Responses to Question 17 – Community Area - Core Policy 17

Cross ID Comments Officer Comments Issue Reference

The North Wessex Downs AONB supports reference to the AONB but this has not been fully explained within the policy. There are issues over impact on the setting of the AONB from the Drummond Park Noted. The site area for the allocation does extend beyond development (which have led to changes of the planning application). Reference to the AONB should the current application site. Further consideration will be 149 SO5 AONB be included in the Drummond Park section. The inset map with map 5.16 is also questioned as it given on how the impact on the setting of the AONB can be appears to show Drummond Park extending across the main road and towards the AONB to the north, better referenced and mitigated against which does not accord with the existing application site area and takes in a greenfield site.

I am content with the general principles of a strategy. I will, however, limit my comments to the Tidworth Community Area. I am concerned at the lack of highway infrastructure improvements for Ludgershall and believe that more flexibility is required in terms of the housing and employment allocations for the area. Ludgershall’s Memorial Junction is nearing capacity but the financial contributions that have been and will be set aside for highway solutions will not even scratch the surface. The only way to resolve the problem is to provide a second road that runs parallel with the existing A342 or a bypass for the town. This can only be achieved through further development over and above the developments planned at Granby Gardens and Drummond Park. I am not necessarily saying that we should include another 1000 Noted. The future of the vehicle depot is still to be clarified. plans in the strategy, which would provide a bypass, but allow for a windfall site or sites that would allow These comments will be passed to the highways team and Highway 201 for highway infrastructure improvements for Ludgershall. However, any such windfall site should only be a further assessment of the traffic situation in Ludgershall infrastructure allowed if the MOD sells the old vehicle depot for development. This would allow for a potential bypass will be included in the next round of the core strategy. to be built. The old vehicle depot should be an industrial park and housing with the land beyond Empress Way leading to the A342 beyond Faberstown being allocated for housing which would provide the remainder of the bypass. The old vehicle depot is potentially very important for the local economy as Castledown Business Park will not sustain the local employment needs on its own if the land beyond Empress Way and the vehicle depot were to be sold for housing. It must, therefore, be at least a mixed development or just industrial. Both areas can only be looked at as a joint venture as singularly they will worsen Ludgershall’s road problems. Moving to Tidworth itself, if the MOD does not require site 19 for housing, this should be a reserve housing site for civilian growth in the town. Ludgershall could take a lot more housing but will need a bypass on NE. quadrant to tke traffic to 303. The current application does included detailed proposals Highway 980 Zog should contribute more money in the implementation of this strategy. I could also open up more on NE site for a bypass. infrastructure prospect for the vehicle depot. We support the recognition of the land at Drummond Park (MSA Depot) as capable for accommodating 550 dwellings and as a key development priority for the Tidworth Community Area. We broadly support the issues to be addressed in the planning for the Tidworth Community Area - subject to the following comments: Whilst we note the reference to the low concentration of employment sites, it should also be noted that the Castledown Business Park is significantly under utilised and has capacity to accommodate substantial growth. Residential development at Drummond Park will help support improvements to Castledown Business Park, by providing new homes to support a future workforce. Hence, there should be policy support to new development which will help support the future phases of employment development at Castledown Business Park; We agree that Ludgershall offers only limited Support Noted. Comment regarding employment and CiL Drummond 1002 retail development (and that this is somewhat fragmented). In our view, policy should encourage new CP3 and developer contributions will passed on to the relevant Park Strategic development within Ludgershall (which will draw in new residents and investment) which can stimulate officer. Site an improvement in facilities; We recognise that there has been disparity between the military and civilian employment within the area. We consider that the development of the Castledown Business Park is a positive non-military employment provider and will encourage a greater civilian base to the area, thus addressing the imbalance. Furthermore the redevelopment of Drummond Park will provide significant housing opportunities to encourage a non-military population to the area; We agree that the settlements of Tidworth and Ludgershall have the potential for new growth on previously developed land, particularly on sites which are well related to the town centres. We consider that Drummond Park is prime example of an appropriate brownfield development which provides good links (pedestrian, Cross ID Comments Officer Comments Issue Reference cycling and via public transport improvements) to the town centre. Whilst we note support the list of ‘essential infrastructure requirements' for the Tidworth community area, however it is fundamental that Community Infrastructure Levy (CIL) in accordance with the CIL Regulations 2011, strikes a balance between securing additional investment for infrastructure to support development and the potential economic effect of imposing CIL upon development across their area. It is vital that the Council identifies the total cost of the ‘essential infrastructure requirements' that it desires to fun from CIL. In order to do this, will need to consider what additional infrastructure is needed in its area to support development. It is vital that future policy relating to developer contributions is flexible and recognises the need to encourage rather than restrain development. When establishing the scope and scale of developer contributions required to support new development, the Council should also take into account individual sites costs, scheme viability and other scheme requirements. Given the current economic climate, it may not be possible for developers/developments to provide the full contributions sought. Accordingly, the Council should encourage developers/applicants to submit an ‘open-book' viability assessment to demonstrate the maximum level of contribution which could be supported. If the level of growth envisaged/required is to be delivered, in accordance with the emerging National Planning Policy Framework, policy should ensure that the scale of obligations should not burden the sites ability to be developed, viably. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, local standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and on-site mitigation, provide acceptable returns to a willing land owner and willing developer to enable the development to be deliverable. There is no mention in the Core Policy of the North Wessex Downs Area of Outstanding Natural Beauty Noted. Consideration will be given to improving references 1032 (AONB). Any development must have due regard to the AONB, including an assessment of the likely to AONB and the setting of AONB in regards to the AONB impact of proposed development on the AONB. allocated site.

