Strategic Sites October 2009
We also reviewed the following supporting documents of which some were prepared by the former North Wiltshire District Council:
• North Wiltshire Retail Needs Assessment Study (Roger Tym & Partners September
2007).
• North Wiltshire LDF Background Paper 1: North Wiltshire Settlement Hierarchy (May
2007)
• North Wiltshire LDF Core Strategy Second Issues and Options Consultation (May
2007)
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The above background papers provide a sound evidence base to warrant an increased allocation at Malmesbury based on inter alia the need to sustain and potentially enhance its service centre role serving a large community in the north of Wiltshire and address key issues
(e.g. affordable housing, employment and land availability) as identified in the above background papers.
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2.0 Options for Growth in the former North Wiltshire area
The market towns within the former north Wiltshire area that meet RSS Development Policy B criteria are Malmesbury, Calne, Corsham and Wootton Bassett. We consider the merits or otherwise of developing in these locations.
Housing Distribution
In terms of housing distribution, the emerging RSS specifies that 5,200 dwellings are required in the former North Wiltshire district outside of Chippenham. The RSS sets out that the numbers are to be distributed to settlements that meet Development Policy B or Development
Policy C criteria. The RSS is clear that in identifying the scale of growth to be located at each settlement, consideration should be given to local factors including landscape constraints, functional relationships between settlements, character, quality of infrastructure and the level of local need. Also, distribution of housing should take particular account of the functional relationship between settlements as the basis for defining distribution.
We note a significant proportion of the RSS housing requirement (i.e. nearly 30%) is proposed at small towns and villages within the former North Wiltshire area (RSS
Development Policy C settlements). This is contrary to the Sustainability Appraisal, which suggests the larger settlements should accommodate growth. Further, Paragraph 8 of PPS7
‘Sustainable Development in Rural Areas’ (2004) makes it clear that the focus for most additional housing in rural areas should be on existing towns and identified service centres.
This implies that growth to the smaller towns and villages within the former North Wiltshire should be limited if not restricted.
Malmesbury town is one of four settlements (along with Calne, Corsham and Wootton
Bassett) within the former North Wiltshire District that is said to meet RSS Category B policy criteria.
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RSS Development B Policy indicates that within these locations, provision will be made for housing, employment, shopping and other services that increase their self-containment and enhance their role as service centres . RSS Development Policy B settlements were previously considered by the former North Wiltshire District Council to be Corsham, Calne,
Malmesbury and Wootton Bassett. However, the RSS sets out that additional growth at
Wootton Bassett should be limited to meeting local needs, as the town’s dormitory relationship with Swindon would be exacerbated by further growth. This was accepted by the former North Wiltshire District Council. We note the proposed distribution seeks to allocate around 18% of the RSS housing requirement to Wootton Bassett. This is considered too high, particularly when viewed against the proposed percentage allocation at Malmesbury, which is only around 14% of the RSS requirement. Additionally, the former North Wiltshire Council acknowledged that Corsham meets RSS Development Policy B criteria but its potential to accommodate development is restricted due to the surrounding landscape constraints such as Green Belt and AONB. Notwithstanding this, the proposed distribution seeks to allocate almost 19% of the RSS requirement to the town. Having regard to the identified constraints at
Corsham and recognised limitations of Wootton Bassett, growth at these settlements must be restricted. To assist in the development of a sound sustainable strategy, the RSS housing allocations should be redistributed to Malmesbury and Calne based on their capacity and ability to appropriately absorb development. This is expanded on below.
Growth at Key Local Service Centres
Having regard to the above, Malmesbury and Calne should be the focus for growth in the former North Wiltshire area (i.e. outside Chippenham and the Swindon Western expansion area) as the evidence would suggest these locations best meet Development Policy B criteria, particularly Malmesbury where opportunities exist through expansion to enhance it’s role as a key local centre and assist in its overall containment.
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In light of the above, this submission is focussed on Malmesbury as a key location for growth.
It sets out why the town is a suitable location for growth. It highlights the town is an important local centre that provides a good level of service to the wider Community Area. The scale of growth should reflect its role as a local service centre serving a large hinterland. Malmesbury acts as an important local centre and has important functional relationships with the smaller surrounding settlements. This should be taken account of in determining /influencing how much future growth is allocated/distributed.
Malmesbury Community
Malmesbury is one of the smallest towns within the former North Wiltshire area but performs a more strategic role to a larger geographical area. Malmesbury has the lowest percentage share of the RSS housing requirement for the former North Wiltshire area. This share does not reflect Malmesbury as an obvious sustainable settlement, serving a wider hinterland to the north of the County. Malmesbury is not only appropriate for growth but has the greatest opportunity to enhanve its service centre role. The main strengths of the town include:
• Greater number of jobs than working residents - Extra housing will therefore assist in
creating a more balanced community with less in-migration for work;
• Strong town centre that is capable of being enhanced;
• Ability of infrastructure to sustain further growth;
• No insurmountable infrastructure issues.
We note a detailed analysis of the market towns is provided and is used to help understand how each settlement currently functions. However, it is not clear how this is used to allocate housing and employment to each town.
