Response of Without Parish Council to Council on Community Governance Review Consultation 20th November 2019

Scheme 24: Melksham Merger proposed by Melksham Town Council

MELKSHAM WITHOUT PARISH COUNCIL OPPOSE THIS SCHEME

Melksham Without Parish Council set the following as one of its key objectives at its Annual Council meeting “To ensure, following the Local Government Boundary Commission for review of the unitary boundaries in the County, that Melksham Without maintains its integrity and independence in order that the rural nature of the parish and the individual character of its constituent villages and communities are preserved”. This was unanimously resolved 13th May 2019 Minute 009/19b).

The following is the initial response to the requests for Community Governance Requests (CGR) from the Full Council meeting 24th June 2019, Minute 101/19: “Melksham Without Parish Council serves the local villages around the town of Melksham, and has always prided itself on its local knowledge of, and sensitivity to, the concerns of its communities and its desire that the rural nature of the parish and the individual character of its constituent villages and communities are preserved. However, it does recognise that when a new housing development sits better within the parish of the Town Council then it should be transferred to them. It therefore stands by its offer to transfer the 100 dwellings at land to the north of Sandridge Common that have been recently built, and the 450 dwellings at land to the east of Spa Road that are to be built, to Melksham Town Council”. These proposals to transfer some 450 dwellings at Land to the East of Spa Road (Hunters Wood) and 100 dwellings from Land to the North of Sandridge Common from Melksham Without Parish Council to Melksham Town Council have been detailed in Schemes 9 and 10. The same transfers were proposed by themselves in Schemes 5 & 6 respectively. It then considered the proposal to merge the two councils at its Full Council meeting on 16th September 2019, with this response unanimously agreed under Minute 178/19: To reaffirm the response in Min. 101/19 above, with the additional statement: It does not recognise that the same applies to , Shaw, Whitley, , , Sandridge, , Woodrow, Outmarsh and believes strongly that these individual communities sit better within the existing parish boundary of Melksham Without. This complies with the guidelines of the LGBCE,

1 in terms of preserving community cohesion, improving electoral representation and providing strong, clear, physical boundaries on the ground. Melksham Without Parish Council believe that the proposal of an amalgamation by Melksham Town Council does not meet the LGBCE guidelines (Clause 114) that state “that Grouping or Degrouping needs to be compatible with the retention of community interests. It would be inappropriate for it to be used to build artificially large units under single parish councils”.

Melksham Town Council have provided no evidence or reasoning for their proposal to merge both councils and in addition, the parish council do not believe that there has been any material change since this was considered, and refused, under the last Community Governance Review which was only decided a relatively short time ago in December 2016. The parish council have been consistent in their approach, in that wherever they recognize that new housing development sits better in the Town parish it offers through the CGR process to transfer those dwellings (as in the 2016 CGR with approx. 750 dwellings from the new East of Melksham housing development and some 90 dwellings from the George Ward Gardens development.)

Melksham Without Parish Council discussed CGR again at its Full Council meeting on 11th November 2019 following the Final Recommendations of the LGBCE and on viewing “Scheme 24” online are very disappointed that the key to the maps in the Melksham Town Council proposal states that the name of the proposed newly merged council would be “Proposed new Melksham Town Council”, it sets the tone and motivation as a “takeover” rather than a “merger”; and that there is still no evidence or reasoning included in the proposal.

The following comments below relate to the two topic areas that you have detailed on your Feedback Form, but also against other guidelines in the “Guidance on community governance reviews” by the Local Government Boundary Commission for England of which “Principal Authorities are required, by section 100 (4) of The Local Government and Public Involvement in Health Act 2007, to have regard to this guidance which is issued by the Secretary of State, under section 100 (1) and (3), and the LGBCE under under section 100 (2).

3. From 13 February 2008 …. Unitary county councils …. Have had responsibility for undertaking community governance reviews and have been able to decide whether to give effect to recommendations made in those reviews. In making that decision, they will need to take account of the views of local people.

Melksham Town Council have provided no evidence that their request for both the Town and Parish Councils to be dissolved and a new Council to be created is

2 as a result of the views of local people; or that they sought the views of local people before making the request.

