123 St Johns Road FROME BA11 2BH

23rd February 2017

Eileen Medlin Development Services Central Bythesea Road, BA14 8JN

By Email to: [email protected]

Re:- Application No: 16/12279/OUT - Outline Application for development of c100 new residential dwellings on arable farmland south of Blind Lane, Southwick, West Wiltshire.

Dear Eileen Medlin,

With regard to the above application I am totally opposed to this development being approved. I have lived in Southwick and still have family living in Southwick (my Mother lived there for almost 50 years having passed away in 2014). Over the years I have been astonished to see that almost every spare inch of land has been developed, both along the main road and the old scrap yard, the Brookmead estate etc., etc.

I have also been cvoncerned, when visiting my family and the Southwick Country Park, at the constant flow of heavy traffic flowing through Frome Road and Wynsome Street. The pollution levels must have been rising at an alarming rate.

I know also that there are NO CYCLING ROUTES available for Southwick to any likely employment areas. My Father stopped cycling to work in Trowbridge, from Southwick, back in the 1970s because the road was so dangerous for cyclists that he was likely to lose his life. That road has never improved – indeed as I have indicated it has become worse.

In fact, when it comes to employment, it is unlikely that any of the likely residents of this proposed development will get any employment in close vicinity to Southwick or even Trowbridge. Between my siblings and partners we have 9 children who live in Trowbridge, Southwick or Hilperton. Only 2 of them have found work in Trowbridge. Of the others, 2 work in London, 1 in , 1 in Ringwood, 1 in and 2 in Bath. They all access their work by car!!! There is NO public transport from Southwick realistically to enable anyone to get to and from work at normal work times. Even when I was using public transport (back in the late 60s) I could not get into Trowbridge on the bus to get the link Bath bus as the traffic issues prevented it. So what did I do? I bought a car!!

I believe that BEFORE considering any large scale building programme the unacceptable traffic issues need to be addressed as well as the problems with flooding (this affected my Mother’s property in Chantry Gardens in the year before she passed). The flooding issue has always been an issue, to my knowledge, ever since we moved to Southwick in 1966. I understand, from the villagers that have always lived there, that the whole of Southwick was originally marshland and the issues from that fact, still exist.

Below are set out some of the practical and planning issues that also affect the application and which I hope you will seriously consider.

 Lack of Compliance with Strategic Planning:

The proposed development of up to 100 houses is not required in our area (Trowbridge remainder). Please refer to ’s Housing Land Supply Statement Table1: Housing delivery compared to annualized requirement (page 6) and appendix 6 – Summary assessment of supply and remaining housing to be identified (page 101).

Southwick has already exceeded its duty in terms of contribution to housing in the region. Being part of the Trowbridge Community Area Remainder, it has an indicative requirement 2006 - 2026 of 165 new homes, with 242 completions to 2016, leaving an indicative remaining requirement of zero new builds to 2026.

Redrow’s Master Plan has conveniently ‘glossed over’ these facts and looks to have deliberately omitted the 56 affordable houses, already built on the old Mowlem’s site in Southwick, from its literature.

 Southwick is a village, not a town.

I believe that Wiltshire Council has three Spatial Strategy Options for development purposes. Southwick is classifies as:

C: Small towns and villages - suitable for smaller scale developments to meet local needs. The key words here being ‘small scale’ and ‘local needs’

My understanding is that Southwick is classified as only suitable for small scale developments that are required to meet local needs.

I hardly consider the construction of 100+new homes in this location as ‘small scale’ and Redrow Homes have failed to submit with their application anything to support their claim that there is a demand for further housing in Southwick.

 Employment:

Core Policy 1 - Southwick is a village with very limited infrastructure, employment and general services and should be considered unsuitable for large scale housing developments because it would put already inadequate services under even more pressure. This would fall contrary to Core Policy 1 – par; 17 of the NPPF and does not meet the housing needs of Southwick.

There are very few, if any, employment opportunities in Southwick. Houses built on these sites would only serve to attract buyers from outside of the village. We would then be in the ridiculous situation where houses built on this site for people to move into the village, only to travel significant distances every day to secure employment. Southwick would become a dormitory village/town, impacting the community.

