Submitted on Behalf of the Residents of Derry Hill and Studley. Objecting Against the Inclusion of Sites Within the Wiltshire and Swindon Minerals Site Options Report

Submitted on behalf of the residents of Derry Hill and Studley. Objecting against the inclusion of sites within the Wiltshire and Swindon Minerals Site Options Report.

Chapter 3 The Calne Mineral Resource Zone: The Calne Area 4 & The Calne Area 5.

C12: Land East of Studley C13: Land South of Studley A C14: Land South of Studley B C15: Land North of Pitters Farm

At the time of writing site proposals C12, C13 & C14 had been withdrawn by the land owner. The objective evidence for exclusion of each site remains within this report allowing for future reference. It is formally requested that this information is archived on the County records for future reference. This report reflects the information gained to date and the right to submit further information is retained.

This report is submitted to cover all sites, but written to allow individual sites to be filed independently

October 2010

Contact: Mrs Alison Maddicks Sandy Lands Old Road Studley Calne Wiltshire SN11 9NF

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Contents Executive Summary 4 Site C12 5 Loss of Agricultural Land Biodiversity & Geodiversity Historic Environment & Cultural Heritage 6 Historic Use Archaeology 7 Listed and Domestic Buildings Human Health & Amenity 8 Landscape, Townscape & Visual 9 Policy NE15 Special Landscape Area (SLA) 10 Economy Traffic & Transportation Site C13 12 Loss of Agricultural Land Biodiversity & Geodiversity Historic Environment & Cultural Heritage 13 Historic Use Archaeology Listed and Domestic Buildings 14 Human Health & Amenity 16 Landscape, Townscape & Visual 17 Policy NE15 18 Special Landscape Area (SLA) 19 Policy HE3 Economy 20 Traffic & Transportation Site C14 21 Loss of Agricultural Land Biodiversity & Geodiversity Historic Environment & Cultural Heritage 22 Historic Use Archaeology Listed and Domestic Buildings Human Health & Amenity 23 Landscape, Townscape & Visual 24 Policy NE15 Special Landscape Area (SLA) 25 Economy Traffic & Transportation

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Site C15 26 Loss of Agricultural Land Biodiversity & Geodiversity Historic Environment & Cultural Heritage 29 Historic Use 30 Archaeology

Listed and Domestic Buildings 31 Landscape, Townscape & Visual 32 Policy NE15 36 Special Landscape Area (SLA) Policy HE3 37 Economy Traffic & Transportation 38 Water Environment 40 Appendix 1 41 Listed Buildings in the areas of C12, C13, C14, & C15 Appendix 2 43 Details of archaeological artefacts in the CALNE CALUNA area Appendix 3 47 Location of Historical Finds Appendix 4 49 Mr D Clark’s Nature Survey, October 2010

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Executive Summary

The majority of residents of Derry Hill and Studley, within the Parish of Calne Without, are opposed to the utilisation of sites C12, C13, C14 and C15 for sand extraction. They have expressed this opinion with the numerous comments on the consultation portal and in attending the public meeting on the 4 th October 2010. This report seeks to summaries the numerous social, economic, environmental and cultural reasons why sand extraction is not acceptable at these sites. It is the opinion of the Derry Hill and Studley Preservation Group, a group formed to co- ordinate a response to the Mineral Site Options Report. This opinion is supported locally and is summarised in the following quote:

“The fact of the matter is that people simply do not want sand and gravel extraction anywhere near their homes. They don’t want the dust and the noise, they don’t want the hundreds of HGVs which would be necessary; they don’t want either the rubbish or indeed the water which would follow; they don’t want the rural landscape transformed. And it is only right and proper that they should say so, say so forcefully and continually, and by that means seek to preserve the beauty and the peace and the quite of their rural environment” James Gray MP (October 2010).

The main areas of objection are loss of valuable agricultural land, loss of biodiversity and geodiversity, the unacceptable adverse impact on the historic environment, the loss of cultural heritage, the unacceptable adverse impact on the resident’s health and amenity, the economical impact, the effect of additional HGVs and the negative impact on the local water environment.

Individually the issues raised are of considerable concern and are likely to be a serious impediment to the development of the sites for mineral purposes. Taken together, they present a wide range of material factors which are likely to create insuperable difficulties for the site's development. As such, these issues provide a clear justification for the Council to remove C15 from its list of potential sites within the DPD and to ensure that C12, C13 and C14 are not allowed to be considered in the future. We request that this is acted upon immediately.

Alison Maddicks Studley Co-Ordinator Matthew Maddicks Studley Parish Councillor John Baumber Studley Archaeologist John Wyatt Studley Janet Robins Studley Duane Clark Derry Hill Amateur Naturalist Andrew Pass Derry Hill Andrew Purvey Studley Water Engineer

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Site C12 Land East of Studley (1,420,000 tonnes soft sand)

The land East of Studley is an agricultural field, currently supporting a crop of maize, situated north of the A4. This field boarders the residential area of Norley Lane. It is sloped in nature facing easterly and is therefore visible from the settlement of Calne. The site falls within the Special Landscape Area “The higher land of the Spye and Bowood Parklands” and is in close proximity to the Grade One, Bowood Historic House and Gardens.

Loss of Agricultural Land

The adoption of the site East of Studley to supply soft sand would result in the loss of 14.8 hectares of grade 3 (best and most versatile) agricultural land. Minerals Policy Statement 1 (MPS1) requires the selection of poorer quality land and (Minerals Policy Statement 2) MPS2 requires that the best and most versatile agricultural land is safeguarded for future use. The exploitation of this land for mineral extraction would directly contradict this requirement. On a more strategic level, it also fails to apply Food 2030 (HM Government 2010) which emphasises the importance of UK food security, and states ‘we want UK agriculture to produce as much food as possible'.

