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Home , River Wylye

22 Grange Lane

Warminster

Wiltshire

BA12 9EY

9th December 2016

Dear Sir

Based on my experience as a member of the Neighbourhood Planning Working Group I am very concerned by the proposed planning application reference 16/10502/OUT and would like to register my objections.

Development Principles ( Core Strategy CP1) The underlying principles of the Wiltshire Core Strategy seek to manage future development to ensure that communities have an appropriate balance of jobs, services and facilities and homes. The strategy recognises that previous growth hasn’t always been delivered in a proportionate manner whereby housing is delivered in settlements where there are insufficient employment opportunities leading to out-commuting. This is the reason why the West Urban Extension is a mix of housing, employment land, primary school, local amenities etc. This development is purely a housing development and does not meet the principles of the Core Strategy in providing balanced facilities that are needed for a self-contained community.

The development does not provide additional employment area and so for new local employment relies on the employment area being developed to support the needs of the West Urban Extension. and Warminster Town Council have both recognised that Warminster is unusual in that more people commute out of town for work. The main towns for work near Warminster are Bath, Westbury, and . With the exception of Salisbury all of these would involve households from this site crossing Warminster Town Centre. It therefore will contribute to Warminster’s current traffic problems relating to commuting through the town centre and Copheap in order to reach the new employment area on the West Urban Extension or go towards Bath, Frome, Trowbridge and Westbury.

Settlement Boundary (Wiltshire Core Strategy CP2) Core Policy 2 states that within the limits of development, as defined on the policies map (which have been carried across from the H1 Town Policy Limit boundary line of the former District Plan 1st Alteration 2004), there is a presumption in favour of sustainable development within the market towns. However, outside the defined limits of development save for the exceptional circumstances detailed within paragraph 4.25 of the development plan (such as affordable housing), development will not be permitted. The site is outside of the defined limits of development for Warminster and would therefore be considered to be contrary to CP2 of the development plan. I am aware that Settlement Boundaries are currently being reviewed by Wiltshire but would point out that Wiltshire has twice asked Warminster Town Council for its views on a draft boundary. At both of these meetings the Council decided not to recommend including this site within the settlement boundary. In addition the Town Council formed a working group of residents tasked to produce a Neighbourhood Plan and steer it through consultation, examination and finally to be passed at referendum. Wiltshire Council have taken the decision pursuant to Section 38A(4) of the Planning & Compulsory Purchase Act, 2004, to ‘make’ the Warminster Neighbourhood Plan. This means that the Warminster Neighbourhood Plan now forms part of the Wiltshire Council Development Plan and the policies in the Neighbourhood Plan will be given full weight when assessing planning applications which affect land in the Warminster Neighbourhood Area. During the production of this Neighbourhood Plan the steering group in response to the draft plan consultation could have included this site within the settlement boundary but did not.

5 Year Housing Supply As indicated in the Planning Statement, Wiltshire is unable to demonstrate a 5 Year Housing Supply for the North and West HMA. The latest Wiltshire Housing Land Supply Statement calculation gives the housing supply as of 1st April 2016 as 5.13 years which is less than 5 year plus 5 percent requirement. It should be noted that the difference between these figures represents a shortfall of 161 houses. As a result of this lack of supply the supplied Planning Statement indicates that paragraph 49 of the NPPF, the housing policies of the adopted development plan cannot be considered up to date. The implication is that paragraph 14 is engaged and the application should be considered in the context of the presumption in favour of sustainable development. The question then becomes the weight that should be given to the planning policies. The recent Court of Appeal decision indicates that weight is not dictated by government policies in the NPPF but will vary according to the circumstances. Examples, given by the Court of Appeal, of circumstances that would affect the weight given in this judgment are

 The extent to which the policies fall short in providing for the five year supply

 The action being taken by the local authority to address it

 The particular purpose of a restrictive policy – such as protection of a green wedge

As has already been stated Wiltshire’s latest calculation was 5.13 years but this was the situation as of 1st April 2016. In table 3 of the Housing Land Supply Statement document the number of additional sites identified beyond the monitoring base date of 1 April 2016 for the North and West HMA is over 3000. A significant number of these sites would count towards the 5 year supply meaning that at of 1st November 2016 Wiltshire has certainly has reached the 5.25 year target. I believe that the planning policies should be accorded full weight.

Alistair Cunningham, Associate Director Economy and Planning, in Wiltshire’s recent Councillors Briefing Note 311 supports this belief and has stated -

The Council would seek to defend its position and will also bring to the attention of the inspector those large sites that have been granted planning permission since 1 April.

Housing Need Wiltshire's documentation now indicates that Warminster is 468 houses short of its target. The underlying reason for this shortfall has been the necessary delay in designing solutions for the problems associated the West Urban Extension development. Problems particularly associated with Warminster include secondary education places, flooding, pollution of the River , traffic, recreation, green buffer. Faced with these problems it was correct for Wiltshire to directly involve the people of Warminster, especially those most directly affected in the West, in the discussions as to how to develop the West Urban Extension. Time is required to provide the additional facilities needed to support development in Warminster and therefore the proposed rate of development on the West Urban Extension is the maximum possible given these constraints. The Hallam site does not provide any additional facilities and so rather than increase the overall number of houses completed it would limit the number that could be immediately developed on the West Urban Extension.