Tidworth. We note that the Site Selection topic paper states that the only strategic allocation in this Noted. The site boundary has not been extended beyond Community Area is 550 dwellings on brownfield land on land at Drummond Park, Ludgershall. However, that set out in the Site Selection topic paper. The land to we also note that the strategic allocation includes land to the north east of the A342. Whilst detailed the north of the A342 has been assessed alongside the rest work (not submitted as part of this consultation) has established that, subject to suitable landscaping, of the site, there is no greenfield land to the south east of the land to the south west of the A342 could be developed without unacceptable impact on the North 1103 the allocation although this may refer to land to the south AONB Wessex Downs AONB, there is no evidence to demonstrate that the land to the north east of the A342 west. Consideration will be given to the impact of these would have an acceptable impact. It also includes greenfield land to the South East of Drummond Park, greenfield sections of the allocation on areas that might be which we regard as a valuable (albeit non designated) landscape asset. We are thus not clear why the considered valuable landscape assets or likely to affect the boundaries of the allocation extend beyond that stated in the Site Selection topic paper, and advise that, setting of the AONB. to be justified, they are adjusted to that given in the Site Selection topic paper.

Consultation on emerging Wiltshire Core Strategy Development Plan Document Ludgershall Town Council broadly accepts the above document, however listed below are their comments which relate to Ludgershall. The housing developments proposed at Drummond Park, Granby Gardens and possible Empress Way will provide approximately 1,000 new dwellings in the area. The lack of major highway infrastructure work needs to be addressed urgently with a bypass or link road to alleviate traffic from High Street, Castle Street and Butt Street, part of the conservation area of Ludgershall, this area must be protected. The considerable increase in population will impact on the following facilities, they all need Support Noted. A further assessment of the traffic situation 1372 to be reviewed and addressed - pre-school, primary and secondary schools, NHS medical/ denistry, in Ludgershall will be included in the next round of the core Highways water and sewage infrastructure and local givernment administration. The enhancement of cycle ways strategy. and pedestrian walkways should be included at all new facilities. The most important aspect is to create substantial local employment in Ludgershall as we cannot rely on Andover or Amesbury providing increased employment needs for the area. The Castledown Business Park must be developed to accomodate labour intensive businesses. An important aspect of the Core Strategy is to provide windfall sites for development but preclude the use of garden infill sites as this will be detrimental to the local area in the long-term. Ludgershall being located on the eastern end of Salisbury Plain Training Area and Cross ID Comments Officer Comments Issue Reference on the fringes of the North Wessex Downs AONB seriously limits the availability of land to expand, therefore negotiations with the Ministry of Defence should be ongoing to provide increased land for lcoal community amenities.

Southern Water owns and operates Ludgershall Wastewater Treatment Works (WWTW), which is located approximately 1.5 km southeast of Drummond Park. Drummond Park is located within the Veolia inset appointment in this area, which is operated by Veolia rather than Southern Water. However, if the site is proposed to drain to Ludgershall WWTW, additional capacity would be required in order to serve the development. The investment required would need to be funded through Ofwat's periodic Noted. These comments will be taken into accost when review of charges process. The next periodic review is in 2014 to cover the investment period 2015 to preparing the schedule of infrastructure requirements that 1525 2020. The earliest possible date by which additional capacity could be delivered to serve Drummond will be provided for the site and during the process of Park is 2017. There is also limited sewerage capacity in the catchment to convey wastewater from new ensuring the site is deliverable. development to the WWTW. If Drummond Park is proposed to connect to Ludgershall WWTW, an assessment would need to be carried out to establish the impact of additional flows on the sewerage system, and/or the possible route of new infrastructure. The timing of development would need to be co-ordinated with provision of this infrastructure.