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The Preferred Options
We fully support the preferred option, to accommodate 200 dwellings. The allocation of 200 dwellings to Malmesbury will assist in helping to deliver affordable homes for the town. This representation sets out how the proposed allocation could work and includes an indicative concept plan.
The site is deliverable and can be brought forward early in the phasing strategy given it is in one ownership and the landowner is willing to release the land for development should it be required.
There are no known constraints on the site that would otherwise prevent development from going ahead.
Land at Whychurch Farm
Notwithstanding the above, the allocation of 200 dwellings at Malmesbury may not allow the option of creating modest critical mass required to help address affordable housing issues and more importantly, it does not reflect the higher proportion of jobs already within the town and the availability of developable land. The next stage of the Core Strategy process should provide more clarity on the actual housing requirement and refine the allocations having regard to the constraints at Corsham and limitations at Wootton Bassett.
Without prejudice to the identified preferred option site at Reeds Farm and part of Whychurch
Farm for 200 dwellings, we believe there is evidence to support a higher allocation at
Malmesbury town. An increase in housing provision is justified on the grounds of enhancing the town’s service centre role, self containment and addressing the need to balance jobs with working residents, delivery affordable housing and community/social infrastructure benefts. In this instance, we feel the allocation at Malmesbury should be increased and the preferred option amended to include the entire Whychurch Farm site (SHLAA ref.649 and.496).
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3.0 Representations
1. Do you agree with the proposed vision for Wiltshire and the strategic objectives set out in Section 2? If not, how would you change them and why?
Vision
We understand the vision will be further refined through public consultation and as such we consider it should aim to set out a clear message about the ways in which the Community
Areas will change by its end date.
We agree the main focus of development should be at Trowbridge, Chippenham and
Salisbury, given their status as Strategically Significant Cities and Towns (SSCTs), as defined in the emerging RSS. Notwithstanding this, the vision implies that ‘ settlements of all sizes’ will accommodate growth. For clarity, we suggest the vision sets out those Market Towns that meet RSS Development Policy B criteria will be central to delivering sustainable growth to each of the Community Areas and will be the main focus for growth.
Growth to the smaller settlements is likely to be unsustainable and may create further issues such as increasing out-commuting. It is therefore our view that smaller settlements warrant a degree of protection from growth. To ensure these settlements are protected the vision must seek to limit growth at the smaller settlements.
We refer to the Government’s position on the delivery of sustainable development which is contained in Planning Policy Statement 1 (PPS1) which states:
“Planning should facilitate and promote sustainable and inclusive patterns of
urban and rural development by:
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• Making suitable land available for development in line wih economic,
social and environmental objectives to improve people’s quality of life;
• Contributing to sustainable economic development;
• Protecting and enhancing the natural and historic environment, the
quality and character of the countryside, and existing communities;
• Ensuring high quality development through good and inclusive design,
and the efficient use of resources; and
• Ensuring that development supports existing communities and
contributes to the creation of safe, sustainable, liveable and mixed
communities with good access to jobs and key services for all members
of the community’
As a suggestion, we propose the following wording to be included within the vision;
‘A number of key market towns will have improved and consolidated their roles as
local service centres through the provision of appropriate housing, employment and
community infrastructure to meet the needs of their Community Areas’ .
Objectives
Objective 2.
We fully support the points in respect of supply of employment and retail land. The distribution of housing should reflect the economic potential of individual settlements and seek to reduce out-commuting.
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Objective 3
We fully support the focus of new housing at the SSCTs, such as Trowbridge, Chippenham and Salisbury.
Overall, we support the identification of 14 separate Community Areas (CA). We would prefer to see this objective specifically refer to the main settlement within each Community Area as the primary focus for housing allocations.
We note there are a number of allocations to the smaller towns and villages, which we consider is likely to exacerbate unsustainable patterns, such as increased commuting and as such may not form a robust sustainable settlement strategy.
Objective 4
In terms of securing appropriate infrastructure and services, this may only be realistically achieved by focussing growth at key settlements. Growth must of a reasonable scale in order to create a critical mass, which could allow for the delivery of essential local infrastructure and facilities.
Objective 5
We welcome the reference to the need to enhance the vitality and viability of town centres and the need to ‘ strengthen role and function of established service centres’ .
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2. Do you agree with the issues and opportunities identified within your community area? If not, how would you change them and why?
Malmesbury Community Area
Para 3.8.1 sets out the objective for the Malmesbury Community Area is ‘ to continue to support local employment opportunities, services and facilities and to address the issue of affordable housing’ . We consider a more critical objective for the Malmesbury Community
Area is to enhance the role of its only market town (Malmesbury) as a service centre serving the northern part of the County whilst ensuring its self-containment is increased.
Para. 3.8.2 indicates that the larger villages of Ashton Keynes and Sherston could accommodate modest development and the smaller villages of Great Somerford and
Luckington could be limited to infill. Given the high completions achieved recently in these locations, it is considered the Core Strategy should seek to impose a policy restraint on these settlements in an attempt to preserve their existing self-containment levels and not to encourage out-commuting patterns.
Malmesbury Issues and Opportunities
Para 3.8.3 identifies a number of issues within the Malmesbury Community Area. We see the key issues primarily relate to Malmesbury town and not the wider community area. We do not consider the identified opportunities at Malmesbury go far enough to suggest the town is the most suitable location for growth. For example, the large proportion of jobs in relation to current population is a good indicator of the need to provide for further housing. The Core
Strategy must clearly set out the opportunities arising from future growth such as the need to provide for much needed affordable housing.