River Wylye I was recently invited by Wiltshire Council to attend 'Our Community Matters' event. One of the items that was discussed at this event was the pollution problems associated with the River Wylye. Recognising that the River Wylye is a SAC, and as such is afforded the highest protection under law, I am extremely concerned by the comments from Wiltshire Council’s ecology officer (See Below). These comments indicate that if this development in conjunction with the West Urban Extension proceed there will be significant amounts of polution discharged in the river. Given that the West Urban Extension is the site selected in the Core Stragety for Warminster it would not be appropriate to hinder development by also granting permission for this application.

Wiltshire Council’s ecology officer- “River Avon SAC - The development would presumably discharge to Warminster sewage works. This STW discharges into the River Wylye which is part of the River Avon SAC, a European protected site which has nationally agreed targets for its water quality. The targets are being widely breached across the catchment for phosphorus and the Environment Agency and Natural have therefore published a Nutrient Management Plan to demonstrate how water quality will be improved over the next few years to ensure the targets are met. However, it is currently recognised there is a high risk that the plan will not deliver its objectives for the upper Wylye (and lower Avon) sub-catchments. The Council is therefore not able to approve planning applications that would discharge to Warminster STW where they would take the quantum of development above that forecast in the Wiltshire Core Strategy.

Permitted and pending applications currently exceed the Core Strategy allocation and this places uncertainty in the short to medium term for further residential housing applications in the Warminster catchment. The Council is working with Wessex Water, the EA and NE to undertake further modelling of housing growth scenarios and identify the scope for measures that would offset additional forecast phosphate.

This situation will have implications for the current pre-application site. Optimistically the matter could be resolved within the next year. However it seems more likely that significant further growth at Warminster may be delayed until after 2020 when advanced phosphate stripping technologies may be available for the STW. Flooding The site is subject to ground water flooding issues and a large part of the site is subject to surface water flooding issues. As a resident of Grange Lane instances of flooding have been reported to Wiltshire Council over the past few years. The site is within flood zone 1 in relation to fluvial flood risk. I have been studying the recent review of ‘The Winter Floods of 2015/2016 in the UK’ which brings together both river flow and meteorological data in an analysis of the events that led to extensive river flooding. This report considered the three months of ‘remarkably persistent and exceptionally mild cyclonic’ activity which, along with Storm Desmond, included the major storms of Abigail, Frank and Gertrude. Current speculation is that the flood risk is increasing due to climate change and there are trends towards higher river flows over the last five decades, especially in western Britain. Although this flooding was worse in the north of England I clearly remember seeing many houses and roads flooded on the other side of in and Tilshead. I am therefore very concerned that if this development was to be allowed a period of persistent rain would not only cause this site to flood but also increase significantly the risk of flooding to adjacent properties.

Access The proposed access from this site is onto Boreham Road which until the construction of the Warminster bypass this road was part of the A36 between Southampton and Bristol. Although this road is now classified as a B road the speed of traffic in both directions is significant. I am concerned that since this is the only access to the site there is a high risk of accidents happening. I know from personal experience of trying to enter/leave Grange Lane that extreme care is required to avoid accidents.

Environment This site was considered for development during the West Wiltshire District Plan and in his report the examiner described the site as -

“I saw that the land mostly comprises arable fields, with similar fields to the north, together with a few cottages and other houses (some set in trees) and bounded by lanes or roads, to the east, west and south. Although there is urban development immediately to the west (across Grange Lane), the area has a pleasant and obviously rural appearance and is very much on the edge of Warminster. From my observations from local footpaths to the north, west and east of the area and from Battlesbury Hill I consider that the land relates well in visual terms to the open countryside to the north and east, forming an integral part of the countryside east of the town. I accept that a high stone wall and cottages fronting Boreham Road impact on any meaningful visual relationship with the countryside to the south, other than when seen from the Hill top. However, in view of the open-ness of the land and its linkage with other open land to the east and north (and especially Battlesbury Hill), I consider that the town policy limit hereabouts should be drawn along the eastern edge of the denser development fronting The Dene, St George’s Close and (the southern part of) Grange Lane.”

The character of this site has not changed since this time and I agree with Wiltshire’s Conservation Officer that – The development of this site is extremely problematic in terms of the potential adverse impact the development would have on the character of the area and the setting of designated heritage assets, principally House and the Bishopstrow Conservation Area.

Irrespective of the quality of the development or design of the individual units, it is difficult to see how development of this area would make “a positive contribution to local character and distinctiveness” of the area (para 126 of the NPPF). Core policy 58 also requires that ‘development should protect, conserve and where possible enhance the historic environment’. My view is that this proposal would fail to protect or conserve.

Conclusion I feel that Wiltshire Council has spent many years considering the best options for development which resulted in the Core Strategy recommended after a long examination by the Planning Inspectorate. This site was considered as part of this process and rejected at the planning stage by Wiltshire and then again at the examination stage by the planning inspector. Hallam are attempting to take advantage of Housing Supply to try and bypass planning policies developed in conjunction with the people of Wiltshire over several years. Therefore, based on the reasons above, I believe that that this speculative application should be refused as being inconsistent with the adopted Wiltshire Core Strategy and Warminster Neighbourhood Plan.