COMMUNITY IDENTITY AND INTERESTS

8. b) ….. the 2007 Act places a duty on principal authorities to have regard to the need to secure that any community governance for the area under review reflects the identities and interests of the local community in that area, and that it is effective and convenient; relevant considerations which influence judgements against these two principal criteria include the impact on community cohesion, and the size, population and boundaries of the proposed area:

The Parish Council consider that they have a unique understanding of the distinct character of the 5 separate villages/areas and rural hinterlands in the Melksham Without Parish and that the dissolution of the Parish Council and the creation of a new Council with the Town & Without parishes together will mean that the separate, distinct identities of the villages of Shaw, Whitley, Beanacre, Berryfield and Bowerhill will be diluted and threaten their community cohesion. A cohesive community is one where there is a common vision and a sense of belonging for all communities.

Villagers feel passionately about retaining their village identities, and we understand that the local community action groups, who are supported by the parish council will be making their own representation.

These separate village identities are recognized and encouraged by Melksham Without Parish Council who engage and support with grant funding the variety of action groups such as BRAG (Bowerhill Residents Action Group), BASRAG (Berryfield and Road Action Group) CAWS (Community Action: Whitley & Shaw) and Beanacre Community Group. There is a real danger that their voice will be lost if they became part of a much bigger parish with areas of the town that are more densely populated having a louder voice. Melksham Without regularly conducts public consultation exercises in these distinct areas to seek their views, for example in Shaw & Whitley in October 2019 on plans for the Playing Field and shortly in Bowerhill on plans for that Playing Field, and would query if this depth of seeking views in these areas would continue if the villages were to become part of a bigger town and parish area. The parish council also provide grant funding for local village magazines/newsletters in the parish including the Shaw & Whitley “Connect” magazine and newsletters published by BASRAG (Berryfield and Semington Road Action Group) as the “Berryfield Buzz”.

The importance of the protection of the villages’ individual characteristics are supported in the Core Strategy, as is the prevention of coalescence between

3

Melksham and Bowerhill. Core Policy 5.83 on Page 130 states: “Melksham and Bowerhill village have a functional relationship and are considered together for the purposes of this strategy. Therefore the housing growth identified for Melksham town will also serve to meet the needs of Bowerhill. The identity of these separate communities will need to be preserved through planning process. Berryfield is considered separately and is identified as a small village. However, it is recognized that both Berryfield and Bowerhill have strong functional links to Melksham and have important individual characteristics which should be protected where practicable. “

Whilst Melksham Town Council have not provided to the parish council, or on the Scheme documents on the Wiltshire Council website, their reasoning for merging the two councils, the parish council are aware of the comments of the Town Mayor at the Town Council meeting 2nd September 2019 which were reported in in the Wiltshire Times https://www.wiltshiretimes.co.uk/news/17924178.one- council-call-unite-town/ but not in the Town Council minutes. The article states “The merger suggestion was made by Melksham mayor, Cllr Jon Hubbard, because many of the hundreds of new homes being built in the town are located within the Melksham Without parish.

With more housing being built in Bowerhill, he says the rural barrier between the town and the without parish no longer exists and that one combined council is in the best interests of the community. He added: “The town council has always believed that the best thing for Melksham is that town and parish should be merged. “The world has moved on and we can no longer say that Bowerhill is separate. It is quite clearly part of Melksham and I think the time has come to take a more grown-up attitude towards this.”

The parish council do not agree with this, as although there has unfortunately been undesired development along both sides of Pathfinder Way whilst the Local Authority were unable to prove a 5-year land supply in this Housing Market Area, the orientation and design of the Pathfinder Place development has deliberately retained a rural buffer between Melksham and Bowerhill. At the instigation of the Planning Officer, the development is following the guidelines that it should very much look part of the Bowerhill built environment, and so is orientated towards the south, and is viewed as the “Gateway Entrance” to both the Bowerhill residential and industrial areas.