Technical work carried out for the former North Wiltshire LDF (Background Paper 1 – May
2007) classifies Malmesbury as meeting the criteria set out in RSS Development Policy B and
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______we would welcome explicit recognition of this status and a better indication of how its purposes will be fulfilled.
There should not be a blanket assumption about constraints at Malmesbury town. The
Strategic Sites background paper indicates Malmesbury has the highest capacity to absorb growth.
We welcome the point about Malmesbury being unique in that there is a ‘ reasonable level of in-commuting’ . The fact there is a higher level of in-commuting into the town further reinforces the case and need to deliver more housing to the town.
The section on ‘opportunities’ in Para. 3.8.4 is more concerned with the characteristics of the town. We would welcome a greater emphasis on specific needs and issues identified at
Malmesbury that require a spatial planning response. We consider, the key issues and opportunities relate to;
• Employment;
• Affordable housing;
• Self-containment;
• Land availability; and,
• Retail.
Below, we expand on the key issues in Malmesbury which should be clearly highlighted in policy for this Community area:
Employment
In terms of employment, we note the key issue in Malmesbury is the reliance on one employer (Dyson). We also note there is a lack of small to medium business enterprises in
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______the town and that little opportunities exist at present to address this shortfall. There is a clear need to assist in diversifying the town’s employment base in order to ensure jobs remain within the town and maintain / enhance self containment, as required by RSS Development
Policy B criteria.
Affordable Housing
Malmesbury town commands one of the highest house prices in Wiltshire, resulting in a high level of demand for affordable housing to meet local needs. It is one of the smaller market towns and in contrast to Wootton Bassett, Calne and Corsham it has seen the least amount of growth over recent years, in relative terms. This has, in part, resulted in high demands for affordable housing. Given the higher house prices in Malmesbury, it is unlikely that appropriate levels of affordable housing will be delivered without a higher overall allocation of housing to the town.
Self-Containment & Local Service Centre
Malmesbury has the highest level of self-containment of all other market towns. In geographical terms, the town is located within the largest Community Area and appears to serve a larger hinterland, above that of Calne, Corsham and Wootton Bassett. It is strategically positioned in terms of it being the most important local service centre serving the northern part of the County and is therefore likely to serve a significant rural population. In this instance, the town’s local service centre role must be enhanced to ensure it remains fully functional in serving the needs of the surrounding rural population.
Availability of Suitable and Developable Land
In terms of developable land, Malmesbury has land available for development that is relatively constraint free. The strategic site assessment study indicates land to the north and northeast
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______of Malmesbury is the most suitable location for an allocation and it intimates the land in this area has capacity for a higher allocation of housing, beyond the 200 dwellings currently proposed.
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3 Do you agree with the descriptions of how we expect your community area to change by 2026 and what the Core Strategy should deliver within this period? If not, how would you change them? Are there any aspects of the community area (for example the need for particular facilities) which should be added?
Malmesbury Community Area
Para.3.8.5 indicates it is ‘unrealistic to plan for significant growth’ on the basis of the rural context. We disagree. We feel that the relative isolation of this Community Area (particularly from the SSCTs of Swindon and Chippenham) warrants greater attention to its local service centre role and what is needed to sustain, support and enhance this. This Community Area is served by the smallest market town but yet it is likely to serve a large catchment population.
Growth is therefore essential to ensure the vitality and viability of the town is sustained/enhanced.
Further growth could help to maintain and enhance the town’s existing employment base and to increase the opportunity for people to live and work in the town. Moreover, it is important the town’s functional role to the surrounding area is supported and the ability of the town to absorb future development is fully recognised. A significant level of growth is required to support its role as a local retail centre, and community benefits could be delivered through a careful, well planned, high quality masterplanned scheme.
What should the Core Strategy Deliver?
The Core Strategy should seek to deliver growth in recognition of the need to expand and consolidate Malmesbury’s role as a key service centre, particularly given it serves a large hinterland to the north of the County and has capacity to absorb growth on suitable and available land.
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We support growth to the town and support the evidence base in respect of identifying a suitable strategic site at Malmesbury for an allocation of 200 dwellings. However, to appropriately meet identified local housing needs and to help deliver additional community benefits, it is likely that a higher allocation is needed.
Over the plan period, Malmesbury will continue to act as a local service centre and it is likely that more demand on a wider range of shops and services for the defined community area and wider hinterland outside the administrative boundaries will arise. In this case,
Malmesbury should appropriately plan for the right level of growth having regard to the issues and opportunities identified and the ability of the town to absorb future development.
Employment
Malmesbury is a ‘net importer’ of workers, which makes it unique in the sense that there is a higher than average proportion of workers commuting into the town than anywhere else in the former North Wiltshire area. This is a strong indicator of the need to increase housing at
Malmesbury to ensure a more sustainable balance between jobs and homes. The retention of the employment base is also an important objective. Any future housing allocation at
Malmesbury should be based on the need to achieve the right balance of jobs with working residents and should recognise the need to change in this regard.