In this respect, can someone please explain the point of building more and more homes in Southwick? If people have to commute across Wiltshire for access to the M4 corridor and major rail networks in order to get to work.

 There is Zero Demand for Additional Housing in Southwick:

Contrary to the unsupported statements made in Redrow’s literature, Southwick does not have any immediate need for additional housing. Southwick will build a small number of new affordable homes over the next 10 years, based on need and targeted to appropriate socio-economic groups.

In this respect, other available sites in Southwick, especially Brownfield sites, should be considered for development purposes first; long before we have any need to consider this site for development purposes.

 Settlement ‘In-Fill’:

Any housing development on this site would be in-fill between settlements and would be in direct conflict with Wiltshire's Green Infrastructure Strategy.

Core Policy 29 – Also advises that open country side should be maintained to protect the character and identity of Southwick as a village.

 Site Allocation Plan:

Core Policy 2 – This proposed development site is outside the limits of development for Southwick and has not been identified for development through the Site Allocation Plan.

The current land owner submitted his arable farmland south of Blind Lane for inclusion in the SHLAA exercise, resulting in SHLAA references 3370 & 3271 being allocated.

I understand that you intend to make a decision on this outline plan in March 2017. Unless this is to reject the proposal, I fail to see how planning permission be granted on this land objectively, as all the activities needed by Wiltshire Council to complete and publish the Site Allocation Plan will not be undertaken until mid -June 2017.

If a decision is taken by Wiltshire Council to allow this planning application to proceed, it would be in breach of Core Policy 2

To impose this housing development on the Southwick community, when there is no demand for housing would also conflict with the Localism Act 2011.  5 Year Housing Supply:

NNPF par 14 and 19 - states that if the Local Planning Authority cannot provide 5 years of housing land supply then planning permission should only be granted if the benefits would demonstrably out way the adverse impact. That has not been demonstrated by Redrow Homes and is clearly not the case with in this application.

 Land-banking:

Land-banking is an activity that is now contrary to Government policy as per the Government’s most recent Housing White Paper.

The environmental study undertaken makes reference to coverage of 34 hectare. The design & access statement refers to only 4.45 hectares for development in the design and access statement, yet SHLAA sites 3370 & 3271 covers 11.5 hectares which is being sold to Redrow Homes as a single parcel, the farmer having no intention of retaining any of his land for farming purposes.

As the remaining land would not be farmed, this is suggestive of a further significant development plan in the pipeline. In short, Redrow intend to build some houses now and land-bank the remaining 7.05 hectares.

This proposal should therefore be called in by the Secretary of State as this issue is greater than just local interest.

 Settlement Boundary:

The development breeches a long recognised boundary of Blind Lane which has always been considered as the village limits. By allowing this development to go ahead would set a precedent, the consequence of which would be additional large scale development in the village, either now or in the future

My concern is that If Redrow Homes were granted permission to build on this site, or it would open up the ‘flood gates’ for new planning applications outside of the current Settlement Boundaries of Southwick. In this respect, we are already seeing two other large scale developers ‘lining up’ to submit their planning applications, the main one so far being an application for residential development of 150 homes on land East of the 361, South of Trowbridge, by Savills on behalf of Waddeton Park Ltd.

Urban sprawl and in-fill would be consequential!!

 Loss of Amenity: This attractive open site is the very heart of the community. This unadulterated aspect extends all the way to the Westbury White Horse, the Malvern Hills and Brokerswood and is priceless to residents of and visitors to Southwick. Building residential housing on it would completely destroy the amenity of the village.

The balance of the village community and cohesive nature of the local population would be put at risk. The village sense of identity will be eroded as the population expands and Southwick becomes just another suburb of Trowbridge.

The development would alter the general feel of the village and it would no longer have the same visual and spiritual appeal.

Southwick has already seen a loss of Greenfield and amenity with the consent to install at least two large solar farms within its boundaries.

200 years of farming heritage within the village would be lost forever.

Loss of Wildlife. Residents would no longer be able to freely enjoy the natural wildlife, including deer, rare birds of prey, foxes, badgers, nesting birds, bats, newts, slow worm, grass snake, water voles, etc, etc. that is so abundant on this site.

