Contents
1. Introduction ...... 1
2. Background...... 1
3. Consultation Arrangements ...... 2
4. Consultation Respondents ...... 5
5. Consultation Responses...... 7
6. Stakeholder Workshops/Public Events ...... 20
7. Sustainability Appraisal...... 27
8. Developing the Core Strategy...... 29
9. Resolutions of the Committee ...... 36
Core Strategy Options Consultation Kennet Local Development Framework Consultation Responses and the Council's Decisions on Considering them 1
INTRODUCTION
1.1 This document is based on a report on the Spatial Options for Future Development consultation presented to Kennet’s Planning Policy Executive Committee on 25th Sept 2008 and records the resolutions made upon considering it. Members considered the report and agreed a preferred pattern for development in Kennet. The new Wiltshire unitary council will have full regard to these decisions when preparing its Local Development Framework for Wiltshire.
1.2 The committee report included 3 separate appendices. These were approved by Members and are published as three separate documents:-
Core Strategy Options Consultation: Statement of Community Involvement; Core Strategy Options Consultation: Summary of Comments Received; and Core Strategy Options Consultation: Interim Sustainability Appraisal Report
The following analysis of consultation responses has been informed by, and refers to, each of the above documents.
2. BACKGROUND
2.1 The Planning Policy Executive Committee met on 14th February 2008, to consider a paper titled Kennet Local Development Framework, Core Strategy Options Development (report number: PSM/04/08). The committee resolved, for the purposes of public consultation, to endorse:- the key principles for developing the core strategy; the approach to developing the core strategy based upon community areas; the draft vision for the core strategy; the Community Area Profiles and summaries (included in that report as Appendix 4); the Options for Locating Future Development (included in that report as Appendix 5); that the documents included at the aforementioned Appendices be reformatted to include questionnaires to record the views of consultees; and that the measures proposed for stakeholder engagement on the above be undertaken in accordance with the Council’s adopted Statement of Community Involvement. Details of the consultation are summarised in the next section of the report and set out in the Statement of Community Involvement.
2.2 In the light of the proposals for a unitary council for Wiltshire, it was proposed that a revision to the LDS would be negotiated in order to give priority to producing a core strategy before the vesting day. It was trusted that the extensive work already undertaken by authorities would proceed to become adopted local development documents without undue delay and facilitate their smooth transition into a single core strategy at a later date. However, advice from the regional government office (GOSW) has progressively changed on both the production of local development frameworks (LDFs) and the transition to unitary local government.
2.3 Following the government’s initial announcement on the unitary proposals for Wiltshire, GOSW advice was for local planning authorities to continue work on LDFs without delay in accordance with agreed timetables. However, more recent advice has been for work to begin on a core strategy for the new authority as soon
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as practicable and certainly before the official vesting day. The implications of this advice are that work on district-wide LDFs (with the exception of the Salisbury Core Strategy1) should cease earlier than anticipated.
2.4 The successor council is required to submit a local development scheme to the secretary of state six months before vesting day. GOSW has advised that a demanding timetable for the production of a Wiltshire Core Strategy should be adopted and work should commence as early as possible. This advice and subsequent draft regulations were not available at the time of the February meeting of the committee, or during the consultation period. The original intention was to report back to the committee on the spatial options consultation and seek a resolution on a preferred development distribution. A further area of work was then to be undertaken to identify suitable sites to deliver the preferred distribution and seek a resolution from this committee on their preferred sites at a further meeting. Changes to the body assuming the role of local planning authority (outlined at paragraphs 4.1 and 4.2 above) now mean that it is likely that this committee will only be able to make recommendations to the Implementation Executive and the succeeding authority. In addition, for reasons set out in the paragraph above, it now seems most unlikely that the proposed further work on identifying sites will be undertaken for consideration by this committee.
3. CONSULTATION ARRANGEMENTS
Publicity
3.1 Publicity for and availability of consultation documents and the means of community engagement are set out in the council’s Statement of Community Involvement (adopted 2005). The usual channels of communication were employed, aimed at attracting and involving different groups of the community (articles on four local radio stations, article on front page of local press, adverts in local press, posters in shops in all towns, posters to all parish and town councils, information in all libraries and leisure centres, direct mailing to all local and regional organisations and individuals registering an interest on the Kennet web site etc).
3.2 In addition to these measures we attempted to spread the net wider and employ the use of free newspaper and other community magazine delivery services to send out copies of the leaflet. This was a departure from usual methods but was considered an additional benefit to extend our contact beyond usual practice. Many authorities have used this medium with success in the south west. Perhaps in Devizes there is a different relationship between residents and the free newspapers as some residents were not aware of the enclosures included with their papers. The distribution of the free paper appeared a little erratic in a small number of locations. However, from this experiment we have learned that the medium can produce patchy results and will use the experience to inform future exercises. In areas not covered by the free paper, distribution was achieved with
1 GOSW considered that the lack of available housing supply land was so acute in Salisbury District, that the Salisbury District Core Strategy should continue at full pace, in parallel with the production of a Wiltshire Core Strategy which would eventually subsume it.
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the help of various community groups which was reliant on the good will of local organisations. The alternative approach of direct mailing to every household in the district would have considerable cost implications and would need to be evaluated in terms of cost effectiveness, among other criteria.
Engagement
3.3 A pamphlet was distributed as described above and made available in council offices, leisure centres, libraries and at public exhibitions. The leaflet included a questionnaire to gauge views on preferred options and inform the council on the nature and distribution of respondents. The leaflet and questionnaire was also available on the council’s web site for on-line responses.
3.4 Side one of the pamphlet set out key facts and identified planning issues. It was considered that this information was needed to make an informed choice on the options. The full extent of background documentation that provided the evidence base for the core strategy was also available on the web site. The government requires planning authorities to plan on the basis of local distinctiveness. The purpose of the community area overviews2 is to highlight the features that describe the form and function of the various places in order to provide a context for addressing the issues they face. Accordingly, we have not sought to develop a standard set of indicators for each place, rather, the idea is to draw attention to those that make one place different to another. The presentation of information in the pamphlet format was very much a departure from the usual style of planning documents. Many people have found this format more accessible than lengthy technical documents. For example, the response from the South West Regional Assembly stated “we would like to comment that we found the format of the document to be very user friendly and innovative; we welcome this approach”. Other individual comments made comments such as “I support your efforts at involvement, and understand the complexity of the issues and potential outcomes”.
3.5 In addition to completing questionnaires, a number of other interactive techniques were used to aid the council’s understanding of peoples views. Public exhibitions were held for two days in Devizes, Marlborough, Pewsey and Tidworth/Ludgershall. At the exhibitions people were asked to graphically indicate their answers to questions on display boards. They were also given dots and asked to place them over the settlements mapped, which they felt could accommodate growth.
3.6 Two workshop style meetings were also held in each of the four locations mentioned above. One meeting held in each of the towns was specifically for an invited audience of key stakeholder groups in the local community such as strategic partnerships, town/parish councils and local organisations. The second meeting in each area was an open meeting with all invited to attend. On two occasions, an unexpectedly large number of people attended which resulted in
2 See section three of Local Development Frameworks Options Generation and Appraisal, Planning Advisory Service, March 2008.
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the need to change the format away from small group discussions to a more traditional public meeting with question and answer sessions.
Purpose of the consultation
3.7 Building on the outcomes of the earlier issues consultation, the purpose of the latest exercise was specifically to gain an insight into people’s views on:- A) the plan’s vision; B) further work done on the evidence base, as expressed in the community overviews; and C) the spatial options for development at strategic and D) local levels. These were set out in the committee report dated 14th February 2008. This report considers consultees’ responses under these four broad question areas.
3.8 Members will recall that the vision was based upon the visions and objectives contained in the community area plans, the Wiltshire Sustainable Community Strategy and the sustainability appraisal scoping exercise. Each of these documents was based upon their own extensive consultation exercises. The spatial options consultation document attempted to “knit” these documents together as a starting point to define a core strategy vision.