Biodiversity & Geodiversity

C12 borders ancient woodland. The site also borders Crab Tree Copse County Wildlife Site (CWS). We note with interest that Dr Gary Mantle MBE – Wiltshire Wildlife Trust (October 2010) writes:

“The site has the potential to cause the greatest ecological damage and it is requested that the site is excluded from further consideration”

C12 – Is adjacent to Crab Tree Copse County Wildlife Site

Duane Clark (Local Amateur Naturalist) has completed an initial assessment of the areas adjacent to the land (the site itself is in private ownership). He notes that C12 is an open arable field that is adjacent to ancient woodlands. Mr Clark has had a relatively small amount of time to compile a list of the wildlife affected by the changes made by the extraction of minerals from this area. He has expressed concern that there are many vulnerable species that would be adversely affected by the change of use of the land and that this could result in the extinction of these local groups of species.

“It is fair to say that most of the wildlife in these areas will spend the majority of their time sheltering in the woods, verges and hedges and will use the open fields as forage, mainly feeding on the insect life and sometimes each other especially whilst the fields are supporting a valuable crop such as maize. The fields in turn, when laid fallow, support the wide variation of insects, whilst the woods, verges and hedges are described as wildlife corridors. If these sites are quarried you will take away the foraging areas rendering the wildlife corridors redundant and the species that can move away will”.

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“There is a secondary issue that doesn’t just affect the wildlife that uses the hedgerows as shelter and the open field as foraging grounds but the loss of the verges, hedges and trees to allow the access to these sites. It has been discussed that for the large vehicles to access and egress these sites large swathes of land for several hundred metres each side will have to be cut down and then, as seen regularly from the Wickwar quarry in the Wotton-under-Edge area, the verges and bushes along the roads will be full of sand. In many visits I have made to this area I see less evidence of wildlife, when compared to hedgerows around C12, in the verges such as berry bearing plants exhibiting visible evidence of small animals feeding on them, bite marks and dropping etc”.

“The restoration may not include every species and will present its own issues as re-introduced species can suffer some horrible issues such as shallow gene pools. When change of use results in the introduction of a new species, there is a whole new issue of compatibility with the remaining species”.

“It is not just the animal species that will suffer, the proposed works will undoubtedly alter the natural water supply to the whole area as removing the permeable layer from above the aquifer will not only reduce the amount of filtering and time taken for the rain water to reach the aquifer, it will alter the properties of the water such as mineral content and possibly even the amount and direction of the water flow itself. If this were to happen there will be a change to the surrounding areas affecting the remaining trees and farmland that will surround the quarry/landfill sites. We could see wetlands drying up altogether or just flooding out”.

The Coach House is also a registered roosting site for the Greater Horseshoe Bats, and the prime feeding grounds for these protected species are the C13 field C12 and immediate properties. The bats are particularly active in the autumn and no building work is allowed between the months of April & October. This would impact on the viability of quarrying in the adjacent sites for at least 50% of the year.

Historic Environment & Cultural Heritage

Historic Use

This zone is prime agricultural land, and has been for over 100 years and is shown as such on Ordnance Survey maps (1” Series dated 1896 and 1924 and before), and clearly has been used for market garden and agriculture over this time to the present day. This land has provided significant yields of crops for the human food chain.

The continued use of this site for agriculture is marked by unchanging field boundaries over the last two millennia with the Romano British dry stone wall boundaries made from stone recovered from adjacent areas known as the “Quarr” (a spelling error from early maps where the letter y was omitted). These walls, in some instances, have been erected to retain soil and prevent subsoil movements. This agricultural use is further identified by the surrounding farm and related dwelling houses. The historic ability to support agriculture is due to the unique

28th October 2010 Derry Hill and Studley Preservation Group Page 6 of 58 geology ( a large aquifer under C12) and soils combined with spring waters rising in the upper elevations of the landscape from Pewsham, across Derry Hill, Black Dog Hill and Chilvester Hill and the associated aquifers providing irrigation but with an excellent draining subsoil geological structure.

This agricultural land forms part of the surrounding landscape setting that needs to be kept for the setting of the listed and historic buildings bordering C12 and cannot be lost to mineral extraction. (ref: Planning Policy Statement 5 (PPS5), HE10.)

Furthermore, development of this landscape would contravene PPS5 HE11 as it would “materially harm the significance of the heritage asset(s) or its (their) setting”.

Archaeology

Whilst C12 has not been subject to an in depth archaeological review, it is a source of Scheduled Monument Records (SMR’s) and is adjacent to recorded Roman finds in the fields immediately to the south-east which are also linked to the SMR recorded Iron Age fort and Roman site at Berhills. The landscape being bounded by the River Marden (fed by the aquifer) to the North West indicates the whole area was populated during the Romano British period and was an ideal agricultural and dwelling location.

In particular, SMR ST97SE303 relates to Five Romano British coins and stretches of dry stone walling of the same period in C12 towards the Norley Lane boundary to the south west.

To the west of C12 lies SMR ST97SE302 which is a Roman Villa site with the remains of baths with under floor heating discovered in 1753.

All these scheduled monuments would be at risk and C12 is therefore an “inappropriate” development under PPS5. See appendix 2

Listed and Domestic Buildings

C12 is bounded by domestic dwellings some of which are of historic importance and are also listed.

To the south west (Norley Lane) the buildings include agricultural workers dwellings and examples of the first steel framed and concrete structures developed in the mid 20th century for social housing (now in private ownership), these maintain a link with the agricultural community of which C12 is part.

To the south of the site across the A4 main road boundary there are two listed buildings within 20 meters: The Lodge and entrance railings (Grade II) and Rumsey House (Grade II). Such development so close would detract enormously from the landscape and amenity of these protected buildings. In addition there is a protected milestone on the boundary of C12 on the verge of the A4.