Affordable Housing
The Swindon Sub-Region HMA indicates the former North Wiltshire area is experiencing major issues in terms of delivering affordable housing. Indeed the Core Strategy background papers reaffirm the need to deliver affordable housing but there is a serious lack of opportunities available to deliver an adequate supply of affordable units. There is therefore a need to deliver affordable housing as a key component of, and justification for the allocation of housing to the town. Any future allocation should be of an appropriate scale that would
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______seek to deliver as much affordable housing as is practicably viable having regard to capacity and availability of suitable sites to absorb development.
Self-Containment and Dormitory Status
Malmesbury has the highest level of self containment in the former North Wiltshire area and is one of the higher performing RSS Development Policy B settlements. This should be made clear in the Core Strategy when defining the most appropriate settlements to accommodate change.
The table below shows the demographic breakdown for each of the key settlement areas.
Malmesbury has the lowest population and the highest levels of self-containment in the district.
Population and Self-Containment
Town Population Level of Self
Containment
11,100 30% Wootton Bassett
15,600 38% Calne
Corsham 9,580 37%
Malmesbury 5,650 49%
In accordance with the emerging RSS, further growth at any of the key settlements should ensure self-containment levels are maintained. Given the proximity of Calne, Corsham and
Wootton Bassett to major urban centres it is likely that any increase in housing could further increase levels of out commuting resulting in the creation of unsustainable travel patterns across the County. Calne and Corsham are located quite close to Chippenham and significant development at these locations may facilitate increased commuting patterns, thus reducing their overall self-containment levels.
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Malmesbury, because of its location north of the M4, is the only key service town in this part of the County, and as such there is the need to allocate housing to the town in order to augment its role as service centre for the surrounding rural area.
Capacity
The table below shows the number of sites identified in the SHLAA (prepared by the former
North Wiltshire District Council) for each of the key locations outside Chippenham.
Malmesbury comes out as a favourable location having 5 Priority 1 sites. Priority 1 sites are sites identified by the former North Wiltshire district council as being suitable to deliver housing within the first 5 years of the plan.
Table 7: Total Number of Sites included in the SHLAA
Priority 1 Sites Priority 2 Sites Priority 3 Sites Total
Malmesbury 5 4 2 11
Corsham 1 5 1 7
Calne 6 12 2 20
Cricklade 1 1 2 4
Wootton 0 6 9 15
Bassett
On the basis of the above, Calne and Malmesbury have the ability to absorb a substantial level of growth on Priority 1 sites. This alone should make them favourable locations to accommodate the majority of housing requirements in the former North Wiltshire area.
Corsham, given its environmental constraints, is unlikely to accommodate growth without having an impact on nationally designated environmentally sensitive areas. Wootton Bassett has no P1 sites. As such, no growth should be allocated on the basis of having no suitable capacity.
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Strategic transport assessment
Malmesbury scored the second best location after Wootton Bassett and scores higher than
Calne in terms of accessibility. It is on an equal par with Corsham. Having regard to the scores, it appears that Malmesbury performs no worse than any of the other Market Towns in the former North Wiltshire area.
Brief Review of Other Market Towns in the former North Wiltshire Area:
Calne Community Area
From our review of the background papers, Calne is affected by its dormitory relationship with
Chippenham, although its capacity for growth is recognised.
Corsham Community Area
From our review of the background papers it suggests the strategy should make no Core
Strategy allocation to Corsham as it is environmentally constrained. Any residual housing need could be distributed through the Site Allocations DPD and limited to infill development.
The role of Corsham as a local service centre is heavily constrained by its location only 4.8 miles from Chippenham, which reduces the need for development. Any further development may increase commuting levels out of the town.
Wootton Bassett
From our review of the background papers it suggests the strategy should make no Core
Strategy allocation given its relationship to Swindon. Any residual housing need that meets local needs could be distributed through Site Allocations DPD and limited to infill.
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4 Do you agree with the preferred strategic site option proposed for your community area? What could be done to improve the preferred option? Is there an alternative option you would suggest?
Malmesbury Community Area: Reeds Farm/Whychurch Farm Preferred Strategic Site
Option
We fully support the preferred option, to accommodate 200 dwellings. The allocation of 200 dwellings to Malmesbury will assist in helping to deliver affordable homes for the town. This representation sets out how the proposed allocation could work and includes an indicative concept plan.
The site is deliverable and can be brought forward early in the phasing strategy given it is in one ownership and the landowner is willing to release the land for development should it be required.
There are no known constraints on the site that would otherwise prevent development from going ahead.
We have prepared an indicative conceptual masterplan which illustrates in broad terms how the site could accommodate 200 dwellings, including suggested access arrangements. We hope this gives the Council confidence in bringing this allocation forward in any future DPD.
From our review of the background papers, we agree the site is the least constrained of all the sites put forward. It is ideally located close to existing residential neighbourhoods and existing employment locations and is accessible from the strategic road network.