 Loss of Quality of Life:

The quality of life for existing residents and their visitors would be adversely impacted. Blind Lane and the fields to the south are used extensively for recreation purposes by villagers and visitors alike. Activities include walking, jogging, cycling, horse-riding, bird watching, artistry, etc. etc.

The additional traffic created by allowing this development to go ahead would not only affect the amenity of the village, but also put these groups at much greater risk of accident and injury.

 Erosion of Greenfield:

Government policy and its directive to Local Authorities still remain not to allow development on Green field sites. “The Government supports building on brown field sites and not green field sites"

Southwick has already been forced to give up large areas of Green field following Wiltshire Council’s decision to allow the construction of two solar farms in the village. Both of these sites are visually detracting, spoiling the open countryside. It would be unfair to expect the residents of Southwick to have to sacrifice more Green field, especially as it does not need any further housing to support local needs

Therefore, as the local authority, Wiltshire Council needs to have exhausted all brown field options in the Trowbridge area before it considers Green field sites for development purposes. Then and only then, should Green field sites be considered as an exception to Government policy.

There are many unused brown field sites in and around Trowbridge that should be considered for development, long before we need to concrete over this Green field site. The old Bowyers site and old Council Offices site in Trowbridge are ready examples of this but there are many, many more.

Furthermore, following the UK’s exit from the EU, Britain will need all of arable land to feed its people. We won't be able to rely on imports in an unstable world. Major agencies like the NFU and DEFRA are already expressing concerns regarding the levels of productive farmland currently being sold off for development purposes in the UK.

 Infrastructure:

Core Policy 1 - Southwick is a village with very limited infrastructure, employment and general services and should be considered unsuitable for large scale housing developments because it would put already inadequate services under even more pressure This would fall contrary to Core Policy 1 – par; 17 of the NPPF and does not meet the housing needs of Southwick.

Southwick simply does not have sufficient infrastructure in place to support this large scale development. The Government has stated that before building in an area the infrastructure has to be in place before further development takes place.

Southwick’s existing utilities are already over stretched. Without doubt, this development will put extra pressure and may even break existing infrastructure.

Higher capacity sub-stations, more or bigger gas pipes and sewerage waste pipes will no doubt be required, leading to digging up of the roads and general disturbance for existing residence.

1. Waste Water & Sewage:

West Wiltshire District Plan U1a - Advises that development will only be permitted where adequate foul drainage and sewerage facilities are suitable or arrangements made for their provision.

Redrow are planning to use the existing public foul sewers which are 150mm and have insufficient capacity to take any more volume. Blind Lane and Hollis Way, which are connected to this system, have had problems for many years. The existing sewers are failing, degrading and collapsing due to the fact the material that they are made from.

The sewage system that runs the length of Blind Lane constantly gets blocked and has to be frequently pumped out via the manholes either in Blind Lane or on the site in question. The suggestion that additional users are connected to the existing sewage pipework is madness.

As stated, The main sewer on Blind Lane is 150mm in diameter and will not cope with the extra demand of the development of the 100 houses, Therefore as a pre-cursor and condition of granting planning approval Redrow Homes should either i) deliver a complete upgrade to the existing sewage and waste water systems in Blind Lane and on the site., or ii) connect with the more robust Wynsome Street sewers.

1. Increase in Traffic Volumes, to from and within the village: Core Policy 60 – Advises the Council to use it’s planning and transport powers to reduce the need for travel, especially by car. This in conjunction with Core Policy 61 advises that new developments should be located with this in mind. Also to encourage alternative sustainable methods of travel (i.e. walking, cycling and by buses/public transport).

On the proposed first housing phase outlined on Redrow’s Masterplan, there will be c100 new dwellings. If there is an average of 2 new cars per household, there will be c 200+ additional vehicles using Blind Lane/Wesley Lane & C234 Wynsome Street/A361 Frome Road on a regular basis. This hardly complies with Core Policy 60.

Redrow’s literature suggest that residents either walk or cycle shows that Redrow do not know much about the area or does not care for the safety of pedestrians or cyclists in general.