Core Policy 17 : Everleigh should be added to the list of small villages in the Tidworth Area. Noted. Consideration will be given to the status of Everleigh Infrastructure Requirements [Paragraph 5.15.7]. The following key services should be added to the list and whether it should be added as a small village. The list of infrastructure requirements in order to reflect the rural nature of the Tidworth Community Area with of infrastructure requirements that is included in place many remote villages such as Everleigh: Improve telecommunications including broadband (as specified specific core policies only identifies requirements that are 1654 in Core Policy 3) Maintain and improve highways, especially major roads such as the A342 and A33 CP1 place specific. The list of infrastructure are addressed in the Everleigh Enhance public transport connectivity to rural villages; for example, Everleigh has recently suffered a general infrastructure policies of the Core Strategy and drastic reduction in bus services to Tidworth & Ludgershall [from 3 or 4 buses to one bus, per day each other council strategies, nevertheless if there are specific way]. While usage in the past may have been poor, this should be balanced against the need to provide issues with the requirements that have been highlighted a bus service for isolated communities. these will be added to the core policy. Cross ID Comments Officer Comments Issue Reference

Additional land should be identified at Tidworth to meet housing needs (see objection to Core Policy 2). Furthermore deferring the identification of “non strategic sites” to Community led Development Plans or The decision to remove a number of sites that were a subsequent development plan document will not aid delivery particularly in respect of the market previously indentified was taken with the view that these towns including Tidworth which are to be the focus of “locally significant development” (Core Policy 1). It could be better planned for in subsequent DPDs and/or is considered at the very least directions of growth should be identified. Considerable evidence exists, new Neighbourhood Plans. Sites that have been included 1820 Strategic Sites including the work undertaken in connection with the Wiltshire 2026 Consultation and the responses in the Core Strategy are those that are considered vital to thereto which would enable directions of growth to be identified. In that context it is considered that land the success of the overarching strategy of the document. at Zouch Manor previously identified in the Wiltshire 2026 document which, whilst within the existing Smaller non-strategic sites will be delivered through other development boundary of Tidworth, should be identified for the development of up to 130 dwellings. The mechanisms. schematic plan below shows how residential development can be accommodated on this land.