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To the east, there is Rumsey Farm (Grade II listed) of which the north east boundary wall is indicated of being of historic importance (both as a field boundary marker and as a structure). The removal of sand from the adjacent C12 and the changes in the water table have severe structural implications as the changes to the water table could allow substructure movement affecting the stability of this important property.

Any industrial activity of this nature would therefore contravene PPS5 (HE7.1) and this implies that the Planning Authority also needs to recognise the potential requirements of HE6.3.

Listed Buildings locations related to C12, C13, & C14

Human Health & Amenity

C12 is surrounded on three sides by 33 residential properties. MPS2 requires that the adverse impact of mineral extraction on neighbouring communities is minimised. It is impossible to see how this can be achieved when the site is residential in nature. Where mitigation is insufficient to safeguard local residents from the environmental effects of mineral extraction, refusal to progress a site is recommended.

The environmental effects will include dust, noise and light pollution affecting the quality of life of residents. The vibration will result in damage to properties and the transportation of sand and infill will increase noise pollution, chemical pollution and vibration from traffic. These impacts will all be to the detriment of the physical and mental well-being of the inhabitants of the villages of Studley and Derry Hill. Many of the inhabitants of these properties are the elderly or the young who are especially vulnerable to the effects of air-bourne pollutants. It is also likely that mineral extraction in such close proximity to property will adversely impact the structural integrity of a large majority of these buildings.

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The landowner of C12 removed the land from the consultation as a result of public pressure stating:

“…it is now clear that certain sites should never have been considered, being contrary to the Council’s criteria: “1.25 Quality of Life.” “A number of areas of land put forward for consideration are located in close proximity to residential, workplace or recreational areas”. This implies they are not suitable for further consideration. Consequently, the Estate has requested that areas C12, 13 and 14 are removed from the register”. (Marquis of Lansdowne, October 2010).

The proximity of residential properties alone is a significant enough factor to warrant the removal of this site from the consultation.

Landscape, Townscape & Visual

The exploitation of C12 would have an inevitable massive visual impact on the wider area as well as the local area. The site is visible from the A4 and due to its sloping nature would be impossible to screen. Long distance views from areas such as Calne would also be impacted.

The Campaign to Protect Rural England (C.P.R.E) have highlighted their concerns (October 2010):

“The raft of sites (18) proposed which cover the Calne Area, fail to meet MCS1(B) under the criteria relating to environmentally valuable features, proximity to local communities, local landscape character (See North Wiltshire Landscape Character Document) and proximity to HGV route network (small, vulnerable and very rural roads have to be used as feeders to reach the HGV routes).”

Policy NE15 (Adopted North Wiltshire Local Plan 2011 –The Landscape Character of the Countryside)

Site C12 falls within the North Wiltshire (saved) policy of NE15. This stipulates that the landscape of North Wiltshire and its locally distinctive characteristics shall be conserved and enhanced, development will be permitted if it does not adversely affect the character of an area and features that contribute to local distinctiveness.

“Development shall take into account:

iii) The special qualities of watercourses and waterbodies and their surroundings such as river valleys. iv) The topography of the area avoiding sensitive skylines, hills and not detracting from important views. The best and most versatile agricultural land shall be protected from non- agricultural development.

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6.40 The landscape shall be safeguarded for its own sake and in order to protect its intrinsic character and beauty. The authority shall find ways of enriching the quality of the whole countryside while accommodating appropriate development.

6.41 A landscape character assessment has been prepared for the district which defines 17 character areas. Each area is described in terms of its character, key characteristics, management guidelines and actions, and landscape sensitivity”.

Special Landscape Area (SLA)

Site C12 falls within the “The higher land of the Spye and Bowood Parklands” as designated in the Wiltshire and Swindon Structure Plan 2016. Appendix 4 of the Structure Plan stipulates that “any proposals for development should have regard to the need to protect landscape character and scenic quality.” This designation is as a result of the North Wiltshire Landscape Character assessment (June 2004). This assessment highlights that the views from the A4 are important to the perception of the area. It also states that the “overall objective for the area is to preserve and enhance the parkland and woodland character and retain the essentially rural character of the area”.

Minerals Policy Statement 1 (MPS1) requires that mineral extraction on such a site would require ‘careful consideration’. It is impossible to see how any careful planning and design could protect the surrounding rural area when a site is in a highly visible special landscape area and consists of best and most versatile agricultural land, which should be protected.

Economy

The utilisation for this land for the extraction of minerals would have a significant negative impact on the local economy. Many locals are understandably concerned about the impact on the saleability and therefore price of their properties. Whilst this itself is not a planning consideration the wider impact of negative equity and decline of a popular residential location should be a concern of the council.

This initiative will not make Derry Hill and Studley more sustainable, quite the opposite.

The A4 is a tourist route and tourism is a major income for the area. The operation of a quarry would be completely out of place and would detract from the visual beauty. Add to this the congestion from the Heavy Goods Vehicles (HGVs) and the negative impact on road safety and the perception of the area will drop and the tourist income will decline. This will affect many individuals and businesses, including public houses such as the Soho and Bowood house and gardens.

Traffic & Transportation

28th October 2010 Derry Hill and Studley Preservation Group Page 10 of 58 primary HGV route. The nearest primary HGV route is the A4 west of Chippenham, as designated in the Wiltshire and Swindon Structure Plan (2016).

The adoption of the site as a quarry would therefore necessitate the use of HGV’s. This would present two major issues; firstly their entry and exit onto the site and secondly their presence on the rural roads. The operation of the quarry would result in numerous daily lorry movements. These lorries would require safe entry and exit to the site. It is impossible to identify how this could be achieved on a fast, unsafe section of road that undulates and turns. The physical nature of the road is such that visibility splays would be insufficient and traffic would have to join the A4 on a slope. The road itself is known as an accident black-spot and has had numerous accidents and a fatality in the last three years. Numerous comments on the consultation portal refer to the very real concerns of residents that the addition of HGVs will result in an increase in accidents in an already unsafe area.