As there are no designated cycle-ways in the area and bus travel is not a viable option for many as buses do not run a service post 17:00 each day, I fail to see how this plan will ever comply with Core Policy 60.

Also, the traffic surveys conducted by Redrow’s agents are flawed and need to be re-done as a high volume of traffic has therefore been completely missed and not recorded by the monitors and will not present a true statement of the traffic volumes, from to and within Southwick village.

As Blind Lane is nothing more than a single carriageway at best in places and would not support the higher volumes of vehicle traffic that this development would cause without serious issues.

Blind Lane is already being used as a rat-run by speeding traffic. This often includes Freight/Heavy traffic that travel through Wynsome Street and the centre of the village every day, to and from the White Horse Trading Estate at Westbury, because they are unable use the roads through Westbury due to the height and weight restrictions.

I am even more concerned about the prospect of a single access to the site being located in Blind Lane. A new estate of 100+ homes should have with it, its’s own roadway for entrance and exit purposes

In addition, no allowance has been made in the Master Plan to allow parking for visitors or delivery drivers on site, which would only lead to inconsiderate parking, creating a hazard to pedestrians and other users. This would need to be redressed and planned for. .

Full consideration should also be given to the increase volume of vehicle traffic on local roads due to the additional c3000 new homes being built in Yarnbrook and West Ashton. At an average of 2 cars per household this would introduce 6000+ vehicles onto local roads that are already struggling to cope with existing volumes. Access from the Yarnbrook towards the A361/Frome Road would impact Southwick. Even more reason for an EIA to be undertaken on Redrow’s proposal.

Increased noise and air pollution from additional traffic should also be considered and the impact these will have on existing and future residents of Southwick. The impact of this on resident’s health and well-being needs to be fully considered, given the Governments recent findings regarding the link between traffic pollution dementia and chronic respiratory diseases.

1. Schools and other amenities.

Southwick only has a small Primary School which I understand is already oversubscribed. There are no Secondary Schools in Southwick, the nearest being John of Gaunt or Clarendon in Trowbridge town. The location of the nearest secondary schools is a concern as they are a long walk for students when carrying their school equipment, especially for those children not in a position to either get the bus or lucky enough to get a lift. This will further congest pavements, especially along busy Frome Road at peak pedestrian flow. As mentioned earlier the demand on the roads for vehicles at these times will already be high leading to conflict at crossing points -both official and unofficial. This issue will be intensified at periods of inclement weather and during reduced daylight hours.

There is one small shop in Southwick that operates as a newsagents/grocer. We do not have a post office. There are no medical facilities in terms of GP’s Dentists, the nearest being Trowbridge which generally are all over subscribed already. Nearest hospitals are in Bath, or Bristol, although Trowbridge does have an Accident and Emergency centre. Southwick only has one pub and only two places of worship (not three as stated in Redrow’s Master Plan). With only a part time irregular bus service operating in Frome Road only, there are virtually no public transport services in Southwick. Sketchy public transport services do not run in the evenings making access to entertainment in Trowbridge, or Frome difficult. Use of a car is essential for this.

 Flooding:

Core Policy 67 requires all new development to include measures to reduce rainwater runoff and improve rain water infiltration to soil and ground.

The development is partially on a flood zone 1 and extremely close to flood zones 2 and 3.

Rain water from the area that will be hard surfaced is channelled into an attenuation area. This area of land is on clay and the water table level is always very close to the surface.

When the water flows from the attenuation pond it will feed into the Lambrook stream at a single point and this will increase the volume of water being carried off towards Trowbridge.

Unfortunately, the stream hasn’t been able to cope with the volume and has flooded the gardens south of Blind Lane. This has happened on three occasions since 2012 which shows that the flood zone models used for these flood calculations are out of date.

Southwick already has serious issues with flooding, although the various agencies do not seem to have any record of this. The Lambrook on the site runs in three directions and the site is on a well-known floodplain. I have frequently witnessed flooding in these fields and within some of the housing surrounding them, especially during autumn winter and spring.

This water will have to go somewhere. The proposal by Redrow to attenuate the flooding is the lowest cost option available to provide a solution to increased flooding and will simply result in flooding elsewhere in the village. Also, the attenuation scheme will give rise to smelly stagnant water, attracting mosquito and vermin infestations.