Chapter 5 states: " As the Tidworth, Netheravon and Salisbury Garrisons have been designated as a ‘Super Garrison', the military population in the area is expected grow and new military housing is planned. Military personnel are also likely to remain in the area for longer. This strategy will help to deliver wider improvements to services and facilities in the community area and thus contribute to the integration of the civilian and military community. Employment growth will be provided to help diversify the economic base, thus reducing the reliance on the MoD, but also allowing opportunities for related industries to locate to the area and benefit from being co-located with specialist military services. The The final paragraph of Core Policy 17 is as stated in the area's excellent road connectivity adds to its attractiveness to employers. The reuse of brownfield response, this makes it clear that all brownfield sites, military land will be a priority to support sustainable local employment growth. This will be particularly including MoD sites, will be considered for residential and important as there is currently a shortage of quality employment premises for small and medium sized employment uses. Specific references to MoD brownfield enterprises including incubation facilities and managed workspaces in the area. " The re-use of sites offering opportunities to help diversify the economic brownfield land should be determined upon the merits of the site and wider economic, social and base of the area simply recognise the nature of current use environmental issues. It is not acceptable or appropriate to seek to restrict the re-use of military land for of MoD sites. References to brownfield land in Core Policy 2008 Military Land employment uses only. Paragraph 5.15.6 states: " The settlements of Tidworth and Ludgershall will 17 are not exclusively related to MoD sites, although it is have developed their complementary roles and taken full advantage of the A303. Growth will have acknowledged that the majority of sites will most likely be reflected the need to create a more balanced community and act as a catalyst to attract inward MoD sites. It is felt that policies 17 & 24 can be applied investment with new employment opportunities complimenting those provided by the MoD. The future of complementary unless significant changes occur to Core existing and former Ministry of Defence sites will be carefully integrated into the needs of the wider Policy 24. If significant changes occur to Core Policy 24 community ." Core Policy 17 states " Proposals for residential and employment growth should prioritise then reference to proximity of settlements may need to be the re-use of brownfield sites. Proposals for Greenfield development will not be supported unless it can included in Core Policy 17. be demonstrated that alternative brownfield sites are not viable and cannot be delivered ." This policy makes no reference of proximity to settlements. Proposed Policy 24 does not comply with Core Policy 17. Any redevelopment of MOD sites will come forward with appropriate community consultation. The needs of the wider community shall be fully considered, however, the operational requirements of the MOD, or Treasury Rules regulating disposal of sites, shall be of paramount importance. Please refer to wider comments relating to Question 22. Cross ID Comments Officer Comments Issue Reference TIDWORTH The Tidworth area is now included in the SWEP economic area although not included within the South Wilts Core Strategy document. Specific points relevant to the Tidworth area were noted: 5.15.3 Whilst "Tidworth/Ludgershall is not identified as a location for new strategic employment growth ...... - it should be recognised that to reach a balanced military and civilian community; fulfil Noted. Although Tidworth is not identified as strategic the current housing requirement c 1200 private houses; that more employment land may be required. To location for employment, new employment and a cover the longer term it would be sensible to start to identify potential employment land now. Following diversification of the current economic base are clears aims recent announcements by the MOD concerning future defence spending cuts and very significant of the spatial strategy for the area. Proposals for economic reduction in manpower levels, the likelihood of new married quarters (MQs) being built as planned on a Employment development will be seen in this context and will be 2073 reserved site in Tidworth must now be very uncertain. Assuming that the Army will continue to be based Land & Military supported where they do not undermine the overarching in garrisons around the Salisbury Plain area, remain in the same station for much longer, and mindful of Housing economic strategy. The comments about MQs are the current shortage of MQs that is driving the need to increasingly rent from the private sector, there is acknowledged as an onging issue, careful monitoring of a growing concern that new housing developments to be erected for the civilian market will be bought by this situation will be needed to ensure the plan does service personnel. If this does occur we will be unable to meet the demand of the Local Plan to better succeed in its stated aims. balance our community. If this is allowed to happen, all the planning to get to this point and opportunities now open to us will be placed at risk - to the advantage of neither part of the community. Recommendation The growth of the Tidworth area housing must be closely monitored and must match the civilian requirements. The proportion of East Wilshire's housing growth directed to Tidworth is too high. Despite some significant Local Plan allocations, Tidworth and Ludgershall have accommodated 14% of East Wiltshire's housing growth over the period 1996 - 2010. The Core Strategy wants to increase this to 32% over the 20 year plan period. This will require more than doubling annual average completion rates from less than 40 dwellings per annum achieved over the last 15 years, to 96 dwellings per annum over the remainder of the plan period. It is questionable whether this is deliverable. The Core Strategy is actively The proportion of housing being directed to the Tidowrth seeking to put the greatest proportion of new homes in East Wiltshire in the unsustainable location of Community Area is consistent with long standing policies 2113 Tidworth and Ludgershall which has delivered very low rates of growth in the past (despite significant CP2 Housing that have looked to provide a more balanced sustainable Local Plan allocations) demonstrating a poor housing market, suggesting that the area is not a desirable balanced community. place to live. This is inconsistent with the emerging National Planning Policy Framework which states that ‘everyone should have the opportunity to live in high quality, well designed homes, which they can afford in a community where they want to live'. The Core Strategy needs to be reviewed to redirect the majority (at least 50%) of future development towards Devizes as the principal town in East Wiltshire. The Community Area of Tidworth and Ludgershall should play a secondary role in the spatial hierarchy for the district, taking a maximum of 20% of East Wiltshire's future growth. See supplementary report. The housing allocation for the Tidworth area is completely focused on providing housing for Tidworth and Ludgershall (1750 new houses between 2006 and 2026) whilst the other villages within the area have been allocated a mere 150 new houses. From this 150, 64 have already been provided so only 86 remain to be provided for all the other villages for the next 15 years! These other villages consist of Collingbourne Ducis and Netheravon, Collingbourne Kingston, Enford, Chute Cadley, Chute Standen The number of homes expected to be delivered in rural and Lower Chute. This will mean the all these villages will become static and the younger generation areas has been based on historic delivery rates. The who have lived in the villages their whole lives will be forced to move outside of the villages, inevitably numbers provided serve as a minimum requirement for 2126 aging the population and loosing the vitality and viability of the smaller villages which are already Rural Housing areas, where there is a demonstrable need more housing struggling. Unless these smaller villages are given equal opportunity to grow and retain their this will be able to be built at smaller settlements outside demographics of their populations they will over the next 15 years and ongoing into the future. New the designated 'strategic’ settlements in each area. housing can provide smaller more affordable units for younger families which is very much needed in the smaller villages, where there is only availability of larger detached dwellings which are unaffordable for a great deal of the population. Also the infrastructure provided by new housing such as new play and sports facilities and highway facilities will be missed by the smaller villages which often need this injection of new facilities to keep the villages vibrant and dynamic. Cross ID Comments Officer Comments Issue Reference