The following is an extract from the Planning Officer’s report to the Strategic Planning Committee 16th September 2016 for 16/01123/OUT Land to the South of Western Way: https://unidoc.wiltshire.gov.uk/UniDoc/Document/Search/DSA,860268 “In summary, there would clearly be a change to the landscape (which includes the town and country at this point) as a consequence of the development proposals. However it is considered that whilst bringing the built form of Bowerhill

4 towards Melksham, as indicatively detailed within the masterplan, would erode the sense of openness and physical separation; this also presents an urban design opportunity to enhance the character and appearance at this point and in doing so retain the separate identities of the two settlements and enhance the identity of Bowerhill in particular. This is clearly a challenge, but in principle it is considered that it may be achieved. The northern edge of Bowerhill currently turns its back to the agricultural land, Western Way and Melksham beyond and offers very little by way of character and may be perceived negatively. Any development proposal would need to establish, through details of landscaping, scale and layout how the identity of Bowerhill can be enhanced and the separate identities of the settlements retained. The masterplan and design and access statement illustrate a potential starting point for further negotiation that can only reasonably be considered within any reserved matters application(s). At this stage, based on the information available it is assessed that, in principle, the proposal would preserve “the identity of these separate communities (i.e. Melksham and Bowerhill)” and “important individual characteristics....should be protected, where practicable”. Indeed there is opportunity to enhance the individual characteristics of Bowerhill”

The buffer will remain, as being used for attenuation ponds, and on the west side will be the proposed additional new primary school for Bowerhill, thus retaining its open feel.

The public art contribution is quite well developed in terms of a scheme, and will be based on an interpretative large panel on Pathfinder Way to mark the entrance to the wider Bowerhill and reflect the RAF heritage of the village. Street naming ties in with the wider Bowerhill residential and industrial areas which all have a RAF link.

5

OPTION B: Omitting Shaw & Whitley The parish council, and residents of Shaw and Whitley, have grave concerns about the Town Council’s Option B proposal under Scheme 24; to merge the two councils at the exclusion of the villages of Shaw and Whitley. These were discussed at the Full Council meeting held on 16th September 2019 where residents were in attendance for another agenda item. http://www.melkshamwithout.co.uk/assets/minutes/2019/FULL%20COUNCIL%20MIN UTES%2016th%20SEPT%202019-%20APV.pdf

Minute 174/19b) Public Participation: “Chairman of CAWS (Community Action: Whitley &Shaw) regarding the request for a merger of Melksham Town and Melksham Without councils: The Chairman of CAWS was alarmed on hearing the proposal of Melksham Town Council to merge the two councils, particularly at the news that the villages of Shaw and Whitley were not included in the proposal and would be cut adrift from Melksham Without Parish Council who support them very well. CAWS had submitted comments to the Boundary Commission early in the year regarding the proposals for the Wiltshire Council Unitary North division stating that they did not identify with the town as they have different needs and issues, but they do identify with the communities of Beanacre, Bowerhill and Berryfield and would have grave concerns about this proposal going ahead and how it would affect the villagers of Shaw & Whitley. The CAWS Chair was asked if he felt CAWS’s view reflected those of the residents and he believed it did as residents had deliberately chosen to live in a village location, with access to local amenities and there was a fear that those local amenities would disappear if Shaw & Whitley were a small parish on their own, or part of a much bigger merged council where they would be outnumbered by the town residents and their issues and needs were therefore likely to be ignored. It was believed that residents of Shaw & Whitley value the current status

6 quo, being part of the wider parish of Melksham Without. The Treasurer of CAWS, was also in attendance and had lived in Whitley for over 20 years, and he agreed with the comments made by the Chair”

Minute 178/19c) Public Participation: “The Treasurer of Whitley Reading Rooms and CAWS wished to put on the record his acknowledgement of the great support provided to the residents of Shaw and Whitley by Melksham Without parish council and that a much smaller parish of just the two villages would be unlikely to be able to support two village halls as is currently done. It would also put into jeopardy the fantastic volunteer work undertaken by the CAWS Community Emergency Group; whose flood wardens were upheld across Wiltshire as an outstanding example. The Chair of CAWS confirmed again the affinity the villages had with Melksham Without parish council and the other communities within the parish and very much wished the present parish arrangement to remain”.

The concern about the future of the CAWS CEG (Community Emergency Group) who act as volunteer flood wardens is considered a legitimate concern, as Melksham Town Council do not engage with the Wiltshire Council Northern Operational Flood Working Group, and the CEG members often provide support to residents of the town in Shurnhold and Dunch Lane as there is no such support available from the town council.