One purpose of the consultation was to gain stakeholders’ views on this version of the vision.
3.9 As stated above, the consultation document attempted to provide sufficient information to help inform people when stating their strategic preferences. The conclusions of information collected from the evidence base was presented in a single document3. This document, although available on line, was considered too large to be suitable as a vehicle for public consultation. Consequently, its contents were further distilled to capture the headline indicators for inclusion in the consultation leaflet.
A further purpose of the consultation was to get a range of views from different perspectives on the evidence base, as expressed in the community area overviews.
3.10 Perhaps the most important purpose of the consultation was to gain an insight into peoples’ preferences for the distribution of development in the district over the next twenty years. This particularly applies to housing development.
Three options for the distribution of strategic growth were set out for comment based on the current and potential function of settlements.
The options were based on an initial assessment of settlement classification and policy as set out in emerging regional spatial policy4 (RSS). This resulted in a consideration of the appropriate levels of growth in the market towns of Devizes, Marlborough and Tidworth/Ludgershall.
3 Core Strategy Community Area Overviews – Summary of Evidence Base by Community Area, Kennet District Council, May 2008. 4 RSS policy B settlements are those market towns which could be considered suitable to accommodate part of the RSS strategic housing allocation in a sustainable manner.
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3.11 The topic of housing in villages and the rural areas was identified as an important issue during the earlier issues consultation. Consequently, three spatial options were set out for development in villages that would conform with the aims of RSS5.
Views were sought on the means to promote sustainable small scale growth in a range of villages.
These comprised:- one large village (Pewsey); one large and one medium sized village (Pewsey and Market Lavington); or one large, one medium sized village, and nine smaller villages (Pewsey, Market Lavington, Burbage, Collingbourne Ducis, Great Bedwyn, Great Cheverell, Netheravon, Ramsbury, Upavon, Urchfont and West Lavington/Littleton Pannell).
4. CONSULTATION RESPONDENTS.
4.1 The response rate was very encouraging considering the non-site specific nature of the exercise and reflects the considerable effort and staff resources committed to the programme of consultation. A total number of 409 individuals responded6 to the questionnaire with 14% doing so via the internet (compared with 11% electronic replies during the previous consultation. In addition, a more detailed response to the proposals has been gained through exhibitions and workshops held with the various interest groups and the general public. The results of the questionnaire survey are set out below.
4.2 A fairly even response was made by gender (see diagram 1) and more females became involved than in previous consultations. In terms of age (diagram 2) the greatest representation came from the 51-65 age group. This demonstrates the difficulty of engaging the younger age groups, 63% of responses were from the 51 plus age group. This Compares with a previous consultation on the town centre when the corresponding figure was similar at 59%
Diagram 1 Responses by gender Sex
Female Male
46% 54%
5 RSS policy C settlements are villages and small towns not suitable for strategic growth but where some growth to meet local needs might be appropriate – subject to criteria including access to services and other sustainability indicators. 6 This compares with the 554 questionnaires and written comments received on the consultation regarding shopping development in the Devizes town centre for the area action plan under the banner of ‘What’s in Store for Devizes?’ October / December 2005.
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Diagram 2 Responses by age
Age 9% 4% Under 14
Age 15-25 17% 33% Age 26-50
Age 51-65
Age 66-75
Over 75 37%
Diagram 3 Responses by Nature of Interest
Nature of Interest
330 350 300 250 200 150 100 32 50 22 11 16 19 0 Other owner Statutory Local organisation voluntary org. voluntary Local resident Interest group/ Interest Developer/ land Developer/ business/employer
4.3 A large percentage (77%) of respondents were local residents with 15% representing interest groups and organisations (excluding developers). Diagram 4 plots the geographic distribution of the origin of comments, where this was stated. A large number of responses were received from within the Devizes and Marlborough area. Tidworth and Ludgershall also had a high frequency of responses whereas Pewsey produced a disappointing number, which was surprising given the good turnout at the public meeting. This may indicate that many people prefer to engage ‘face to face’ rather than through letters or questionnaires.
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Diagram 4 Distribution of Respondents
Number of comments Map of Kennet showing the origin of where
0 people work or live 1-5
6-10 Aldbourne Og bo 11-25 St urn Ge e org 26-40 e Winterbourne Monkton >41 F y Mildenhall f ie ld rough West Marlbo Overton
Bishops Savernake R Cannings o u
n B d Wilcot Great Bedwyn w u r a & b Rowde y a Huish g e Seend Devizes Pewsey
W Potterne North or ton Urchfont Newnton Marston E Collingbourne a s t Kingston a M e n e a r r t k g k o a o e n Chute t t s M L a e l l l v
r e in Collingbourne Ducis r E g Chute e to v West n Enford e Forest h Lavington Ludgershall C Fittleton Tidworth
5. CONSULTATION RESPONSES.
5.1 Government guidance on generating and appraising options in LDFs7 suggests that options should undergo three tests:- a reasonableness test, a community engagement test and a sustainability appraisal. The reasonableness test includes issues such as:- meeting objectives; implementation is within the council’s powers; deliverability (infrastructure availability, resources); and conformity with national and regional policy. The sustainability appraisal is dealt with later in this report. In order to consider the consultation results against the other two tests, the responses have been grouped under three general headings as outlined below. These headings also contain examples of the type of stakeholder falling within the groups.
Table 1 Options Analysis: Stakeholder Groups by Test Criteria
Conform with Government Policy and Strategic Planning Policy:- GOSW (PPS and other policy); Other Government Agencies (EH, NE, HA) Regional Assembly (emerging RSS); County Council (adopted structure plan).
Respond to Views of Statutory Consultation Groups and Infrastructure Providers Agencies responsible for Service Delivery (Environmental, Health, Utilities) Local Government (LSPs, parish councils) Adjoining authorities (region, county, parish)
7 Section four of Local Development Frameworks Options Generation and Appraisal, Planning Advisory Service, March 2008.
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Reflect Views, Concerns, Preferences and Aspiration of local communities Interest Groups Business interests Housing interests Individuals
Responses to Question Area A - Stakeholders’ Views on the Vision.
5.2 329 responses were submitted on this question and 72% of replies either agreed or strongly agreed with the draft vision (see Diagram 5 below). Headlines of the comments8 submitted on the vision are included at Tables 2a 2b and 2c. Comments from strategic authorities and organisations representing key stakeholders point to the need to revise the vision to make it more specific to Kennet.
5.3 General consultees and others were also concerned that the vision wasn’t specific enough to Kennet. There was also some doubt expressed about the ability to deliver such an aspirational list. A full list of comments received on the vision is included as Part A in the Report of Comments Received.
Diagram 5 Questionnaire result – To what extent do you agree with the draft vision for Kennet up to 2021?
Strongly disagree 0%
Disagree 12% Strongly agree 19% Neutral 16%
Agree 53%
Table 2a Responses Representing Government Policy and Strategic Planning Policy in relation to the proposed Vision- Summary
South West Regional Assembly The vision lacks local distinction Wiltshire County Council The principles are welcomed but consider that it should include aspirations and ambitions locally distinctive to Kennet.
8 The full summary of comments is contained in the Report of Comments Received.
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Table 2b Responses Representing Views of Statutory Consultation Groups and Infrastructure Providers in relation to the Vision - Summary
Environment Agency Support the principles of the vision but the first point should include “sustainable communities”. Natural England Bullet points 4, 10, 11, 13 & 14 are supported in particular. Request broadening of terms relating to recreation and tightening up terms referring to countryside and landscape. Adjoining Council The vision needs to be more Kennet focussed. Parish Councils The vision should focus on local concerns such as affordable housing and local healthcare.
Table 2c Responses Representing Views of Local Communities in relation to the Vision - Summary
General Consultees & Others Quite a few people felt the vision was well balanced but were concerned about internal contradictions/connections and questioned whether each objective should have equal value. Suggestions to make the vision more locally specific were to include reference to the North Wessex Downs AONB, Avebury World Heritage Site and the opportunities surrounding the Kennet & Avon Canal. Other issues raised included the lack of reference to health care and Kennet as a tourism destination; concerns about housing delivery and lack of infrastructure; traffic/public transport in Devizes specifically and the area generally; opportunities for young people and the need to preserve the character of our towns & villages. A widely held view that the vision is just a list of desirable aspirations difficult to disagree with.