Existing plans are therefore grossly insufficient. Surface water from the site pumped back into the brook in this area, would just cause more flooding further down Blind Lane, Wynsome Street and Chantry Gardens.

Application 13/02007/OUT being a property on the corner of Blind Lane/Wynsome St. was recently refused planning by Wiltshire Council, due to the level of existing flooding in the area.

If Redrow’s proposal for development is to be allowed, then they should submit revised plans to drastically reduce the risk of flooding to the satisfaction of residents most likely be impacted by flooding. Also Redrow and/ or the existing landowner should also be made to set aside funds in order to compensate future flood victims in the village should such anti flooding provisions fail.

This will be a difficult and expensive ask as some residents in the village, especially those in Blind Lane, are already struggling to secure property insurance because of the existing pronounced risk of flooding.

My final point on flooding is that it is not clear from Redrow’s documentation who will have long term responsibility for maintaining the attenuation system going forward. This would need to be clarified and agreed before any plans for development are accepted.

 Impact on Ancient Trees & Hedgerows:

Who will be responsible for maintaining these ancient oaks and hedgerows going forward? Clearly, once the houses are built and sold, the developer can completely wash their hands of all responsibilities in this regard. Also, Redrow’s Master Plan shows that much of the existing hedgerow is to be removed, which I am totally against due to the impact on wildlife, wildlife habitats, environmental impact, visual degredation to the village. Other options must be considered before hedgerows are ripped out.

 Lack of Environmental Impact Assessment:

I am concerned that a full EIA has not been undertaken on this site, or deemed necessary. This planning application is for a third of the SHLAA site 3271. If you take into account the possibility of the remaining two thirds being developed, the proposed Firs Court development in Southwick, and the two Solar farms already built in Southwick then perhaps this decision not to have an EIA is a mistake and that an EIA is should be a pre- requisite before Planning Approval is granted.

 Master Plan - Other Failings and Inaccuracies:

Core Policy 45 requires a mix of housing types and Core Policy 46 requires that Redrow respond to the needs of an ageing population.

The development is selective by design, because there are no single storey homes included on the plan which would suit disabled or senior citizens, so lacks diversification. There may be elderly people in the village who would like to move into a smaller property to suit their needs, which would free-up family accommodation in the area. In this respect, why have bungalows not been included in this mix?

From the property development plans there is little evidence to support the needs of the local community regarding design of housing. From the design information it is apparent that 2 and 2 ½ floor properties do not cater for any of the less able groups

Generally, Redrow’s documentation has some serious errors and inaccuracies. For example, Southwick does not have a Petrol Garage, Post Office or three Places of Worship. Also Southwick does not have bus stops in some of the locations mentioned.

In fact, when I lived in Southwick it had many more facilities than it does now. The main village had 2 stores (the Post Office situated in one of them) and a hairdressing salon. In the then newly built Chantry Gardens, we had a Mini-Market, a high quality Butchers, a hairdressing salon and a general gift shop. Almost all of the Chantry Gardens retail space has now been converted to residential living – leaving just a takeaway eaterie. Material facts have also been omitted such as Southwick having already created significant low cost housing in the village, especially with regards to the 56 properties built on the old Mowlem’s site.

Collectively, we must question the accuracy and truthfulness of Redrow’s documentation and I would suggest a decision to grant planning permission based on its contents would be unsafe, wrong and lends itself to legal challenge.

In Summary:

I have very grave concerns regarding Redrow’s proposal. It does not bring with it any tangible benefits for the village, existing residents or future residents. The proposal is therefore detrimental to the integrity of the village and clearly its aim is just to make profit for the developers and landowner involved.

In this respect Redrow’s proposal lacks integrity. Much of the content of their ‘Master Plan’ and associated documentation is questionable. There are clearly numerous inaccuracies and half-truths contained within.

In this respect I urge you to fully reject this proposal from Redrow Homes.

In addition, I trust that Wiltshire Council will support its people and stand by its core ethical principles in this matter.

Yours sincerely

Marilyn Patrick-Smith