Question 17 - Tidworth Community Area (Core Policy 17) In this policy and in the infrastructure section, there is no mention of the need to consider foul and surface water disposal and water cycle study. This, along with water supply needs to be identified as it is a possible constraint. We note that section 5.15.5 Noted A water cycle study looking at flood risk and surface makes reference to the potential redevelopment of brownfield sites. Equally we note that the related Water Cycle 2167 water is part of the infrastructure requirements and this policy (Core Policy 17) refers to significant potential development, namely Drummond Park Depot, near Study should be added to the list. Ludgershall. However section 5.15 and Core Policy 17 of this document fails to make specific reference to the consideration potential flood risk or surface water management, which we recommend should be included.

As Highways Authority, County Council is concerned about the development proposed for the Tidworth and Ludgershall area, and the potential impact of extra traffic and transport demand on Hampshire roads close to the Wiltshire border. Paragraph 5.5.17 outlines a number of transport improvements related to the A303 and public transport links, and proposals for better community facilities in Tamworth. However, it is considered that there could still be demand from planned new Noted. These comments will be passed to the highways development for travel to Andover, especially for higher goods/ services, and that this may have an team and a further assessment of the traffic situation in 2387 Highways impact on Hampshire roads. In particular, the County Council is concerned about the potential traffic Ludgershall will be included in the next round of the core impact on the A342, including through the settlement of Weyhill. HCC would welcome the opportunity to strategy. be engaged at the earliest opportunity as proposals come forward for the sites that are close to the border of Hampshire. The impact of these sites on the highways and transport network within Hampshire will need to be fully considered and assessed through a Transport Assessment (TA), with appropriate mitigation provided where an impact is expected.

As the A303 is located just south of the area, any future proposals will need significant consideration before planning consent is granted. We are encouraged that Tidworth/Ludgershall is not identified as a Noted. These comments will be passed to the highways location for new strategic employment growth and would encourage any employment proposals in the team and a further assessment of the traffic situation in 2471 town to contribute to self containment. We are pleased to note that where housing and employment Highways Ludgershall will be included in the next round of the core growth have been mentioned that one of the objectives is to reduce out commuting. The Agency strategy. acknowledges the intention to provide 12ha of employment land, the supporting of Principal Employment Areas and 1,900 dwellings in the community over the plan period (2006-2026).

We would like the following additional information considered as an issue that needs addressing: This Community Area comprises a number of Horseshoe roosts, for example, Stourhead National Trust. This 2717 SO5 Noted. Ecology Community Area also comprises the southern portion of the West Wiltshire Batscapes Area. Efforts should be made in this area to retain and enhance landscape habitat connectivity.

2907 Holding objection to the allocation in the community area strategy. Noted. Strategic Site

Question 17 Comment No. 149 Comment No. 1372 Comment No. 2113 Mr Andrew Lord Mrs Janet White Ms Lauren Taljaard Planning Advisor North Wessex Downs AONB Clerk Ludgershall Town Council Senior Planner Barton Willmore Comment No. 201 Comment No. 1525 Nick King Cllr Mark Connolly Susan Solbra Hills UK Ltd Comment No. 980 Southern Water Comment No. 2126 Unknown Comment No. 1654 Anna Hebard Comment No. 1002 Denis Bottomley Comment No. 2167 Jan Donovan Comment No. 1820 Miss Katherine Burt Planning Liaison Technical Specialist Environment Agency Rolfe Judd Phil Hardwick (Wessex Area) Unknown Robert Hitchens Ltd Comment No. 2387 Zog Brownfield Ventures Ltd Comment No. 2008 Mr Toby Ayling Principal Planning Officer Comment No. 1032 Ellen O'Grady Hampshire County Council Ms Jenny Hawley Defence Estates Comment No. 2471 Environmental Intelligence Officer Wiltshire Wildlife Trust Comment No. 2073 Ms Meghann Downing Comment No. 1103 Mr David Wildman Asset Manager Highways Agency Charles Routh SWEP Comment No. 2717 Planning and Local Government Natural Gareth Harris Wiltshire Bat Group Comment No.2907 Georgia Developments (Wessex) Ltd Nigel Whitehead WPB Development Planning