Conclusions on Responses to Stakeholders’ Views on the Vision.
5.4 The exercise undertaken to merge the various community area plan visions and the higher level visions produced for the district and county clearly suffered from over-generalisation as a result. All the issues identified in the amalgamated vision were included as a result of consultation. As a result, there was a reluctance to edit any of these out of the statement. Similarly, there is a reluctance to add to their number as a result of numerous detailed points raised during the consultation, as these would not be at an appropriate level or scale to the nature of a document such as the core strategy. However, there has been a clear call to re-cast the vision in a way that reflects Kennet’s needs, rather than stating a general list of aspirations to which any-one could subscribe. Kennet will not exist after April 2009 and the question of how relevant a Kennet vision is in the new context must be raised. It might be more responsive (to the views raised) to reflect local concerns at community area level as a sub-set of a Wiltshire vision.
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5.5 Discussions between the Wiltshire authorities and Government Office on the timetable for preparing the Wiltshire-wide core strategy has included a proposal for pre-production community engagement that will include the plan’s proposed vision, during October/November 2008. It is recommended that the Implementation Executive should be advised to ensure that any draft vision for consultation reflects the distinctive nature of local communities.
Responses to Question Area B - Views on the Evidence Base, as Expressed in the Community Area Overviews.
5.6 Tables 3a, 3b and 3c summarise the range of comments made by respondent group. A full list of comments received in relation to the community area overviews is included as Part B in the Report of Comments Received.
5.7 About 62% of replies either agreed or strongly agreed with the characterisation of the community areas. Respondents who disagreed with the assessment (about 14%) in the main sought further emphasis with regards to local infrastructure and facilities. A number of respondents also stated that the civilian / military imbalance within the Tidworth Community Area should not necessarily be viewed as a threat (see Diagram 6 below). Similar percentages of responses agreed/disagreed with the description of planning policy issues facing the community areas, as indicated at diagram 7. Comments submitted on the overviews are included at Tables 3a – 3c.
Diagram 6 Questionnaire result – To what extent do you agree with the assessment of the characteristics of the community areas?
100% 90% 80%
70% Strongly disagree 60% Disagree 50% Neutral 40% Agree Strongly agree 30% 20% 10%
0% Devizes Marlborough Tidworth Pewsey
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Diagram 7 Questionnaire result – To what extent do you agree that the analysis of the planning policy issues facing each area is correct?
100% 90% 80% 70% Strongly disagree 60% Disagree 50% Neutral 40% Agree Strongly agree 30% 20% 10% 0% Devizes Marlborough Tidworth Pewsey
Table 3a Responses Representing Government Policy and Strategic Planning Policy on Community Area Overviews – Summary
Government Office for the South West Consultation will assist working together with other Wiltshire authorities on the “One Wiltshire” LDF. Advise that means of delivery are identified, including transport requirements, to give detail at preferred options stage. South West Regional Assembly Reminder that the Core Strategy is required to be in general conformity with RSS and point out that EiP recommendation of 6000 houses for Kennet should be regarded as a minimum to be planned for given uncertainties over content of final version of RSS. Comment that document format was welcomed as very user friendly and innovative. Relationship with Trowbridge regarding employment, commuting and cross boundary issues is mentioned. Wiltshire County Council Questions whether the impact of Trowbridge has been taken sufficiently into account. County Council not aware of evidence of increasing traffic in Marlborough town centre. Relationship between new housing and increasing long distance out commuting needs examination.
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Table 3b Responses Representing Views of Statutory Consultation Groups and Infrastructure Providers on Community Area Overviews - Summary
Natural England Overviews should recognise natural environment as a driver for tourism and health and how to enhance the natural environment. Environment Agency Planning policy issues should include protecting and enhancing the local built and natural environment. Need to refer to protecting the headwaters of the Avon and Bourne, Thames Water Property Services It is essential that developers demonstrate that adequate capacity exists for water and sewerage infrastructure both on and off site and agrees improvements and how they are to be funded. It is difficult to comment on options due to complexities of sewerage networks. Parish Council’s Concerns about affordable housing and the loss of rural services but consider overviews cover all major factors.
Table 3c Responses Representing Views of Local Communities on Community Area Overviews - Summary
Devizes Improvements to the road network are required including the management of commuter traffic. Need to safeguard Devizes natural and built environment assets. Marlborough Marlborough should utilise the strength of a picturesque town. Marlborough has a wide independent food offer including butchers and greengrocers etc. Tidworth The civilian imbalance within the Tidworth community area is potentially an issue however the opportunities that the military population can and does bring to the area should also be recognised. District Improvements should be made to public transport services and their frequency within rural areas. Infrastructure improvements should be captured and delivered in a timely fashion to ensure minimum strain on existing infrastructure provision. More facilities are needed for young people including the provision of sporting facilities and their adequate maintenance to ensure they do not fall into disrepair. Need to ensure the adequate provision and protection of employment sites.
Conclusions on Responses on the Evidence Base, as Expressed in the Community Area Overviews.
5.8 At the time of the consultation, the position regarding RSS was that the Panel’s report on the public examination recommended that 6000 houses should be provided in Kennet . Consequently, the Regional Assembly’s comments stated
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that this figure should be regarded as a minimum, given uncertainties over content of final version of RSS. However, the Secretary for State’s proposed changes to the RSS were published at the end of July 2008. It had been widely anticipated that the proposed changes would further increase housing numbers. However, in the case of Kennet District9, no amendment to the housing figure has been proposed.
5.9 Comments on the relationship of Devizes with Trowbridge appear to have been made on the basis of the contents of the summary included in the pamphlet rather than the full version of the Community Area Overviews. This latter document addresses the relationship regarding retail hierarchy and travel to work data (which shows a high level of self-containment). At the strategic level, the issue of protecting and enhancing the local built and natural environment will be dealt with through the sustainability appraisal outcome of options for development. Detailed issues will be dealt with at later stages dealing with site selection and development control policies.
5.10 Without doubt, there is a need to undertake an assessment of current infrastructure capacity and the ability to provide adequate additional infrastructure to serve the needs of new development. Discussions will take place with infrastructure providers when the preferred distribution of development has been determined (providers are reluctant to undertake detailed assessment until the probable locations are put forward, due to the scale of the task at regional/national level). This information will then allow informed decisions to be made regarding the preferred option stage. The authority will have the duty to prepare an Infrastructure delivery plan in tandem with the core strategy10.
Responses to Question Area C - Options for the Distribution of Strategic Growth.
5.11 Diagram 8 shows that a majority of responses favoured option 1C with only 11% supporting a concentration based only upon Devizes and 34% favouring development split between Devizes and Tidworth/Ludgershall. Consultees were also asked “if you have chosen 1B/1C as your preferred option, would you assign an even proportion of development to each centre. 47% answered yes, 53% answered no.
9 Despite local government reorganisation, the RSS will distribute housing allocations on the basis of district council areas, even in cases where some districts will be subsumed into new unitary authority areas. 10 Infrastructure Delivery - Spatial Plans in Practice: Supporting the reform of local planning, CLG 2008
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Diagram 8 Questionnaire results - Which of the strategic development options would you favour? Option 1A 11%
Option 1C Option 1B 55% 34%
Diagram 9 Questionnaire result - Please highlight why you have chosen your preferred strategic development option
Promotes Aids in the sustainable protection of the transport patterns environment 16% 15%
Promotes local employment opportunities Represents the 16% best distrubution for development Supports local 27% community objectives 12% Encourages economic growth 14%
Diagram 10 Preference of Option by Community Area
100%
90%
80% 70%
60% 1c 50% 1b 40% 1a
30%
20% 10%
0% Devizes Marlborough Pewsey Tidworth
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5.12 Diagram 10 also shows that the choice amongst those residing in the Pewsey Community Area was almost evenly split between focussing development on Devizes and Tidworth/Ludgershall and sharing it between the three principal settlements in the district. Just over 70% of residents from the Tidworth Community Area favoured some development in Tidworth/Ludgershall, with the largest proportion favouring a split between Tidworth/Ludgershall and Devizes (possibly because this would give the largest number to Tidworth/Ludgershall). Conversely, just under 30% of residents from Tidworth/Ludgershall wanted all development to be located solely in Devizes, the largest proportion choosing this option.