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Site C13 Land South of Studley (A) (1,475,00tonnes soft sand)

The land South of Studley (A) is an agricultural field, currently supporting a crop of maize, situated south of the A4. The field borders the residential area of Old Road in addition to the residential cluster of Rumsey House. The site is adjacent to the southern border of the village of Studley and the site itself contains First Derry Hill’s scout hut. The site falls within the Special Landscape Area “The higher land of the Spye and Bowood Parklands” and is within 1 km of the Grade One, Bowood Historic House and Gardens. The site itself also forms part of the historic gardens designed by Lancelot “Capability” Brown.

Loss of Agricultural Land

The adoption of the site South of Studley (A) to supply soft sand would result in the loss of 15.4 hectars of grade 3 (best and most versatile) agricultural land. Minerals Policy Statement 1 (MPS1) requires the selection of poorer quality land and Minerals Policy Statement 2 (MPS2) requires that the best and most versatile agricultural land is safeguarded for future use. The exploitation of this land for mineral extraction would directly contradict this requirement. On a more strategic level this also contradicts Food 2030 (HM Government 2010) which emphasises the importance of UK food security, and states ‘we want UK agriculture to produce as much food as possible'.

Biodiversity & Geodiversity

Duane Clark (Local Amateur Naturalist) has completed an initial assessment of the areas adjacent to the land (the site itself is in private ownership). He notes that C13 is an open arable field that is adjacent to woodlands. Mr Clark has had a relatively small amount of time to compile a list of the wildlife affected by the changes made by the extraction of minerals from this area. He has expressed concern that there are many vulnerable species that would be adversely affected by the change of use of the land and that this could result in the extinction of these local groups of species.

28th October 2010 Derry Hill and Studley Preservation Group Page 12 of 58 bushes along the roads will be full of sand. In many visits I have made to this area I see less evidence of wildlife, when compared to hedgerows around C13, in the verges such as berry bearing plants exhibiting visible evidence of small animals feeding on them, bite marks and dropping etc”.

Historic Environment & Cultural Heritage

Historic Use

This zone is prime agricultural land and is part of the Bowood House grounds landscaped by Lancelot “Capability” Brown in the 1760s, when over 2,000 acres (8km²) of the parkland were developed into “gardens, avenues and wilderness”. This site is therefore part of the grade one listed gardens.

Whilst C13 is described in the Minerals document as woodland, it has been in agricultural use for at least 150 years and is shown as such on Ordnance Survey maps (1” Series dated 1896 and later in 1924 and historic maps, believed to be in the Bowood House archives). It continues as a valuable feedstock crop site to the present day. It is therefore incorrectly denoted in the proposals as woodland.

Recently, Romano British occupation has been identified indicating military, agricultural and domestic/industrial activity on this site with a small fort and associated villa (see below).

Archaeology C13 contains a recently identified Roman “fortlet” and associated living space/villa and industrial activity. The surface finds are currently a discussion point between the Bowood Estate and the ‘County Finds Officer, Ms K Hines. This site aligns

28th October 2010 Derry Hill and Studley Preservation Group Page 13 of 58 with others that run across the Bowood Estate to the South, and to the North, line up with the recently identified possible Roman Fort site in Foxham. These are very significant in relationship to Verlucio, a Roman settlement to the South about 1.25km to the South East of Sandy Lane. There is a well defined Roman Road linking Cunetio to Verlucio going on to Aquae Sulis (Bath), each one-day’s march apart. The identification of the Roman site in C13 could identify the very important “correct” routing of the Roman Road that runs from the South at Poole/Hengistbury through to the North and Cirencester.

Rag Lane (Old Road) forming the North boundary of C13 has evidence of a Roman road discovered circa 2007 at a shallow depth outside Rag Cottage (formerly known as Monument View), confirming that a substantial Romano British site within C13 required established road access.

Dr Ken Dark of Reading University and holder of various professorships confirms that “Verlucio is of National importance and there should be no action in this area that could impact on the site and the surrounding landscape” (see also C15 Pitters Farm and the recorded and identified site of Roman iron smelting which is believed to be linked with Verlucio).

Furthermore the Wiltshire County Archaeologist (Ms Melanie Pomeroy-Kellinger) has stated that this field “is a very important site with lots of evidence for Roman industrial activity as well as settlement”. Discussions with the landowner (Bowood Estates) and Ms Katie Hines, Wiltshire Council Archaeological Finds officer, have been ongoing for some time relating to the significant coin finds, other artefacts and known features in C13 Roman “fortlet” but the Bowood Estate has been reluctant to publicly acknowledge this. These coins are seen as very significant by Sam Moorhead of the British Museum indicating the very high Roman occupation stretching through the Bowood Estate from Verlucio to the Roman fort at Foxham.

Listed and Domestic Buildings

There are historic and listed buildings surrounding this site, with the south extremity bordering the Grade I listed Bowood House and Grade 1* Bowood Mausoleum sites. Significant large Grade 1 buildings and their surrounding landscape are usually protected (guideline 1 kilometre) from unnecessary industrial development. Quarrying is industrial development.

The southern boundary abuts Bassett’s Moor Coppice which is part of the Bowood Estate and is included within the significantly important Grade I property and “Capability” Brown’s Gardens with the Grade I* Mausoleum. It is understood that the boundary for the Grade I listed Bowood House and Gardens originally abutted the boundary with Rag Lane ( Old Road), therefore C13 falls within, rather than being adjacent to the protected “Capability Brown” landscape, and therefore cannot be subject to industrial exploitation. This is confirmed by Defence Estate Maps (2010) and as such it is considered to fall within the remit of the Grade 1 Listing restrictions curtilage and so no such extraction should be allowed on the associated landscape.