The reasons why the site is a suitable preferred option include the following;
o It is the least constrained site in Malmesbury;
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o The site is within one ownership and is capable of being delivered;
o The site is large enough to accommodate 200 dwellings;
o The site is part of a larger site that has extra capacity for more dwellings,
without prejudicing the setting of the settlement;
o The site is close to existing residential areas and employment areas;
o The site can provide a mix of uses and address key housing issues for the
Malmesbury Community Area;
o Development on the site could ensure affordable housing is delivered at the
right location and at the right time;
o Development of the site could ensure delivery of green infrastructure;
o Development of the site may bring opportunities to provide employment to the
town through construction jobs.
We also believe, having regard to the issues highlighted in Malmesbury, that the preferred option could be improved to take account of the further housing capacity at land at
Whychurch Farm (see separate representation).
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5. Do you agree with the settlement hierarchy in Section 4, which sets out the difference between strategically significant towns, market towns and smaller towns and villages? If not, what would you change and why?
Whilst we generally agree with the settlement hierarchy in Section 4, it should not be the sole indicator used to determine housing distribution and location. The methodology indicates the proposed hierarchy of settlements in Wiltshire is based on the identification of SSCTs in the
RSS and from work carried out by former district councils’.
The settlement hierarchy is said to have had regard to the RSS policy criteria for both Market
Towns (Policy B) and small towns and villages (Policy C). The indicators used to define these settlements are based on three factors:
- Facilities - basic facilities
- Employment - existing concentration and potential employment
- Transport - sustainable transport
We do not believe the assessment is clear in highlighting the difference between the settlements in the former North Wiltshire area, assessing their ability to increase self containment and potential to enhance their roles as local service centres.
The evidence suggests Malmesbury provides the greatest opportunity to increase self- containment levels and enhance its role as a service centre. This should be fully recognised in the settlement hierarchy. As such, an appropriately sized allocation should be made which secures the provision of housing, employment, shopping and other services in an effort to enhance self-containment and its role as a service centre.
Corsham and Wootton Bassett act as key local centres but if further growth is allocated to them it could further exacerbate unsustainable settlement patterns, given their proximity to
Chippenham/Swindon. For example, the analysis work undertaken (such as the role and
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______function studies) and the Spatial Strategy background paper indicates that Corsham and
Wootton Bassett are unable to appropriately accommodate sufficient new development due to a high number of identified constraints associated with each of the settlements and as such should be subject to a policy of restraint on development.
Malmesbury is an identified market town which has an already high level of self-containment.
It is a key service centre for the north of the district and serves a wider hinterland beyond the
Wiltshire administrative boundary. Additionally, the evidence from the Strategic Sites background paper and Sustainability Appraisal reaffirms the town is suitable and has sufficient capacity to absorb growth. Based on this, it must be recognised as a potential location to accommodate a substantial level of growth in the former north Wiltshire area outside Chippenham and the Swindon area.
We note the proposed settlement hierarchy reflects that presented by the former North
Wiltshire District in their draft Core Strategy. It presented a spatial strategy for North Wiltshire based on the settlement hierarchy background study and sought to concentrate locally significant growth at Corsham, Calne, Malmesbury and Wootton Bassett. However, since that strategy the Proposed Changes to the RSS have been published, which indicate that growth at Wootton Basset is no longer an option. Additionally, the former North Wiltshire Council concluded that development opportunities at Corsham are limited given the high environmental constraints surrounding the town, thus, leaving Malmesbury and Calne as the main centres to accommodate growth.
Having regard to the above, the settlement hierarchy must acknowledge the limitations of
Corsham and Wootton Bassett within the former North Wiltshire area and seek to resist allocations that would result in creating unsustainable development patterns.
The technical work carried out for the former North Wiltshire LDF (Background Paper 1 – May
2007) identifies Calne, Corsham, Malmesbury and Wootton Bassett as meeting RSS
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Settlement Policy B criteria (whilst noting that Wootton Bassett performs a largely dormitory function to Swindon and should not receive growth above the level appropriate to local needs). It also set out that growth at Corsham is limited due to environmental and landscape constraints. In this instance, the role and limited potential of Corsham and Wootton Bassett should be clearly explained in the Core Strategy. Additionally, the role of Malmesbury as a key service centre in the north of the county should be more explicit and set out in Core
Strategy policies.
We object to the proposed distribution of housing numbers between the Community Areas for the former North Wiltshire area. We do however welcome the level of information contained within Figure 4.2 as a basis for discussion.
We consider the housing figures for each of the main settlements within the Community Areas for the former North Wiltshire district area require further refining in light of the limitations of growth at Corsham and at Wootton Bassett.
We understand the distribution is in part derived from the role and function analysis, which provides an understanding of each settlement through an analysis of the level of housing, employment and facilities that are currently available and the potential which exists to consolidate and improve the current situation. However, on review of the study it would appear that the conclusions drawn do not reflect the true potential at Malmesbury and the limitations of Corsham and more specifically Wootton Bassett.
The RSS is clear about the level of development to Chippenham, Trowbridge and Salisbury but does not specify numbers to the market towns or the small towns and villages. The emerging RSS specifies that 5,200 dwellings are required in the former north Wiltshire district outside of Chippenham. The RSS sets out that these are to be distributed to settlements that meet RSS Development Policy B or Development Policy C criteria. The RSS is clear that in identifying the scale of growth to be located at each settlement, consideration should be given
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______to local factors including landscape constraints, functional relationships between settlements, character, quality of infrastructure and the level of local need. Also, the distribution of housing should take particular account of the functional relationship between settlements as the basis for defining distribution. In this respect and having regard to the aforementioned considerations, it is clear that Malmesbury is in need of a significant proportion of the housing requirement in order to sustain and enhance its role as a key service centre in the northern part of the County.