Table 4a Responses Representing Government Policy and Strategic Planning Policy on Strategic Options
South West Regional Assembly Clear that Devizes is the main centre. Marlborough and Tidworth/Ludgershall have potential to fulfil policy B (of RSS) criteria. Potential for new employment, retail and need for new housing is much greater than for other settlements. Thus an emphasis on Devizes will be a crucial part of a successful strategy. Option 1C is supported but development should not be equally spread, Devizes should be the main centre for growth and appropriate development at Marlborough and Tidworth/Ludgershall provided based on realistic assessments of their needs and growth potential. Wiltshire County Council An emphasis on Devizes will be crucial to a successful Kennet settlement strategy. Option 1C is supported but development should not be equally spread but should reflect the role and function of the 3 settlements. Devizes is a Policy B settlement and is the location where most growth should be located. Recognise that Devizes has finite capacity regarding transportation that may need to be resolved to accommodate growth. Marlborough should be capable of locally significant growth. Tidworth & Ludgershall could allow for future strategic growth provided it is carefully managed to ensure balanced development to avoid acting as a dormitory to Andover. Government Office for the South West Specific aspects of infrastructure need to be addressed. Need to develop more specific outcomes for places shown in the consultation document as the LDF process progresses.
Table 4b Responses Representing Views of Statutory Consultation Groups and Infrastructure Providers on Strategic Options -
Natural England Options need to be assessed in terms of traffic generation but recognise the difficulty of doing so at this stage. Environment Agency No preferred option but all development should be located in areas of low flood risk as identified in strategic flood risk assessment.
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Highways Agency Encourages a strategy that enables integration between transport and land use planning. Adjoining Council Development at Marlborough would need to be balanced by economic growth to avoid more commuting to Swindon. Recognise the position of Tidworth and supports Option B, provided it is proportional in favour of Devizes to recognise RSS. Parish Councils (6 replied) Further housing development should be spread throughout the district. Adequate infrastructure is needed to support development including public transport. Smaller communities are becoming dormitories. Include an objective not to change villages into small towns. Shortage of sites in Marlborough. Recognise Devizes has larger infrastructure but has seen considerable development already and need to balance the community in Tidworth.
Table 4c Responses Representing Views of Local Communities on Strategic Options - Summary
General Consultees and Others General comments related to encouraging a spatial distribution of development that responded to local needs and reflects the size, services and economy of a given place. This is seen as a way of moving towards more sustainable communities. In the rural areas dispersed, organic growth is supported. Opportunity for limited planned development in Pewsey is noted.
Devizes Devizes is seen as the principal location for housing and employment growth by groups and organisations commenting from outside the District and by planning consultants. Local comments consider development in Devizes has already exceeded its infrastructure capacity and development should not exacerbate existing traffic and congestion problems.
Marlborough Comments in relation to Marlborough consider the town should develop at a scale proportionate to its size without spoiling the countryside. Some specific sites are identified but often acknowledgement that there is limited land available in the town. Affordable housing is seen as a priority.
Tidworth & Ludgershall More development in Tidworth and Ludgershall is seen as an opportunity to develop a more sustainable community and increase the balance between civilian and military personnel. Concerns about current movement to work to Andover from Ludgershall and there is a need to improve transport links to Salisbury.
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Conclusions on Responses to Options for the Distribution of Strategic Growth.
5.13 A full list of comments received on the strategic options for development is included as Part C in the Report of Comments Received. A difference of emphasis appears to exist between the views of local residents and the strategic planning authorities (Regional Assembly and County Council). Local views clearly do not favour an emphasis on Devizes whist the statutory bodies consider that Devizes, as the principal economic driver for the district, should be the main focus for future growth. Whilst many comments recognise the role of Devizes as the main settlement in the district with higher level services, there is also a recognition that the amount of growth in the town has had consequences in terms of congestion and assimilating the speed of growth. Views have also been expressed about the loss of facilities (such as healthcare) which has raised the question of whether a district such as Kennet should accommodate the scale of growth advocated by RSS.
5.14 A view supported by many, including the Regional Assembly, is that the strategy should recognise the role of Devizes but also direct development to Marlborough and Tidworth at a scale appropriate to their role and function. However, again a difference in emphasis appears to exist between local residents and the strategic planning authorities. Local views seem to favour a reduction in rates of growth in Devizes as a response to local traffic conditions unless a solution to alleviate the problem is provided. The highway authority has stated that only a partial solution is available and this would limit the scale of additional growth. Overall, local opinions wish to see the towns of Marlborough and Tidworth/Ludgershall take a proportion of future growth both to take pressure off Devizes and also help them to meet local needs (in the case of Marlborough) and reach local aspirations and fulfil potential (in Tidworth/Ludgershall).
Responses to Question Area D - Views on the Means to Promote Sustainable Small Scale Growth in Villages.
5.15 Diagram 11 demonstrates that option 2C received the majority support for the choice of options for development to support sustainable development in rural areas. This option provides scope for the widest range of settlements containing existing services. Only a small percentage of respondents favoured concentrating rural development in one large village (Pewsey) although a significant minority opted for meeting rural needs in two centres (Pewsey and Market Lavington). Diagram 12 shows the number of preferences stated for each of the smaller settlements included in addition to Pewsey and Market Lavington. The distribution among this group of villages is reasonably constant with Great Cheverell placed at the lower end and Upavon at the higher. From diagram 13 it can be seen that supporting local services and supporting local housing need were the most frequent reasons for choosing this option.
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Diagram 11 Questionnaire result - Which of the local development options would you like to see in the core strategy?
Option 2A 15%
Option 2B 21% Option 2C 64%
Diagram 12 Questionnaire result - If you have chosen Option 2C indicate the villages where small scale development to meet local needs would be acceptable?
140
120
100
80
60
40
20 0 e s ll n l g i yn ry o a w u v b d b r eravon s Pane Bu h Upa Urchfont t Be et a at Chevere N Ram leton bourne Duc re e t g G Gr / Lit Collin ton ving a st L e W Diagram 13 Questionnaire result - Why have you selected your preferred local development option?
180 160
140
120 100 80 60 40
20
0 Supports local Assists local Encourages Supports local Encourages services and community diversification of housing need environmental facilities objectives employment improvements opportunities and new open space 18 Core Strategy Options Consultation Kennet Local Development Framework Consultation Responses and the Council's Decisions on Considering them 5
Table 5a Responses Representing Government Policy and Strategic Planning Policy on Local Options – Summary
South West Regional Assembly Policy C of RSS is appropriate to Pewsey, Market Lavington and the named larger villages. Option 2C is therefore supported where development would support local population and current services. Wiltshire County Council Policy C of RSS is appropriate to Pewsey, Market Lavington and the named larger villages which offer best opportunity for supporting sustainable communities. The extent of growth needs to be clarified and negative impacts of encouraging car travel avoided by utilising public transport opportunities.
Table 5b Responses Representing Views of Statutory Consultation Groups and Infrastructure Providers on Local Options - Summary
Environment Agency No preferred option but all development should be located in areas of low flood risk as identified in strategic flood risk assessment. Parish Councils Need to safeguard and encourage new facilities. Options should be to safeguard and promote the vitality of villages and not to accommodate housing growth figures.