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To the eastern boundary there lies, immediately abutting C13, The Barn, The Coach House, The Granary and Rumsey House. The actual building structure of The Barn dates from 1823 and is typical of the Wiltshire grain and threshing farm buildings associated with cereal crop harvesting and is positioned such that winnowing can take advantage of the prevailing westerly autumn winds. As such it would be vulnerable to the dust and noise generated from any quarrying activity being only some 8 metres from the C13 boundary. This historic building does not have conventional foundations and so any mineral extraction and changes to the water table could cause severe ground movement and subsidence.

The Coach House is Grade II listed and The Granary (Grade II listed by curtilage of both The Coach House and Rumsey House) being only some 10 metres from the C13 eastern boundary means they would be also be affected by ingress of noise and dust. This has significance because there are limits or restrictions on double glazing, thus mitigation against noise and dust is not possible. C13 development as a quarry would not be in keeping with the preservation of the surrounding landscape of listed buildings.

Ground transmitted vibration on these early 19th century agricultural buildings could damage the properties as they do not have conventional foundations. Therefore it is difficult to forecast how the preservation of any of these historic and listed building properties would be prioritised as their potential for continued living accommodation would be severely compromised being so close to the dust, vibration and noise source. The Coach House, being attached to Rumsey House, has a higher sensitivity concerning water table changes than normal as shared support between the two buildings could be affected. Furthermore, the disturbance of the geology is likely to result in contamination of the spring sources and pollution of the agricultural irrigation systems. Wells within local properties currently show the water level is maintained at less than 2 metres from the surface.

To the west boundary, the Grade II Frog Hollow property has similar issues and records indicate that this property was one of the three blacksmith cottages in the area. The evidence of the recent finds in C13 could indicate that this was also the possible site of iron workings in Romano British, and even earlier times. In particular the records show SMR ST97SE309, for the site of Frog Hollow of a Romano British coin would give credence to this.

All the properties along Rag Lane (Old Road) would be affected by C13 development many of which built in an age when modern stable footings were not installed. The historic significance of these buildings relates to their use by 1 agricultural and local skills: Siwian Cottages relates to the skilled material “sewers” that worked fabric produced locally from the woollen mills; Rag Cottage (previously known as Monument view, now renamed after the road) alludes both to material reclamation activities from nearby woollen mills and also to some of the cottages being used by garment sewers. As industry changes impacted on the economics of the community some of these properties became known as “squatters” cottages. The continued use and value of these historic buildings should not be jeopardised.

1 Gothic Latin meaning To Sew

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To the North boundary is a series of cottages both on the south and north sides of the A4 arterial road. The properties to the north boundary of C13 whilst not listed provide evidence of local cottage styles across the centuries. The Soho Inn public house opposite the current entrance to C13 is a Grade II listed property and the aspect from the front of this property looks across the A4 directly onto the current C13 entrance gate and would lose substantial amenity and context of the roadside Inn.

As C13 is over an aquifer, these properties are very sensitive to any geological intrusion and any quarrying for sand in this area would result in the significant and irreparable movement of the water table which could lead to destabilising the historic and listed buildings that bounding C13. Any change to the water table could have immediate structural integrity inferences for them and put at risk their continuing presence in an appropriate historic context.

Listed Buildings locations related to C12, C13, & C14

Human Health & Amenity

C13 is surrounded on three sides by 40 residential properties. MPS2 requires that the adverse impact of mineral extraction on neighbouring communities is minimised. It is impossible to see how this can be achieved when the site is residential in nature. Where mitigation is insufficient to safeguard local residents from the environmental effects of mineral extraction refusal to progress a site is recommended.

28th October 2010 Derry Hill and Studley Preservation Group Page 16 of 58 inhabitants of these properties are the elderly or the young who are especially vulnerable to the effects of air-bourne pollutants. It is also likely that mineral extraction in such close proximity to property will adversely impact the structural integrity of a large majority of these buildings.

The landowner of C13 removed the land from the consultation as a result of public pressure stating:

The proximity of residential properties alone is a significant enough factor to warrant the removal of this site from the consultation.

Landscape, Townscape & Visual

The exploitation of C13 would have an inevitable massive visual impact on the wider area as well as the local area. The site would be visible from the A4 following the removal of the tree line to give the necessary visibility to enter and exit the site. The site would also be visible from the residential properties of Old Road and the residential cluster around Rumsey House.

View 1- from Sandy Lands looking East along C13

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Compton Bassett Windmill Hill

The Barn

Rumsey House The Granary

View 1 - expanded showing far reaching views of Windmill hill, Compton Bassett Taking note of the listed Rumsey House complex

The Campaign to Protect Rural England (C.P.R.E) have highlighted their concerns (October 2010):

Policy NE15 (Adopted North Wiltshire Local Plan 2011 –The Landscape Character of the Countryside)

Site C13 falls within the North Wiltshire (saved) policy of NE15. This stipulates that the landscape of North Wiltshire and its locally distinctive characteristics shall be conserved and enhanced, development will be permitted if it does not adversely affect the character of an area and features that contribute to local distinctiveness.

“Development shall take into account:

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Special Landscape Area (SLA)

Site C13 falls within the “The higher land of the Spye and Bowood Parklands” as designated in the Wiltshire and Swindon Structure Plan 2016. Appendix 4 of the Structure Plan stipulates that “any proposals for development should have regard to the need to protect landscape character and scenic quality.” This designation is as a result of the North Wiltshire Landscape Character assessment (June 2004). This assessment highlights that the views from the A4 are important to the perception of the area. The views from and to the site are long ranging and therefore the impact of extraction from this site would affect a large area. The assessment also states that the “overall objective for the area is to preserve and enhance the parkland and woodland character and retain the essentially rural character of the area”

Policy HE3 (Adopted North Wiltshire Local Plan 2011 -7. Historic Environment Topic Area)

Site C13 is adjacent to Bowood Historic House and Gardens and as such is subject to HE3. This policy stipulates that “New development and advertisements within or adjacent to Historic Parks and Gardens which do not respect their character, appearance or setting, will not be permitted”. The Wiltshire and Swindon Structure Plan clarifies this further stating that the settings of historic parks” should be protected from inappropriate development, having regard for the scale and location of any development proposals and their impact on the character and features of historic importance of these sites”.