Melksham Without Parish Council does not believe that the proposal of splitting the parish council ward of Beanacre, Shaw & Whitley is well thought through as there was a very clear physical link between Beanacre and Whitley via the connecting Westlands Lane.

15. In many cases making changes to the boundaries of existing parishes, rather than creating an entirely new parish, will be sufficient to ensure that community governance arrangements continue to reflect local identities and facilitate effective and convenient local government. For example, over time communities may expand with new housing developments. This can often lead to existing parish boundaries becoming anomalous as new houses are built across the boundaries resulting in people being in different parishes from their neighbours.

Melksham Without Parish Council recognise this and have therefore put forward its proposals in Schemes 9 & 10 to reflect this, as it did for earlier new developments in the CGR process in 2016.

However, these are the only areas where there has been an expansion of housing causing the boundaries to become anomalous, and so the Parish Council sees no need for the town and parish councils to be dissolved with one bigger council set up to cover both areas. The boundary between Town and

7

Without is accentuated by the A350/A365 Western Way and the new distributor road “Eastern Way” and its rural buffers therefore the redrawing of the boundary to the schemes proposed in Schemes 9 & 10 would suffice.

EFFECTIVE AND CONVENIENT LOCAL GOVERNANCE

23. ………. Ultimately, the recommendation made in a community governance review ought to bring about improved community engagement, better local democracy and result in more effective and convenient delivery of local services.

The Parish Council does not believe that the proposal to dissolve the Town and Parish Council and create one new Council demonstrates any of the above. In fact, it argues that there is better community engagement and local democracy now, under the current boundaries.

To enable a manageable council, a newly created council would presumably have approx 17 councillors and that number is still large and unwieldy. When added together, the population of the two parishes together makes the representation per councillor very high. The councillors are volunteers and it imposes a high burden of responsibility on those councillors with such high representation. It would therefore discourage those of a working age to become councillors, and thus the council would not be representative of its electorate.

As an example, *, the current 13no. Melksham Without Parish councillors represent a figure of 315 electorate each, 225 houses. However, if a new council was created covering both the town and parish, and 17 councillors were appointed then each councillor would represent 887 electorate each, and 633 houses. This change would not bring improved democracy. At present the town and parish residents have good representation per electorate by elected councillors; there is currently effective representation, participation and leadership.

*Based on No. of Dwellings in the Parish from CIL List dated 1st April 2019 Melksham Town Council 7,839 properties x 1.4 electors per property = 10,977 Melksham Without Parish Council 2,931 properties x 1.4 electors per property = 4,103

The parish council already actively engages with the members of its communities, and actively supports and facilitates the work of action groups, Assets in the community are also community led with management committees, supported with practical advice as well as grant funding, running village halls and playing fields in the Melksham Without Parish area.

The parish council believes it already provides effective and convenient delivery of services to its residents. The average Band D cost across the 8,859 parishes

8

(town and parish councils) in England for 2019/20 is £67.181, for Melksham Without this was not significantly different at £75.69 even with the additional assets it has taken on from Wiltshire Council.

The play area at Beanacre, owned and maintained by the parish council, is visited and used by many town residents, as are the playing field facilities at both Shaw and Bowerhill – although owned and maintained by Melksham Without Parish Council both the playing fields have bookings from many town residents by a variety of football teams. This means that Melksham Without parish council is providing facilities for town residents. However, King George V playing field and play area in the Town, as with others in the town, are still currently owned and partially maintained by Wiltshire Council and therefore residents of Melksham Without are also paying to support those facilities through the Wiltshire Council element of their council tax.

The Town Council proposal does not provide evidence of how this new council will improve the effectiveness and delivery of services to residents of Melksham Without. In fact, without such a clear line of communication, with elected councillors living and representing distinct areas in the parish one could question if the provision of services in the community facilities such as village halls and playing fields, such as toddler groups, friendship clubs and lunch provision for vulnerable groups could suffer. The parish council always supports the provision of services in the parish in order that residents of the parish should not have to always make the trip into town to access services; this could be jeopardized if there was a more central, one stop shop approach to providing services. The parish council already works on several joint projects with the town council and more importantly funds many of these joint projects on a higher ratio than is proportionate to its comparable number of residents. For example, it has jointly funded on a third each basis the set up of Parkrun and Junior Parkrun, and projects to develop the Melksham Railway Station with the Town Council and Wiltshire Council’s Area Board. It funds 50% of the Market Place public toilets in town, the only ones currently open. It funds 4/9 of the joint Melksham Neighbourhood Plan. The parish council not only supports a whole host of village halls and groups and organisations in the parish, but also those in town too where there is a recognition that those projects and organisations undertake work that benefits the residents of Melksham Without.