Table 5c Responses Representing Views of Local Communities on Local Options - Summary
Devizes Development should be spread across the District. Development should be directed away from Devizes to alleviate further traffic congestion. Marlborough Marlborough should receive a proportion of housing development to ensure its future vitality. Marlborough should be classed as a larger village appropriate to local needs. Tidworth The villages within the community area have changed greatly residents do not wish to see any more development within the villages. Pewsey A more sustainable transport system should be encouraged. Pewsey currently suffers from poor roads. The train station should be seen as an advantage and a valuable resource for the community. The centre of Pewsey is in need of redevelopment. District Numerous comments received regarding concerns over increased village development within the district. Comments received regarding infrastructure provision and the importance of providing adequate services and infrastructure which are proportionate to demand and growth.
19 Core Strategy Options Consultation Kennet Local Development Framework Consultation Responses and the 6 Council's Decisions on Considering them
Conclusions on Responses to Local Options.
5.16 A full list of comments received on the local options for development is included as Part D in the Report of Comments Received. Part E within that document also includes some general comments that were unrelated to the specific questions in the pamphlet. These often relate to specific sites, specific local issues or details of service provision.
5.17 The strategic planning authorities support local opinion that local needs should be met in a variety of settlements where this can be undertaken in a manner that promotes sustainable development and strengthens local communities (Option 2C). This view reflects the content of Development Policy C of the RSS as revised by the Secretary of State11. Parish councils endorse the RSS view that development in villages should take place where it serves the needs of the village and not to play a part in delivering part of the strategic housing need.
6. STAKEHOLDER WORKSHOPS/PUBLIC EVENTS.
6.1 Reports of the community area workshops and exhibitions have been published and circulated to all participants, these can be found in the Statement of Community Involvement. The intention was that each of the evening meetings discussed in detail the planning issues facing each community area and the consequences of different levels of growth in each of the main settlements within that community area. There was no discussion of the proposed vision. In practice, the meetings evolved in response to the topics people attending the meeting felt were the most relevant. The tables below summarise the comments made at each event. The tables also summarise any additional comments made at the exhibitions that preceded the meetings.
Table 6: Summary of Marlborough Meetings
Marlborough Stakeholder Meeting, St Johns Church Marlborough Date of Meeting Tuesday 13th May No. of participants 4 Summary of Planning Issues Concerned about lack of take up on Salisbury Road employment site. Accommodation for key workers and young people High outward commuting Lack of facilities in rural areas Agree with analysis of Marlborough as a tourism destination Affordability a big concern – size of houses, price of houses, distribution of social houses, delivery of affordable homes Availability of community facilities – use of obligations? Protect the environment - landscape, historic environment and water sources
11 Draft Revised Regional Spatial Strategy for the South West Incorporating the Secretary of State’s Proposed Changes – for Public Consultation, July 2008.
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Slow growth in rural areas on PDL
Summary of Consequences of Growth Discussion focussed on existing planning issues Summary of Consequences of No Growth Marlborough Public Meeting, St Johns Church, Marlborough Date of Meeting Wednesday 14th May No. of participants 6 Summary of Planning Issues Affordable housing – choice, key workers, match local wages, shouldn’t be segregated High house prices effect local economy Sustain local communities – develop sense of community Village boundaries too tight Jobs needed in Marlborough New food retail store needed. Role for Marlborough as a tourist destination Summary of Consequences Need to know scale and type of housing proposed of Growth No development in areas liable to flood Use of Salisbury Road West? Increase economically active Effect on environment Build too much on gardens and open spaces? Exacerbate problems of through traffic Summary of Consequences Increasing elderly population of No Growth More of a dormitory town Marlborough Exhibition Date of Exhibition Tuesday 13th and Wednesday 14th May Summary of Planning Issues New food retail store needed. Protect open spaces within the town incl. allotments Do not encroach on wider landscape Better facilities needed including parking. Allow some development in smaller communities Consider development in villages where schools have capacity
6.2 Concerns arising from the Marlborough events included the availability and affordability of housing both in Marlborough and the rural areas. The lack of access to affordable housing, coupled with an ageing population was perceived as a problem building-up for the future that would impact on the viability of the local economy (unable to house local workers) and the delivery of local services. It could also lead to increased commuting (inward and outward). A lack of balance in the local retail offer was also noted, particularly for food shopping as a result of a concentration of establishments at the higher end of this sector. Despite these views, from diagram 13 it can be seen that residents visiting the Marlborough exhibition only voted to allocate 21% of the growth to the town.
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Table 7: Summary of Pewsey Meetings
Pewsey Stakeholder Meeting, Bouverie Hall, Pewsey Date of Meeting Monday, 19th May 2008 No. of participants 8 Summary of Planning Issues Need for affordable housing Housing should be linked to employment Employment policy should relate to size of village Infrastructure & communication issues Protect the role of Pewsey as a service centre More employment land needed in Pewsey Keep within existing boundaries Summary of Consequences Develop Pewsey’s role as a service centre of Growth Impact on the AONB if boundaries breached Few brownfield opportunities Achieve ‘critical mass’ to sustain shops Mix of houses Summary of Consequences Parishes close to Pewsey may suffer if centre declines of No Growth and services lost Fewer jobs may mean more commuting Local people may find it harder to stay local Pewsey Public Meeting, Bouverie Hall, Pewsey Date of Meeting Thursday 22nd May 2008 No. of participants Over 50 Summary of Planning Issues No housing development on Ball Road More affordable housing needed Loss of small employment sites Activities for young people Retain sense of community Summary of Consequences Is current boundary sufficient to allow incremental of Growth change? Change should be slow Support shops and facilities Impact on AONB Coalition with Wilcot? Mixed use opportunities Summary of Consequences Dormitory village of No Growth Decline in services Keep within existing boundaries Vote at this meeting initially voted in favour of keeping existing boundaries but debate then moved on and a number of people opposed this view. Pewsey Exhibition Date of Exhibition Monday, 19th and Thursday 22nd May Summary of Planning Issues Home working /small business to support local economy Retain free car parking Protect existing employment sites Infill on brownfield sites Wider range of shops in Pewsey
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Protect community facilities Need affordable homes Too much development and not enough infrastructure
6.3 There was a strongly held view coming from the Pewsey meetings that Pewsey should retain its role as a service centre with a strong sense of community but there was no agreement whether to do this required further housing. Pewsey Parish Council expressed the view that the current limits of development in Pewsey should not be extended to cater for more large scale housing growth. Indeed there was a lot of support for incremental change within the existing boundaries on greenfield sites.
Table 8: Summary of Meetings in Tidworth & Ludgershall
Tidworth Stakeholder Meeting, Tidworth Leisure Centre Date of Meeting Monday 9th June 2008 No. of participants 4 Summary of Planning Issues Increase job opportunities/reduce commuting More land for housing Employment opportunities appropriate to size of settlement and different types of industry Create a more balanced community Better co-operation between Tidworth and Ludgershall Retain the essence of villages Low cost housing needed Summary of Consequences Opportunities to combine schemes and increase energy of Growth efficiency Better relationship with MoD Opportunities for different types of industry Achieve long term objectives Summary of Consequences Houses less affordable of No Growth Don’t achieve long term objectives This group preferred strategic option 1b as the way forward and felt local option 2c was the least favourable. Ludgershall Public Meeting, Ludgershall Memorial Hall Date of Meeting Thursday 12th June 2008 No. of participants 5 Summary of Planning Issues Tidworth & Ludgershall should be looked at separately Support local small retailers Traffic through Ludgershall Supply of land in MoD ownership Infrastructure available before development e.g. play provision, schools, doctors, dentists Collingbourne Ducis not a location for major development Concerns about impact of social housing
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Summary of Consequences of Growth Discussion focussed on existing planning issues Summary of Consequences of No Growth Tidworth & Ludgershall Exhibition Date of Exhibition Tuesday 13th and Wednesday 14th May Summary of Planning Issues More green space/trees needed in housing areas. Tidworth & Ludgershall are complementary settlements Improve infrastructure – schools, shops, doctors, play areas Use privately owned land Owner occupied housing is needed. Support local businesses
6.4 In the meetings in Tidworth and Ludgershall a sense of belief in the existing plans for the two settlements came through. Concerns related to the need for a more balanced community in Tidworth and more affordable housing in Ludgershall. Whilst the two communities of Tidworth and Ludgershall recognised they had complementary role they did not want their essential differences overlooked. Representatives from the rural areas were concerned about retaining local character.