The following table ‘HOUSING DISTRIBUTION PROPOSED IN WILTSHIRE CS Community
Areas’ shows the indicative breakdown of proposed housing distribution for the former North
Wiltshire area. On review of the proposed proportional distribution of housing for the former
North Wiltshire District Community Areas, we note there is a disproportionately small share of the emerging RSS housing requirement to Malmesbury; which is less than that of Wootton
Bassett. Furthermore, an even higher proportion remains on potentially ‘ unallocated sites’ .
HOUSING DISTRIBUTION PROPOSED IN WILTSHIRE CS Community Areas
RSS % Share
N Wilts Location Target * Commitments W'falls Proposed Total RSS % Share of
2021-26 Allocations provision Target Allocations
5200
Calne CA 670 80 530 1280 24.6 31.0
Corsham CA 870 70 120 1060 20.4 7.0
Malmesbury CA 750 80 280 1110 21.3 16.4
Wootton Bassett CA 920 50 280 1250 24.0 16.4
Unallocated 500 9.6 29.2
Total 5200 3210 280 1210 5200 100.0 100
As indicated earlier, there are significant higher-level constraints associated with Corsham and Wootton Bassett that should be taken into account prior to distributing final housing allocations within the former North Wiltshire area.
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Sustainability Appraisal Preferred Distribution of Growth
The Sustainability Appraisal indicates the preferred distribution of growth should be across a wider range of larger settlements and a narrower range of smaller settlements, indicating that this approach would maximise the benefit associated with improving services across different towns. The proposed approach as set out in Fig.4.2 however suggests a larger proportion to the small towns and villages than any of the main towns, except Calne. This approach is contrary to the Sustainability Appraisal.
Current Housing Distribution to Malmesbury
Malmesbury Town has the lowest percentage share of the overall emerging RSS requirement
(i.e.13.8% of RSS requirements).) despite having one of the greatest needs for more housing and the highest levels of self containment. It is not clear how the distribution of housing has taken account of these factors.
Current Housing Distribution to Wootton Bassett
We note that Wootton Bassett ultimately takes a higher percentage of the RSS allocation
(17.7% of RSS requirements) than Malmesbury, despite the need to restrict growth at
Wootton Bassett. The emerging RSS comments in relation to Wootton Bassett states no additional housing growth should be permitted above that which meets local needs due to the dormitory relationship it has with Swindon (of which the Secretary of State has subsequently endorsed this approach and also sets out that no additional growth at Cricklade other than to meet local needs). In this regard, Malmesbury town should have a higher percentage of the
RSS housing requirement.
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Current Housing Distribution to Corsham
Corsham also receives a higher proportion of growth than Malmesbury despite its constraints
(18.3% of RSS requirements). More importantly, we note the current distribution allocates almost 24% of the RSS requirement to the small towns and villages, further indicating the disparity between the settlements. This is considered too high, given the rural nature of much of the district and may lead to the creation of unsustainable patterns of movement and development across the former North Wiltshire area.
HOUSING DISTRIBUTION PROPOSED IN WILTSHIRE CS Market Town Distribution
RSS Commitment
N Wilts Location target * Completions W'falls proposed Total % share % share of
2021- RSS
26 allocations provision target allocations
5200
Calne 580 60 500 1140 21.9 33.8
Corsham 800 50 100 950 18.3 6.8
Malmesbury 480 40 200 720 13.8 13.5
Wootton Bassett 720 50 150 920 17.7 10.1
Small Towns and Villages 800 150 250 1200 23.1 16.9
Residual 280 5.4 18.9
Total 5200 3380 350 1200 4930 100.2 100
We understand the role and function analysis of each settlement has helped to determine the spatial strategy as set out in Section 4.0 of the Consultation document. This has in turn helped influence the level of housing distribution and allocations proposed for each
Community Area. In terms of the Malmesbury Community Area, the evidence suggests
Malmesbury is a key market town, capable of accommodating a significantly higher proportion of the growth, than that proposed.
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In light of land availability, identified constraints, self containment and importance /potential as local centres, it appears that Malmesbury and Calne could be the principal locations for development. The key facts that should influence the distribution of growth between the two settlements are set out below:
• Calne as a local service centre is restricted by its proximity to Chippenham in the
south of the former North Wiltshire area.
• Malmesbury is in a relatively isolated location, more remote from the top tier
settlements of Chippenham and Swindon and is likely to have a more significant role
as a local service centre for a larger area.
• Malmesbury has the smallest population but the highest level of self containment.
• Malmesbury has the lowest retail floorspace (with a very low convenience floorspace
balanced to some extent by the highest level of comparison floorspace of the three
settlements and the highest level of comparison goods turnover).
In terms of land availability, the two settlements compare as follows in the number and capacity of “Priority 1 sites” in the SHLAA:
• Malmesbury 5 P1 sites 841 dwellings (81% at Whychurch Farm)
• Calne 6 P1 sites 1,302 dwellings
Malmesbury appears to have a more significant role as a local service centre but Calne has more capacity. Given the importance of the need to enhance the local service role of the town, Malmesbury should be given priority as a key town to absorb growth.