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Economy

This initiative will not make Derry Hill and Studley more sustainable, quite the opposite.

Traffic & Transportation

MPS1 requires the promotion of sustainable transportation for extracted minerals. C13 is located in a rural area away from rail, sea or inland waterway connections. As such the extracted mineral and returning landfill would be required to be transported solely by road. The A4 is a local HGV route and does not constitute a primary HGV route. The nearest primary HGV route is the A4 west of Chippenham, as designated in the Wiltshire and Swindon Structure Plan (2016).

The adoption of the site as a quarry would therefore necessitate the use of HGV’s. This would present two major issues; firstly their entry and exit onto the site and secondly their presence on the rural roads. The operation of the quarry would result in numerous daily lorry movements. These lorries would require safe entry and exit to the site. It is impossible to identify how this could be achieved on a fast, unsafe section of road that undulates and turns. The location and design of the site entrance would also need to account for the junction interplay with the junction of Old Road and the junctions of the Soho public house, Bowood Sports Ground and K4 kitchens. The physical nature of the road is such that visibility splays would be insufficient and traffic would have to join the A4 at the crest of a hill. The road itself is known as an accident black-spot and has had numerous accidents and a fatality in the last three years. Numerous comments on the consultation portal refer to the very real concerns of residents that the addition of HGVs will result in an increase in accidents in an already unsafe area.

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Site C14 Land South of Studley (B) (470,000 tonnes soft sand)

The land South of Studley (B) is a small agricultural field, currently supporting a crop of maize, situated north of the A4. The field borders the residential areas of Old Road, Stanely Lane and the A4. The site is within the village of Studley and adjacent to the A4. Excavation would be highly visible within the village and along the A4 itself. The site falls within the Special Landscape Area “The higher land of the Spye and Bowood Parklands” and is in close proximity to the Grade One, Bowood Historic House and Gardens.

Loss of Agricultural Land

The adoption of the site South of Studley (B) to supply soft sand would result in the loss of 4.9 hectares of grade 3 (best and most versatile) agricultural land. MPS1 requires the selection of poorer quality land and MPS2 requires that the best and most versatile agricultural land is safeguarded for future use. The exploitation of this land for mineral extraction would directly contradict this requirement. On a more strategic level this also contradicts Food 2030 (HM Government 2010) which emphasises the importance of UK food security, and states ‘we want UK agriculture to produce as much food as possible'.

Biodiversity & Geodiversity

Duane Clark (Local Amateur Naturalist) has completed an initial assessment of the areas adjacent to the land (the site itself is in private ownership). He notes that C14 is an open arable field. Mr Clark has had a relatively small amount of time to compile a list of the wildlife affected by the changes made by the extraction of minerals from this area. He has expressed concern that there are many vulnerable species that would be adversely affected by the change of use of the land and that this could result in the extinction of these local groups of species.

28th October 2010 Derry Hill and Studley Preservation Group Page 21 of 58 verges such as berry bearing plants exhibiting visible evidence of small animals feeding on them, bite marks and dropping etc”.

Mr Clark has made notes with regards to the species he has observed or acquired evidence of in his informal survey. This is documented as Appendix Three. The extent of the BAP priority species is evident and gives weight to the need for the requirement for extensive and costly surveys to comply with legal requirements if the use of this land is to be changed.

Historic Environment & Cultural Heritage

Historic Use

This zone is primarily an extension of C13 regarding agricultural land use (see C13) and has been used for either agriculture or horticulture for 150 years. It continues as a valuable feedstock crop site to the present day.

Archaeology

C14 contains evidence of Romano British activity and these are believed to be related to known features in the adjacent C13 site Roman “fortlet” and associated finds (K Hines, County Finds Officer).

Listed and Domestic Buildings

The southern boundary is completely embraced by the buildings in Rag Lane (Old Road) directly abutting their boundaries. All these properties would be affected by C13 and C14 development, many of which being built in an age when modern stable footings were not engaged. The historic significance of these buildings relates to their use by agricultural and local skills. Any activity that causes disturbance to the water table and thus jeopardise their structural footings should not be considered. These properties directly abut the quarry site.

It is difficult to forecast how the preservation of these properties (including the Grade II listed Frog Hollow and Grade II listed Soho Inn) would be maintained as

28th October 2010 Derry Hill and Studley Preservation Group Page 22 of 58 their potential for continued living accommodation would be drastically affected and the potential loss of those properties having historic links to the community (referred to as both “squatters”, “weavers” and “smithy” cottages) due to quarrying, is not in line with preservation of historic landscapes (Planning Policy Statement 5 (PPS5) HE3.4).

Human Health & Amenity

C14 is surrounded on three sides by 46 residential properties. Minerals Policy Statement 2 (MPS2) requires that the adverse impact of mineral extraction on neighbouring communities is minimised. It is impossible to see how this can be achieved when the site is residential in nature. Where mitigation is insufficient to safeguard local residents from the environmental effects of mineral extraction refusal to progress a site is recommended.

The environmental effects will include dust, noise and light pollution affecting the quality of life of residents. The vibration will result in damage to properties and the transportation of sand and infill will increase noise pollution and vibration from traffic. These impacts will all be to the detriment of the physical and mental well- being of the inhabitants of the villages of Studley and Derry Hill. Many of the inhabitants of these properties are the elderly or the young who are especially vulnerable to the effects of air-bourne pollutants. It is also likely that mineral extraction in such close proximity to property will adversely impact the structural integrity of a large majority of these buildings.

The landowner of C14 removed the land from the consultation as a result of public pressure stating:

The proximity of residential properties alone is a significant enough factor to warrant the removal of this site from the consultation.