Table 9: Summary of Devizes Meetings
Devizes Stakeholder Meeting, Cheese Hall, Devizes Town Hall Date of Meeting Tuesday 3rd June 2008 No. of participants 11 Summary of Planning Issues Public transport needs improving Some development in villages only if infrastructure improves Services declining Retail offer should be linked to settlement size Retain village shops Devizes not to become a ‘clone’ Safeguard employment sites Concern about loss of services to larger urban centres Summary of Traffic Issues Continuing and increasing congestion Need significant improvement to road network to reduce congestion Improve public transport. By pass not an option Congestion in Devizes needs to put into perspective Congestion deters businesses Some mis-trust of findings of traffic modelling work Devizes Public Meeting, Ceres Hall, Corn Exchange, Devizes Date of Meeting Thursday 5th June 2008 No. of participants About 70 Summary of Issues No further growth in Devizes Detailed concerns about Quakers Walk i.e. gates,
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sewers, lighting, protection of the walk itself Concerned about number of houses already permitted and recently built in Devizes Mismatch between type of houses and jobs available Infrastructure cannot cope with more housing Loss of services – health, police, post offices Improve public transport Strong concern about congestion and traffic using back lanes Protect green spaces Opportunities in Tidworth and Ludgershall Summary of Consequences Discussion focussed on existing issues but a vote was taken of Growth at the meeting on preferences for future development in Summary of Consequences Devizes. About 80% supported the view there should be of No Growth no more housing in Devizes. Alternative, if necessary, would be strategic option 1c Devizes Exhibition Date of Exhibition Tuesday 3rd and Thursday 5th June Summary of Planning Issues Traffic congestion and consequences of traffic congestion Keep Devizes a small market town – don’t need big shops Retain environment around Devizes Housing shouldn’t exacerbate traffic Encourage small businesses Concern about the decline in services – health, police Develop brownfield not greenfield Improve public transport/reduce travel to work Growth in housing and employment should be linked
6.5 The main concerns highlighted in each of the Devizes events were congestion, the consequences of congestion and the recent decline in the range of services in the town (health, police, post offices). In terms of the future there was a strongly held view that Devizes has already seen enough housing development and policies should concentrate on maintaining Devizes’s role as a market town by improving public transport, protecting its historic character and retaining Devizes’s independent shops.
6.6 Each of the meetings in the four community areas was preceded by an exhibition that asked people to identify where they believed housing should be distributed in the District. Diagram 13 below represent those preferences. Visitors to the Devizes exhibition showed similar preferences to Devizes residents answering the questionnaires (see Diagram 10) with little support for growth in Devizes, although preference for growth taking place in Marlborough and Tidworth/Ludgershall was more evenly distributed. Visitors to the Marlborough exhibition favoured a greater proportion in Devizes with Tidworth accounting for about a third of preferred choices. The highest level of support for growth in Tidworth/Ludgershall was displayed by visitors to the exhibitions in these locations with 91% compared with 70% of residents from the Tidworth Community Area
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registering support for development in Tidworth/Ludgershall on the questionnaires. Visitors to the Pewsey exhibition did not favour significant development in the village and displayed a stronger preference for locating development in Tidworth/Ludgershall.
Diagram 14 Preferences for Distribution of Development indicated at Exhibitions
Devizes Exhibition Marlborough Exhibition
Pewsey Exhibition Tidworth/Ludgershall Exhibition
6.7 The exhibition boards also asked people to indicate which of the local options for development they preferred – small scale development concentrated in Pewsey (option 2a), small scale development concentrated in Pewsey & Market Lavington (option 2b) or small scale development directed to these and larger villages (option 2c). In relation to option 2c people were then asked to indicate which villages they felt could accommodate small scale local development. Very few people completed this part of the exhibition but the results are summarised in Tables 10 and 11 below. In addition to the villages already named in the exhibition, Seend was named in additional comments.
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6.8 The comments expressed support Local Option 2c, the same preference expressed in questionnaire responses (See Diagram 11). It was also clear that visitors to the exhibition considered some villages as capable of accommodating small scale growth. Great Cheverell and Netheravon received least support with the larger villages of Burbage, Great Bedwyn, Market Lavington, Pewsey and Ramsbury receiving the greatest support.,
Table 10 Options for Small Scale Development
Local Marlborough Pewsey CA Tidworth CA Devizes CA Total Option CA Option 2a 0 2 0 0 2 Option 2b 0 3 0 0 3 Option 2c 6 19 0 3 28
Table 11 Villages that could benefit from small scale local development
Village Marlborough Pewsey Tidworth Devizes Total CA CA CA CA Burbage 4 4 3 11 Collingbourne Ducis 3 3 1 7 Great Bedwyn 4 6 1 11 Great Cheverell 0 3 0 3 Market Lavington 2 3 5 10
Netheravon 2 3 0 5 Pewsey 7 5 7 19 Ramsbury 6 4 1 11
Upavon 3 3 No votes recorded 1 7 Urchfont 0 4 3 7 West Lavington 2 3 2 7
7. SUSTAINABILITY APPRAISAL
7.1 It is mandatory for the council to subject all planning policies and proposals to be included in the local development framework to a sustainability appraisal. The sustainability appraisal will perform a key role in providing a sound evidence base for the plan and is integral to the plan preparation process, including the evaluation of alternatives, (para 4.43, PPS12). Recent advice from the Planning Advisory Service12 reinforces the point that options must be subject to sustainability appraisal.
7.2 The first stage in carrying out a sustainability appraisal is the preparation of a ‘scoping report’ which establishes the context, existing objectives and baseline information for the district. The culmination of this research is a Sustainability Appraisal Framework that establishes sustainability objectives for the district. Kennet District Council approved a scoping report for Kennet in July 2006 (available on the web). It includes 18 objectives for Kennet.
12 Local Development Frameworks: Options Generation and Appraisal, PAS, March 2008.
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7.3 The three strategic options included in the options consultation have been subject to an assessment using Kennet’s Sustainability Appraisal Framework. The assessment is set out in the Interim Sustainability Appraisal Report and uses a system of ticks and crosses to indicate whether the strategy will be compatible or incompatible with a stated objective in relation to each main town. At this stage all the objectives have been treated equally: no priorities are implied. Furthermore, the assessment cannot be totally objective as there is a need to interpret knowledge of the area against the likely impact of development anticipated by the three strategic options. For example, once a site has been identified one can state categorically that it is or is not within the AONB. In a strategy assessment it is a judgement as to whether the scale of development proposed is likely to have an impact on the AONB. The assessment is also based on current knowledge of the area. Information may come to light as the core strategy is progressed that removes a potential negative impact or provides possible mitigation to a particular negative effect.
7.4 The first step undertaken was to consider the impact of each strategy option on each of the main settlements in the district. There are different ways to analyse the assessment. One way is a simple count of ticks and crosses in the matrix to indicate which option is most compatible with the stated objectives (see Diagram 15). In this type of analysis strategy options 1b and 1c are likely to promote a more sustainable pattern of development than option 1a. However, a more valid approach may be to focus on the occasions where likely conflict with the stated objective is likely to occur. These are most prevalent in option 1a where it is considered that focusing all development in Devizes is likely to increase congestion within the town with consequential effects on the environment. Additionally, it would not support community development, economic growth and housing for all in Tidworth or improve access to affordable housing in Marlborough.
Diagram 15 Comparison of Analysis of Strategy Options by Impact on Towns
60 Very Compatible Compatible Neutral Potential Inconsistency Likely conflict No relationship 50
40
30
20
10
0 Strategy Option 1a Strategy Option 1b Strategy Option 1c
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7.5 The second step was to consider the overall balance of impact on Kennet as a whole (see Diagram 6). This analysis concluded that option 1b has the greatest potential to promote a more sustainable development. The significant difference being the fact that Option 1b removes the prospect of ‘over development’ in Devizes which has the potential outcome of increasing green house gas emissions by increasing congestion, exceed infrastructure capacity and affect biodiversity and landscape quality by breaching existing settlement boundaries.