We support the Councils’ approach in identifying Community Areas. However, the distribution of housing to the Community Areas must ensure that growth is directed to the most suitable
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______settlements capable of absorbing growth and ensuring that self containment is increased and their overall role as service centres enhanced.
Para 1.5 of PPS12 is clear that ‘ the planning system has been substantially reformed to embed community responsive policy making at its heart and to make contributing to sustainable development a statutory objective’ . The current housing distribution, we believe, could create unsustainable patterns of development across the former north Wiltshire district.
The distribution must not be based on rolling forward historic trends but should seek to create a ‘step-change’ in housing delivery and ensure sustainable growth is delivered within the former North Wiltshire area. PPS12 goes one step further in stating the new planning system exists to deliver positive social, economic and environmental outcomes. The evidence prepared to date (Strategic Sites and Spatial Strategy background documents and the
Sustainability Appraisal) clearly sets out that this can be achieved at Malmesbury.
Benefits of an increased housing allocation to Malmesbury
Self-Containment: We support the principle that further growth should ensure self- containment levels are maintained. In this instance, Malmesbury, because of its location north of the M4, is the only key service town in this part of the former North Wiltshire area, and as such an increased allocation above 200 dwellings is required to augment its role as service centre for the surrounding rural area.
Housing growth at Calne and Corsham, given they are located quite close to Chippenham, may facilitate increased commuting patterns, thus reducing their overall self-containment levels.
Affordable Housing: There is a clear need to deliver affordable housing in Malmesbury. A higher proportion of growth would allow for a significant percentage of the housing backlog to be met.
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Land Availability: The evidence shows that Malmesbury has the ability to absorb a substantial level of growth. In this instance and having regard to other matters, the housing distribution for the former North Wiltshire Area should focus development at the town.
Having regard to the issues raised such as affordable housing, employment, retail, and the availability of constraint free land to the north of the town, there is potential to accommodate and support sufficient new development to enable Malmesbury to consolidate and develop its service role. The land to the north and northeast is relatively constraint free and could provide a logical expansion of the town. Indeed, information from the Core Strategy Issues and Options Consultation (May 2007) recognised that land promoted to the north and northwest are possibilities that will require further investigation.
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Former North Wiltshire Market Towns Comparative Matrix
The table below sets out a brief comparison of the four market towns in the former North
Wiltshire area.
Malmesbury Calne Corsham Wootton Bassett Population 5,590 15,600 9,580 11,100
Employment Employed Residents 2,709 5,903 4,291 5,700 Jobs 4,656* 4,147* 3,753* 3,999* Self Containment 49% 38% 37% 30% Nearest SSCT 11miles 6.9miles 4.8miles 6miles Housing Affordable Housing 114 dwellings 128 dwellings 53 dwellings 195 dwellings Need Housing Completions 266 359 452 74 since 2006 Facilities Retail Convenience 750sq.m 5,450sq.m 1,450sq.m 3,230sq.m Comparison 4,520sq.m 4,030sq.m 4,200sq.m 5,000sq.m Service 2,190sq.m 3,570sq.m 3,710sq.m 11,960sq.m Vacant 560sq.m 1,410sq.m 490sq.m 1,170sq.m Education Primary Schools 2 7 3 4 Secondary Schools 1 1 1 1 Further Education 2 2 2 1 Library Yes Yes Yes Yes Leisure Centre Yes Yes No Cinema No No No No Health GP services Yes Yes Yes Yes Hospital Yes No No No Faith Faith facilities Yes Yes Yes Yes Transport Strategic Transport 37% 33% 37% 42% Assessment Score Developable Land SHLAA P.1 Sites 5 6 1 0
SHLAA P.2 Sites 4 12 5 6 SHLAA P.3 Sites 2 2 1 9
* Figures obtained from Role and Function Analysis study
It is clear from the table that Malmesbury as the smallest town, has a greater function in terms of its local service centre role, has had the least amount of development historically, is suffering from the lowest levels of retail floorspace, has the greatest amount of facilities in relative terms and more importantly has a significantly higher proportion of suitable sites available for development.
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It is worth noting that the RSS judgement that Wootton Bassett has a dormitory relationship with Swindon is based on its proximity to this SSCT (circa 6 miles). We consider that very similar concerns apply to both Corsham which is only 4.8miles from the SSCT of
Chippenham. The proximity of Corsham to Chippenham, together with the relative close nature of this market town to Calne is likely to have a negative impact on its function as local service centre and overall self containment.
Malmesbury being 11 miles from Chippenham have a much more significant role in providing services for its rural hinterland.
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Defining the growth potential at Malmesbury Town
The background papers, particularly the Strategic Sites supporting paper, is clear that there are good grounds to support a significant proportion of the total housing requirement at
Malmesbury, given the requirement of the town to maintain and enhance its local service centre role and the availability of suitable land.
The exact quantum of housing which Malmesbury could support requires testing as the Core
Strategy progresses. However, based on the SHLAA assessment and the emerging RSS housing requirement it is likely that Malmesbury could potentially accommodate up to 800 dwellings on Greenfield sites over the plan period.