47. An important aspect to approaching sustainable communities is allowing local people a say in the way their neighbourhoods are managed. One of the characteristics of a sustainable community is the desire for a community to be well run with effective and inclusive participation, representation and leadership. This means:

 1 published by the Dept of Communities and Local Government https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/804274/Coun cil_tax_levels_set_by_local_authorities_in_England_2019-20_Revised.pdf 9 a) representative, accountable governance systems which both facilitate strategic, visionary leadership and enable inclusive, active and effective participation by individuals and organizations; and b) effective engagement with the community at neighbourhood level including capacity building to develop the community’s skills, knowledge and confidence

The parish council believes that this is already achieved by the existing two councils. The parish council believe that they already do this and it would be diluted and not enhanced by the dissolution of the two councils and setting up of a new, bigger one. The parish council already has resilient communities recently demonstrated by the active flood plan that the villages of Shaw and Whitley have with sandbags stored in place with means of distribution, products such as walkie talkies, pumps, generators and ration packs provided by grant funding from Southern Electric, and trained flood wardens in place; all supported and facilitated by the parish council. This demonstrates the building of the community’s skills, knowledge and confidence, alongside their own action groups and recent consultation events and ability to obtain grants in their own right. The parish council have taken an holistic approach and are happy to cross boundaries and work with other councils when the need arises with the approach to the flood plan being based on the flow of water rather than parish boundaries and the trained flood wardens include not only those of Beanacre which is in the parish, but also those from (neighbouring parish) and Shurnhold (in the town parish). The work of the Shaw & Whitley flood wardens is upheld as an excellent model and example across Wiltshire and sharing of best practice has been undertaken with other parish and town councils.

The parish council is also the Lead Council on the joint project of the two councils to turn the ex George Ward school playing fields into a mini country park, named Shurnhold Fields and takes an active part in the Neighbourhood Plan and Local Plan Review process.

50. Parish Councils continue to have two main roles: community representation and local administration. For both purposes it is desirable that a parish should reflect a distinctive and recognizable community of place, with its own sense of identity. The views of local communities and inhabitants are of central importance.

The residents have a much better representation under the current system; see point 23 above about the numbers of electorate represented by councillors at present and the excellent working relationship with local resident action groups.

51. The identification of a community is not a precise or rigid matter. The patterns of daily life in each of the existing communities, the local centres for education and childcare, shopping, community activities, worship,

10 leisure pursuits, transport facilities and means of communication generally will have an influence. However, the focus of people’s day to day activities may not be reflected in their feeling of community identity. For instance, historic loyalty may be to a town but the local community of interest and social focus may lie within a part of the town with its own separate identity.

The parish council has a very clear understanding of this and fears that the five distinct identities of the separate parts of the parish will be lost if the parish council is dissolved and the villages become part of a larger council with the town. Children from Shaw, Whitley and Beanacre attend the secondary school in Corsham; and & Holt scouts; they also attend Atworth youth club. Children from Bowerhill attend play group and the primary school in Seend. These nuances are recognised by the parish council and these external volunteer groups are supported with grant funding by the parish council as they understand that they are attended by the residents of Melksham Without. There are concerns that the whole, new council will become Melksham Town centric, with much less regard for the relationships that residents from the rural parish have with their other neighbouring parishes.