Diagram 16 Comparison of Analysis of Strategy Options by Impact on Kennet
Very Compatible Compatible Neutral 18 Potential Inconsistency Likely conflict No relationship 16
14
12
10
8
6
4
2
0 Option 1a Option 1b Option 1c
7.6 The sustainability appraisal is not set up to provide a simple categorical answer. It is one part of the process to help inform a judgement on the most appropriate development strategy for Kennet. The methods of assessment show that option 1a is least likely to promote a more sustainable pattern of development based on current knowledge. Options 1b and 1c provide better options although there are questions relating to the potential environmental impact of option 1c if following this strategy results in sites being identified in Marlborough in the AONB.
8. DEVELOPING THE CORE STRATEGY
8.1 Planning Policy Statement 12 states that core strategies must be:- founded on a robust and credible evidence base; and contain the most appropriate strategy when considered against the reasonable alternatives. Paragraph 8.1, above, refers to more specific government guidance on generating and appraising options in LDFs. An extract from this guidance is included at Diagram 15 which set out the three tests which options should undergo. The first of these tests requires the options put forward for consideration to be realistic and viable. The committee report considered on 14th February 2008, together with the supporting evidence base and community profiles demonstrates that the options met this test (the reasonable test).
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Diagram 17 The Tests for Options
1. the reasonableness test options presented to stakeholders and subject to SA must contribute to the plan’s objectives, be expressed in sufficient detail and be genuinely implementable in practice
2. the community engagement test options must be developed with stakeholders through a process of continuous engagement
3. the sustainability appraisal test
options must be subject to Sustainability Appraisal and the appraisal findings taken into account
Source: Section Four, Local Development Frameworks Options Generation and Appraisal, Planning Advisory Service, March 2008.
8.2 The guidance also suggests that “It may be wise to undertake consultation at the ‘issues’ stage to ensure that all the key problems and opportunities facing the area are identified before moving on to consulting on the options for resolving these … It may also be necessary to have more than one iteration of options consultation; for example, it may be prudent to consult the community, firstly, on the broad spatial options for future development in the area and, secondly, on the more detailed policy options for implementing the chosen spatial strategy.” The council has followed this advice and separated the issues and options stages of consultation. The current consultation represents the broad spatial options stage. Although the process of the community engagement test might be met, it is critical that the council demonstrates how the information gathered is used to inform its decision making. The committee’s deliberations on the choice of options in the light of the details of the consultation outcomes, set out in this report and the appendices, also form part of meeting the second test.
8.3 The sustainability appraisal is summarised at section 10 of this report (for the full document see Interim Sustainability Appraisal Report) and the results need to be taken into account when considering the option, to meet the third test.
8.4 In recommending a way forward for preparing the core strategy, the council should be guided by the outcomes of the consultation exercises, the sustainability appraisal and the policy context set by government guidance, including emerging regional spatial strategy. The key word in this context is “guided”. There may be considerations that require the outcomes of consultation and sustainability processes to be tempered or the application of policy to be modified. However, this should be firmly based on evidence and fact. In addition, although a consensus view should always be sought, it is inevitable that contradictions will emerge between sources of advice and information. These will need to be dealt
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with in a robust but transparent manner. The core strategy also needs to reflect the council’s Corporate Strategy13 and its priorities:- Community Leadership Improving Services Stewardship of the Environment Develop Strong, Safe and Healthy Communities
Officer Guidance
8.5 The following guidance on interpretation of the results of the consultation and sustainability appraisal, resulting in the recommendations, was offered to members.
Question Area A - the Vision
8.6 Comments from strategic authorities and organisations representing key stakeholders point to the need to revise the vision to make it more specific to Kennet. In the light of local government reorganisation where districts would disappear, and the production of a single core strategy, there would be little purpose in redrafting a Kennet vision for inclusion in the new plan. However, given the government’s drive for local development frameworks (LDFs) to reflect and promote local distinctiveness, coupled with the one council’s aim of strengthening local governance, some mechanism would be helpful to articulate local ambitions and priorities. This is particularly important in the context of a single LDF for Wiltshire where a common vision might lead to a greater loss of local distinctiveness.
8.7 One means of resolving this dilemma might be for the aims of local communities, perhaps at community area level, to be reflected as sub aims of any plan wide vision in the new Core Strategy for Wiltshire. It was therefore recommended that, based on its experience of the consultation exercise, the committee advise the Implementation Executive to ensure that any draft vision for the Wiltshire LDF should reflect the distinctive nature of local communities.
Question Area B - the Evidence Base
8.8 Evidence gathering is an iterative process with no end position, we can only achieve a latest position. Members have been advised throughout the process of preparing the LDF that the evidence base needs to be kept under review and updated as required. Without doubt, there is a need to undertake an assessment of current infrastructure capacity and the ability to provide adequate additional infrastructure to serve the needs of new development. Current examples are the proposals to undertake a Wiltshire Workspace Strategy study to update the findings of the four district employment land studies. The SHLAA14 will also need updating to reflect new sites put forward or granted planning permission.
13 Kennet Corporate Strategy 2007-2008, Kennet District Council, 2007 14 Strategic Housing Land Availability Assessment, undertaken jointly between Kennet DC, North Wilts DC, West Wilts DC and Wilts CC 2007.
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8.9 Government’s view that plan proposals should be realistic and deliverable has been referred to above. Deliverability will be a key test in assessing the soundness of proposals in the core strategy. Guidance has now been published15 setting out the requirement to undertake an assessment of the infrastructure that will be required to support development proposals and how it will be provided. Local planning authorities will be required to prepare infrastructure programme and delivery plan to support local development documents.
8.10 Considerable work on assessing capacity and additional need for infrastructure will need to be undertaken in conjunction with the various agencies responsible for supply and the development industry. This area of research for the evidence base will form a focus for work following the council’s recommendation on a preferred pattern for distributing future development. Work on infrastructure provision and sustainability appraisal at this level will assist in determining which sites present the best option for development proposals in the core strategy. It was therefore recommended that the committee urge the Implementation Executive to undertake work on the viability of securing required infrastructure improvements, including roads, transport, social/health facilities, prior to confirming the location of development in the Wiltshire LDF.
Question Area C - Options for the Distribution of Strategic Growth
Option 1A Devizes Focus for Development
8.11 There was general acceptance, as a matter of fact, that Devizes performed the principal role in the district as the centre for providing services and facilities and was the main focus for economic and social activity in the area. However, there is a large body of local opinion, as expressed on questionnaires and at public consultation events, that takes the view that continued growth of the town was not sustainable. In particular, the issue of congestion throughout the town caused by the current volume of traffic on a road network which appears unable to cope, was cited as a reason to reject further significant additional growth. Furthermore, the traffic modelling work16 undertaken by the County Council demonstrated that congestion could not be alleviated by the provision of a by-pass or relief road. Some respite could be provided by improving the flow and capacity on the existing road network but this was not finite.
8.12 In simple terms, the outcome of the modelling work revealed that the growth of traffic in the town will mean that remedial measures at three critical junctions are required in order to maintain an acceptable level of traffic flow at peak times. Undertaking this remedial work would not only cater for expected traffic growth but would also cater for an increase in housing of about 800 dwellings. It should also be noted that the Devizes traffic modelling study stated that improvements to
15 Infrastructure Delivery - Spatial Plans in Practice: Supporting the reform of local planning, CLG 2008 16 Devizes Paramics Model, Wiltshire County Council, Consultant’s Technical Report, Local Model Forecasting and Test Report, Mouchel Parkman, August 2007
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the network will be required before 2016, even if no additional allocations are made.