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Landscape, Townscape & Visual

The exploitation of C14 would have an inevitable massive visual impact on the wider area as well as the local area. The site will be visible from the A4 following the removal of the tree line, which will be necessary for the safe entry and exit of vehicles.

The Campaign to Protect Rural England (C.P.R.E) have highlighted their concerns (October):

Policy NE15 (Adopted North Wiltshire Local Plan 2011 –The Landscape Character of the Countryside)

Site C14 falls within the North Wiltshire (saved) policy of NE15. This stipulates that the landscape of North Wiltshire and its locally distinctive characteristics shall be conserved and enhanced, development will be permitted if it does not adversely affect the character of an area and features that contribute to local distinctiveness.

“Development shall take into account:

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Special Landscape Area (SLA)

Site C14 falls within the “The higher land of the Spye and Bowood Parklands” as designated in the Wiltshire and Swindon Structure Plan 2016. Appendix 4 of the Structure Plan stipulates that “any proposals for development should have regard to the need to protect landscape character and scenic quality.” This designation is as a result of the North Wiltshire Landscape Character assessment (June 2004). This assessment highlights that the views from the A4 are important to the perception of the area. It also states that the “overall objective for the area is to preserve and enhance the parkland and woodland character and retain the essentially rural character of the area”.

Economy

This initiative will not make Derry Hill and Studley more sustainable, quite the opposite.

The A4 is a tourist route and tourism is a major income for the area. The operation of a quarry would be completely out of place and would detract from the visual beauty. Add to this the congestion from the heavy goods vehicles (HGVs) and the negative impact on road safety and the perception of the area will drop and the tourist income will decline. This will affect many individuals and businesses, including public houses such as the Soho and Bowood house and gardens.

Traffic & Transportation

MPS1 requires the promotion of sustainable transportation for extracted minerals. C12 is located in a rural area away from rail, sea or inland waterway connections. As such the extracted mineral and returning landfill would be required to be transported solely by road. The A4 is a local HGV route and does not constitute a primary HGV route. The nearest primary HGV route is the A4 west of Chippenham, as designated in the Wiltshire and Swindon Structure Plan (2016).

28th October 2010 Derry Hill and Studley Preservation Group Page 25 of 58 unsafe section of road that is very close to a major junction (Studley Crossroads). The physical nature of the road is such that visibility splays would be insufficient even if the entire site tree-line was removed. The road itself is known as an accident black-spot and has had numerous accidents and a fatality in the last three years. Numerous comments on the consultation portal refer to the very real concerns of residents that the addition of HGVs will result in an increase in accidents in an already unsafe area.

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Site C15 Land North of Pitters Farm (3,000,000 tonnes soft sand)

The land North of Pitters Farm is a large agricultural field, currently supporting a crop of maize, situated West of the A342. The field runs adjacent to the A342 and is clearly visible from this route. It is sloped in nature and forms part of an important skyline visible locally and from the town of Chippenham. The site falls within the Special Landscape Area “The higher land of the Spye and Bowood Parklands” and is in close proximity to the Grade One, Bowood Historic House and Gardens. The site falls within 1km of the grade one listed mausoleum.

Loss of Agricultural Land

The adoption of the site North of Pitter’s Farm to supply soft sand would result in the loss of 42.1 hectares of grade 3 (best and most versatile) agricultural land. Minerals Policy Statement 1 (MPS1) requires the selection of poorer quality land and Minerals Policy Statement 2 (MPS2) requires that the best and most versatile agricultural land is safeguarded for future use. The exploitation of this land for mineral extraction would directly contradict this requirement. On a more strategic level, it also fails to apply Food 2030 (HM Government 2010) which emphasises the importance of UK food security, and states ‘we want UK agriculture to produce as much food as possible'.

Biodiversity & Geodiversity

C15 boarders Pitters Farm which has the potential to be a designated site of scientific or special scientific interest (SSI). It is also understood that it is possible that the site itself could receive such a designation. Following such designation this would require special additional consideration under MPS1. The site borders Raspberry Copse County Wildlife Site (CWS). We note with interest that Dr Gary Mantle MBE – Wiltshire Wildlife Trust writes (October 2010):

“The site has the potential to cause the greatest ecological damage and it is requested that the site is excluded from further consideration”

C15 – Is adjacent to Raspberry Copse County Wildlife Site (CWS)

Duane Clark (Local Amateur Naturalist) has completed an initial assessment of the areas adjacent to the land (the site itself is in private ownership). He notes that C15 is an open arable field that is adjacent to ancient woodlands and boggy wetland areas such as Spye Park SSSI (Site of Special Scientific Interest) and the lower ends of Pitters Farm. Mr Clark has had a relatively small amount of time to compile a list of the wildlife affected by the changes made by the extraction of minerals from this area. He has expressed concern that there are many vulnerable species that would be adversely affected by the change of use of the land and that this could result in the extinction of these local groups of species.

28th October 2010 Derry Hill and Studley Preservation Group Page 27 of 58 whilst the fields are supporting a valuable crop such as maize. The fields in turn, when laid fallow, support the wide variation of insects, whilst the woods, verges and hedges are described as wildlife corridors. If these sites are quarried you will take away the foraging areas rendering the wildlife corridors redundant and the species that can move away will”.

“There is a secondary issue that doesn’t just affect the wildlife that uses the hedgerows as shelter and the open field as foraging grounds but the loss of the verges, hedges and trees to allow the access to these sites. It has been discussed that for the large vehicles to access and egress these sites large swathes of land for several hundred metres each side will have to be cut down and then, as seen regularly from the Wickwar quarry in the Wotton-under-Edge area, the verges and bushes along the roads will be full of sand. In many visits I have made to this area I see less evidence of wildlife, when compared to hedgerows around C15, in the verges such as berry bearing plants exhibiting visible evidence of small animals feeding on them, bite marks and dropping etc”.