56. Parish Councils can contribute to the creation of successful communities by influencing the quality of planning and design of public spaces and the built environment, as well as improving the management and maintenance of such amenities. ……

Melksham Without Parish Council does contribute to the creation of successful communities already, and recognises the diverse settlements in the parish such as the historic villages of Shaw, and Whitley; the industrial estate in Bowerhill and the new developments in Sandridge, Berryfield and Bowerhill. It actively seeks funding from a variety of sources and regularly requests and uses s106 funding. It has taken on community assets from Wiltshire Council such as Bowerhill Playing Field and has been instrumental in the project for the existing pavilion to be demolished and a new one rebuilt for the benefit of the local community; obtained Lottery funding towards new allotments; Landfill funding for a new MUGA at Shaw and s106 funding for a new one at Bowerhill. It consistently consults with its residents as to what their needs and aspirations are, and documents this with external bodies such as Wiltshire Council in the Open Spaces Study recently undertaken. The Parish Council does not see any improvement or better quality of contribution to successful communities if it became part of a larger council, more that it would become more diluted. The urban view will have a larger voice as a large proportion of a newly created council will be urban, not rural. At present the rural view is considered within the context of Melksham Without. As the majority of development will take place in Melksham Without, and not the Town, it is right that the rural view of these areas is respected. There is already a designated area for a Melksham Neighbourhood Plan that covers both the Town and Without parishes and so there is already joint working on cohesive planning issues without the need to create one new council.

11

Both councils are embarking on writing a joint Statement of Common Interest with the Wiltshire Council Spatial Planning team as part of the current Local Plan Review process.

In the last few years the parish council have taken on the three play areas in the parish that were currently maintained by Wiltshire Council, with devolved service leases in place until an asset transfer can be arranged; with one taken on directly from the developer. In addition, the parish council plays an active role in pre- application planning discussions with developers and is named on several current s106 agreements. In two new developments in Bowerhill and Berryfield the parish council will take on the ownership of the play areas and has had a proactive input into their design to ensure a high level of play value, longevity and ease of maintenance. It is also working on a current planning application for a new village hall at Berryfield, again part of a s106 agreement, and is working with the community, developers and a host of professional services to ensure a fit for purpose building for this growing community.

58. It is clear that how people perceive where they live – their neighbourhoods – is significant in considering the identities and interests of local communities an depends on a range of circumstances, often best defined by local residents. Some of the factors which help define neighbourhoods are: the geography of an area, the make-up of the local community, sense of identity, and whether people live in a rural, suburban, or urban area.

AND

59. Parishes in many cases may be able to meet the concept of neighbourhoods in an area. Parishes should reflect distinctive and recognizable communities of interest, with their own sense of identity. Like neighbourhoods, the feeling of local community and the wishes of local inhabitants are the primary considerations.

This guidance keeps coming back to the views of local people, their sense of identity and their rural or urban view. How will Wiltshire Council be receiving and interpreting the views of local people? Will it be weighting the views of an urban population of the town which has over double the population of those in Without?

65. Wider initiatives such as the Quality Parish Scheme and charters agreed between parish councils and principal councils also help to give a greater understanding of securing effective and convenient local government. In such cases, parish and town councils which are well managed and good at representing local views will be in a better position to work closely with partner authorities to take more responsibility for shaping their area’s development and running its services.

12

Melksham Without Parish Council is perfectly capable of taking responsibility for developing and running services in its own parish, without having to become a new council with the town. Melksham Without Parish Council was the first council in Wiltshire to become accredited as a Quality Council when the scheme was introduced in 2009 and its Clerk is qualified to CiLCA level. The parish has a large enough electorate, precept and reserves to be able to manage its own affairs. It is not a small village satellite to a big town that would benefit from the experience and precept of the town. It has its own population of circa 7,000 and is the largest rural parish in Wiltshire, covering an area of 2,904 hectares (7,173 acres).

78. The Local Government Commission for England in its 1993 Report Renewing Local Government in the Shires” makes the point that there is a long history of attempts to identify ideal minimum and maximum sizes for local authorities. Instead its preference was for authorities to be based on natural communities and reflecting people’s choices. This is even truer today, particularly at the most local level of government.

The Parish Council believes that the current set up reflects the natural communities with the 5 distinct areas of the parish having their own identity, but grouped together to provide a cohesive group with a rural view, that has a large enough electorate already to be in a good position to develop and run its own local services.