8.13 Although local views seem to favour a reduction in rates of growth in Devizes as a response to local traffic conditions unless a solution to alleviate the problem is provided, the statutory bodies consider that the town, as the principal economic driver for the district, should be the main focus for future growth. This view may be based on a lack of appreciation of the circumstances. The opposition to significant development in the town cannot be dismissed as simply a negative ‘NIMBY’ reaction. The limiting factors of traffic congestion and the limited opportunities to resolve it result in a limited capacity for new growth with a ceiling based on up-to-date evidence.
8.14 The sustainability appraisal does not indicate Option 1A as the strategy with the least damaging set of outcomes. Issues surrounding the potential impact on landscape, biodiversity and ability of infrastructure to cope (particularly roads) are identified in Devizes. The appraisal also looks at the ‘opportunity cost’ of this option in terms of its effect on other settlements. Adverse effects include loss of momentum in providing facilities, economic growth and affordable housing in Marlborough and Tidworth/Ludgershall.
8.15 In at least the medium term, it appears that this option is not viable until such time that adequate infrastructure can be provided to resolve the traffic congestion issues in Devizes. Implementation of the option would be likely to have adverse consequences on the economy and the attractiveness of the town for investment in addition to bad effects on quality of life, air quality and accessibility. It is suggested that three-way discussions should be held with GOSW and the highway authority to explain the position and reach an agreement on the optimum level of growth in the town. This currently looks to be in the range of 500-700 dwellings during the eighteen year period up to 2026. The latest position on housing provision is contained in the Housing Land Supply Statement April 2007 (the April 2008 statement is due to be published in October this year). At April 2007, 522 dwellings were outstanding (e.g. permitted but not started or completed) but 384 of these were included in the traffic modelling exercise as committed dwellings. This leaves 138 dwellings to count against the ‘ceiling’ of 800.
Option 1B Devizes and Tidworth/Ludgershall Twin Centres for Development
8.16 Option 1B was the strategy with widest support, apart from the Devizes community area where it only received 20% support compared with about 60% in Marlborough and 45% in both Pewsey and Tidworth community areas. The difficulty in interpreting these results lies with the unknown effect of ‘tactical voting’ by those stating their preferences (for example, residents of Devizes preferring Option 1C because it possibly gives greater scope for reducing numbers in Devizes). However, it is clear that this option (which offers the greatest scope for increased rates of development to the Tidworth/Ludgershall area) was most widely supported by residents of the Tidworth community area. This represents a growing consensus from residents of those two urban areas in support of a strategy to reduce rates of growth in Devizes and increase them in Tidworth/Ludgershall : albeit for different aims/motives.
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8.17 The sustainability appraisal process shows this option performing well with a larger number of indicators achieving compatibility and fewer potential areas of conflict. Compatibility mainly revolves around the potential to build a more sustainable and balanced community in Tidworth/Ludgershall whilst maintaining the status quo in Devizes. Potential conflicts arise in the Tidworth area due to the presence of major aquifers and Salisbury Plain’s European designation as a Special Protection Area for birds. This option also has an adverse effect on Marlborough where constraints on additional house-building would result in negative impacts on economic growth, access to affordable housing and a reduction in the potential for community development. The community development issue in Marlborough is related to the likely future needs of an increasing elderly population and other social capacity building issues.
Option 1C Development Directed to Devizes, Marlborough and Tidworth/Ludgershall
8.18 Taking the four community areas together, overall support is greatest for Option C but this is by no means overwhelming. At individual community area level, Devizes gave greatest support at 75%. In Marlborough, this option was second most popular with almost 40% support. It therefore appears that the majority of local opinion wishes to see the towns of Marlborough and Tidworth/Ludgershall take a proportion of future growth to help them to meet local needs.
8.19 The performance of this option in the sustainability appraisal process is the highest in delivering the highest number of objectives that are compatible or neutral and the lowest number with potential inconsistency or conflict. However, this is at the expense of lower levels of being ‘very compatible’ compared with the other options. This, perhaps, reflects the compromise nature of the option. In Marlborough, this option resulted in more positive scores for the community building objectives, including housing and employment. Negative consequences result from potential threats to the protected landscape and associated biodiversity.
Conclusions
8.20 An examination of the sustainability appraisal in terms of which option performs best for the district overall and for each town reveals the following. In overall terms option 1A performs significantly worse with Option 1B performing best. Turning to individual towns, Option 1B is marginally best for Devizes. Option 1B is also best for Tidworth/Ludgershall, whilst there is little to choose between any of the options for Marlborough. However, this assessment is made on the basis of equal weighting for each of the criteria. If greater weight is given to criteria related to community building, Option 1C performs best for Marlborough. However, this is at the expense of environmental criteria such as landscape protection.
8.21 Comments above regarding 1A lead to the conclusion that it should be recommended that this option be rejected on the basis of infrastructure problems which appear difficult to resolve. Consequently the debate revolves around which of Options 1B and 1C should be promoted. From the sustainability
34 Core Strategy Options Consultation Kennet Local Development Framework Consultation Responses and the 8 Council's Decisions on Considering them
perspective, Option 1B would appear to deliver the best strategy. However, this could only be realistically adopted, with a ‘cap’ applied to the extent of development that Devizes should accommodate. This could result in problems regarding the degree to which Tidworth/Ludgershall might be able to balance the scale of additional housing with new employment opportunities. Additionally, it could lead to a social deficit in Marlborough.
8.22 The solution may be to allocate a modest number of dwellings at Marlborough, in a location that would minimise the impact on the landscape and providing mitigation could be introduced to address any ecological consequences. It was recommended that Option 1C with restrictions on the scale of development allocated to Devizes and Marlborough should be promoted. Table 12 demonstrates how the 190017 dwellings required in RSS up to the year 2021 might be allocated in Kennet.
Table 12 Indicative Number of Additional Dwellings 2006 - 2021
RSS Policy B Settlement Dwellings Devizes 700 Tidworth/Ludgershall 1000 Marlborough 200 Total 1900
Question Area D - Options on the Means to Promote Sustainable Small Scale Growth in Villages
8.23 In relation to options for villages meeting the criteria of Development Policy C of the RSS, the choices were between one or two larger villages/small towns and a larger number of villages (11). Option 2C received the majority support for the choice of options based on the view that development should support sustainable development in rural areas. This option provides scope for the widest range of settlements containing existing services. Supporting local services and local housing need were the most frequent reasons for choosing this option. It was recommended that Option 2C is adopted to meet local needs in rural areas.
8.24 Having established the preferred future function of towns and villages, a further consultation exercise will need to be undertaken to establish preferred locations for housing sites. Options for locating development will be considered in the light of the evidence base, particularly the outcomes of the Strategic Housing Land Availability Assessment and the Strategic Flood Risk Assessment. The Sustainability Appraisal will also form part of the process of site selection. These future stages for preparing the core strategy depend on:- the outcome of 9 negotiations with Government Office for the South West on revisions to the local development scheme; and discussions regarding the programme for combining core strategies for the new unitary authority.
17 Table 9.1 of the North Wiltshire, Kennet and West Wiltshire Joint Strategic Housing Land Availability Assessment, Tym&Partners, March 2008
35 Core Strategy Options Consultation Kennet Local Development Framework Consultation Responses and the 9 Council's Decisions on Considering them
9. Resolutions of the Committee
9.1 It was resolved that the committee adopt the following resolutions and commends them to the new Wiltshire unitary authority for inclusion in the Wiltshire Local Development Framework:-
a. that, based on its experience of the consultation exercise, this committee advises that any draft vision for the Wiltshire LDF should reflect the distinctive nature of local communities;
b. that this committee urges the new unitary authority to undertake work on the viability of securing required infrastructure improvements, including roads, transport, social/health facilities, prior to confirming the location of development in the Wiltshire LDF;
c. that Option 1C with restrictions on the scale of development allocated to Devizes and Marlborough should be promoted as the preferred option for spatial distribution of housing, as set out in Table 12;
d. that Option 2C is adopted to meet local needs in rural areas; and
e. that the committee agrees that the:- Statement of Community Involvement on the Options Raising Consultation, Report of Comments Received and Sustainability Appraisal, as included at Appendices 1, 2 and 3 respectively, be approved and published.
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