We place particular emphasis on the potential of Malmesbury in spatial planning terms. The comparative assessment matrix indicates Malmesbury is a favourable location for growth, particularly if the current emerging RSS housing requirement for the remainder of the district is endorsed and adopted. The comparative assessment suggests there is scope to increase retail provision at Malmesbury. Additionally, given its location to the north of the County, it has further potential to act as a key centre, serving villages situated north of the M4. This in itself enhances the town’s potential and need to accommodate strategic growth.
Further, we have reviewed the community strategy for the former North Wiltshire area (that was prepared by the former district council) and the Community Plan for Malmesbury and the surrounding villages (2005-2015). The key vision for Malmesbury is to improve quality of life.
The top priority in Malmesbury is to ensure general infrastructure such as health facilities, water supply, sewage, access and general community provisions are provided.
Some of the key community aspirations include:
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• Maintain self sufficiency;
• Balance conservation with the need to plan sensibly and sustainably;
• Enhancement of sustainable tourism: the Abbey and the Abbey House gardens are
key tourist attractions.
• Protect heritage and the town’s hilltop setting.
• Improve and enhance riverside walks and access to the open countryside.
• Improve facilities for young people: recognised demand for ‘uncontrolled facility’ for
young people.
• Waste reduction and prevention: provision of recycling facilities.
• Public toilets in Malmesbury.
• Concerns over car parking in Malmesbury.
• Idea of Park and Ride site in Malmesbury – potential to create a public transport link
to Swindon and other neighbouring towns.
• Taxilink scheme: taxi /bus service in the Malmesbury area (there is a need for the
Council to identify times and places where there would be a demand for a regular
service).
• Provision of safe and sustainable routes.
• Potential being explored to create a new path for walkers and cyclists along the route
of the old Malmesbury branch railway line, linking the town with the Somerfords.
• Addressing the issues of traffic congestion, HGVs, pollution and road safety issues in
Malmesbury.
• Concerns about the state of the Filands stretch of road to the Dyson junction.
• Concerns with traffic along the A429 passing through villages.
• Pedestrianise the High Street.
• Concerns about the future of the local community hospital and the provision of local
health services.
• Affordable housing.
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• Potential to provide new community, recreational, civic and cultural facilities. Could be
scope to explore the opportunity to provide a tourist information centre, a museum,
theatre group space and pre-school.
• Promote citizenship and community identity
It appears that some of the aspirations identified may only be met through the provision of a suitably sized allocation at Malmesbury, which could deliver an appropriate proportion of affordable housing, bring employment opportunities to the town helping it to diversity the employment base, create potential demand for shopping and other services in the town by increasing the local population and to overall ensure the self-containment level is maintained and enhanced. This approach would enhance Malmesbury’s role as a key service centre, serving the north of the district.
Overall, growth at Malmesbury would need to ensure that it maintains self-sufficiency. The level of community benefits/gains that any future development could offer could ultimately influence the level of growth identified for Malmesbury.
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Whychurch Farm site as a preferred option
We fully support this proposed allocation which is an entirely appropriate response to the level of development currently proposed for the town,
The Strategic Sites background paper confirms the most logical direction for future growth in
Malmesbury is on land immediately north and northeast of the existing built up limits of the town. This would include the general area of Whychurch Farm (SHLAA ref.649). We note the Council acknowledge the site is large enough to accommodate over and above 400 dwellings. However, because the proposed allocation at this stage is only for 200 dwellings at
Malmesbury, the entire site is not required.
Without prejudice to the identified preferred option site at Reeds Farm and part of Whychurch
Farm for 200 dwellings, we believe the evidence suggests that a higher allocation to
Malmesbury town is required and is justified on the grounds of enhancing the towns service centre role, self containment and addressing the need to balance jobs with working residents and provision of affordable housing and much needed community/social infrastructure. In this instance, we feel the allocation at Malmesbury should be increased and the preferred option amended to include the entire Whychurch Farm site (SHLAA ref.649).
We support Option 2A and the identification of Whychurch Farm as a suitable development site. The emerging evidence base and background documentation already suggests that
Malmesbury is a key town that could benefit from a higher allocation, not only because of an available suitable site at Whychurch Farm but also a higher allocation could help deliver the wider aspirations of the town, affordable housing and green infrastructure.
Whychurch Farm is included as a Priority 1 site in the SHLAA and is expected to deliver within the first five years. The Site is identified as having a capacity of 679 dwellings on some
45 hectares.
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There are a number of Priority 1 sites identified within Malmesbury, but none are on the same scale as Whychurch Farm. Ultimately, it is in the interests of sustainable planning that LPAs identify at least one large scale development site that can deliver a continuous supply of housing over the plan period and ensure that an appropriate level of physical, social and community infrastructure is provided as part of its delivery.
Although there are a number of perceived constraints associated with the site, none of these impact on its development potential in the context of development that could be delivered.
The principles of good urban design based on a sensitive masterplan that fully responds to its setting.
Overall, the opportunities of including Whychurch Farm as a preferred option will not only allow a greater number of affordable homes to be delivered in the town but could also provide opportunities to enhance the town’s setting by providing greater access for the public to the
Worthy’s, bringing community benefits and transport improvements.
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