80. The general rule should be that the parish is based on an area which reflects community identity and interest and which is of a size which is viable as an administrative unit of administration. This is generally because of the representative nature of parish councils and the need for them to reflect closely the identity of their communities. It is desirable that any recommendations should be for parishes or groups of parishes with a population of a sufficient size to adequately represent their communities and to justify the establishment of a parish council in each. Nevertheless as previously noted, it is recognized that there are enormous variations in the sizes of parishes, although most parishes are below 12,000 in population. As the population of the Town is already above the average 12,000* there should not be a need to create a much bigger Council with a much larger than average population. As per point 23 above, the Parish Council does not believe that one, new, bigger Council will improve local democracy, in fact it argues the opposite; that this would mean that the council would no longer closely reflect the identity of its communities.

*Based on No. of Dwellings in the Parish from CIL List dated 1st April 2019 Melksham Town Council 7,839 properties x 2.4 people per property = 18,813 Melksham Without Parish Council 2,931 properties x 2.4 people per property = 7,034

13

81. A parish council should be in a position to provide some basic services and many larger parishes will be able to offer much more to their local communities. The parish council feels strongly that it is already well placed to provide services to its community, is large enough with an electorate of 4,103 and precept for 2019/20 of £201,108; and does not need to join with the Town Council to achieve this.

82. There may be cases where larger parishes would best suit the needs of the area. These might include places where the division of a cohesive area would not reflect the sense of community that needs to lie behind all parishes; or places where there were no recognizable smaller communities.

Melksham Without parish council believes that it already has very recognizable smaller communities, for example, this is reflected by the recent entries into the CPRE Best Kept Village competition where individual entries have been made for Shaw, Whitley, Beanacre, Berryfield and Bowerhill. (Whitley coming 3rd across the whole of Wiltshire in 2019). The new Hunters Wood housing development has its separate identity and the Parish Council have recognized that this may better fit within the town boundary as recognised by Scheme 9.

90. If a principal council chooses to establish a parish council, or if an existing parish whose boundaries are being changed has a parish council, the principal authority must consult on, and put in place the necessary electoral arrangements for that parish.

What would this look like for a newly created council? How can residents make an accurate judgement on the benefits of a new single council if they are not aware on what warding or representation would be proposed for such a new parish? No details have been provided by Melksham Town Council.

114. In some cases, it may be preferable to group together parishes so as to allow a common parish council to be formed. Degrouping may offer the reverse possibilities perhaps where local communities have expanded. Such proposals are worth considering and may avoid the need for substantive changes to parish boundaries, the creation of new parishes or the abolition of very small parishes, where, despite their size, they still reflect community interests. It would be inappropriate for it to be used to build artificially large units under single parish councils.

Melksham Without Parish Council believes very strongly that this would be an artificially large unit if both the town and parish council were dissolved and a new council created. The parish and town councils are large enough in their own right

14 to exist and the parish council sees no benefit in them being dissolved and a new one created.

125. About 90% of the geographical area of England is covered by a parish, and this is mostly in rural and semi-rural areas. So, most populated rural areas already have a structure of local government that includes parishes and many of these have been in existence for hundreds of years. It is desirable that any changes do not upset historic traditions but do reflect changes that have happened over time, such as population shift or additional development, which may have led to a different community identity.

Apart from the new development to the east of Melksham, which has its own boundary review proposed under Schemes 9 & 10, the parish council sees no need to change the current boundaries to dissolve Melksham Without Parish Council which has been in existence since 1894.

127. In rural areas, the Government wants to encourage the involvement of local people in developing their community and having a part to play in shaping the decisions that affect them. A parish can be a useful and democratic means of achieving this.

The parish council strongly believes that this is what they currently achieve for the rural and semi-rural separate communities that it represents in Melksham Without. Any proposal to dissolve the parish council and set up a new one with the town would detract from the statement above in point 127 rather than enhance it.

147. The purpose of a review undertaken by a principal council ….. is likely primarily to concern the administrative boundaries or a new or existing parish. …. However, in addition to these primary concerns, principal authorities will also need to consider the governance of new or altered parishes. The principal council must have regard to the need for community governance within the area under review to reflect the identities and interests of the community in that area, to ensure that the governance is effective and convenient.

Points 148 – 176 cover Electoral Arrangements such as a) Ordinary year of elections b) Council size c) Parish warding The guidance states that any Governance Review should cover Electoral Arrangements, and yet none of these have been proposed and therefore not consulted on for the proposal for the creation of a new council covering Melksham and Melksham Without.

22nd November 2019 15