”4.13.2 How to quantify vulnerability A classical way to illustrate the lateral distribution of aquifer vulnerability is to use a set of maps showing, e.g., depth to groundwater table, clay content, cation exchange capacity (RIVM 1987,for the Netherlands) or depth to groundwater table and thickness of near surface clayey layers (LANU 2003, for Schleswig-Holstein). However, for practical use, the quantification of vulnerability by a single parameter would be preferred. One approach for vulnerability quantification is the AVI Aquifer Vulnerability Index (Van Stempvoort et al. 1992): This method quantifies vulnerability by hydraulic resistance to vertical flow of water through the protective layers.”

Quoted from a paper from REINHARD KIRSCH & KLAUS HINSBY

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Illustration of the strata required to construct an aquifer

Historic Environment & Cultural Heritage

GENERAL COMMENTS RELATING TO ALL 4 SITES:

At the commencement of the Mineral Sites Options programme issues concerning archaeological and historic buildings, their settings and landscapes would have been guided by Planning Policy Guidance PPG15 1994 – Planning & the Historic Environment & PPG16 1990– Archaeology & Planning , which covered in detail the considerations and actions that should be followed to assess the impact of any proposals. In March 2010 these were replaced by a single, simpler document, Planning Policy Statement PPS5 Planning for the Historic Environment 2010 , in which all the essential elements of ’15 &16’ were retained and greater clarity and simplicity given to focussing on the policy without the detailed guideline examples which are now subject to a supporting document, Historic Environment Planning Practice Guide 2010 . It is these documents, together with all the current legislation and requirements concerning listed buildings, historic buildings, scheduled monuments, archaeology, planning constraints and building regulations that form the basis of the points made concerning the impact of the identified sites on the surrounding archaeology, history and related landscape. The details can be confirmed in most instances by the County Archaeology Officers.

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Historic use:

This zone is mixed agricultural land, and has been for many centuries. This and the surrounding land has been in farmed agriculture since at least the 12 th Century (the land surrounding Locks Well and the abbey held several hides of land some in demesne – land retained by a Lord for his own use ) providing human as well as animal feedstuffs. There are significant SMRs on or near C15 evidencing the Romano British occupation and medieval occupation of the land.

The continuance of this landscape in its historic context is a requirement within the Planning Policy Statement 5 (PPS5) and should not be lost to mineral extraction. C15 contains important archaeological features and as such should be protected by HE5, which stipulates that permission will not be granted if there is an adverse effect upon such sites.

Archaeology:

To the southern border of C15 there is a Romano British site (SMR ST96NE311) containing a kiln and smelting site which is linked to Verlucio. . Dr Ken Dark of Reading University and holder of various professorships confirms that:-

“Verlucio is of National importance and there should be no action in this area that could impact on the site and the surrounding landscape”

C15 is very much part of this hinterland. HE5 stipulates that such important archaeological features should be protected.

To the northern boundary sits Loxwell Farm (owned by the Bowood Estate) which was demolished in the 1950’s by the owners to avoid it becoming a listed building/monument at the same time major parts of Bowood House were demolished and stripped. The site contains a well that supplied the Corsham Water Works until the 1890’s and it still holds water. Present are the original conduit chambers “repaired” by the War Department/Army in WWII. These, and other conduits, also supplied water to Stanley Abbey and cross important archaeological landscapes. Water was conveyed to Stanley by stone conduit in 1241, via Old Derry Hill, so these courses would be affected by any quarrying.

The Grade II Granary at Loxwell Farm sits in the landscape which requires the maintenance of the context of the Grade II building, being a type site saddle stone granary.

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Granary – Loxwell Farm

To the northern boundary, the site of Lockswell Abbey was founded in 1151 before it moved to Stanley in 1154. Whilst there are no above ground remains, the site is registered with the County Archaeologist (Ms Melanie Pomeroy-Kellinger) and this site and the surrounding hinterland are “untouchable” with regards to any destructive activity. As they form part of the regions significant history, the County Archaeologist is likely to ban any development/ground disturbance around this site, including the northern area of C15.

The well and spring (hence Locks Well becomes Loxwell) are key water causes and should not be disturbed. Discussions will be required with the Environment Agency.

Listed & domestic buildings:

Whilst there are no listed buildings within the site, the landscape form part of the heritage for Lockswell Abbey and Verlucio, and as such should not be disturbed within the general remit of PPS5. The listed buildings in proximity to the site do though include The Granary at Loxwell Farm. As mentioned above

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Listed Buildings locations related to C15

Pitters Farm, having been renovated by Dawber in the 1920’s, is of historic importance. The excavation of C15 would have the potential to damage the setting of these buildings.

Landscape, Townscape & Visual

The exploitation of C15 would have an inevitable massive visual impact on the wider area as well as the local area. The site is visible from both the A4 and the A342 and due to its elevated nature would be impossible to screen. Long distance views from areas such as Chippenham (7KM away) would also be impacted.

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Vehicle travelling South on the A342 showing the close proximity of the road to the proposed site Photograph taken from C15

View from the North of site C15 facing North West towards Chippenham OS grid reference (954 697) – Lower level of the proposed site

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View 1 – Expanded

View 2 – Expanded

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View 3 – Expanded

Far reaching views from C15 – Including Chippenham The two trees circled for reference and can be compared to view 2 for orientation.

This photograph was taken from the heart of site C15, which is further evidence that the elevated position of the site is clearly visible from a wide spectrum of North Wiltshire and is exposed to the frequent Westerly weather patterns.

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The Campaign to Protect Rural England (C.P.R.E) have highlighted their concerns (October 2010):

Policy NE15 (Adopted North Wiltshire Local Plan 2011 –The Landscape Character of the Countryside)

Site C15 falls within the North Wiltshire (saved) policy of NE15. This stipulates that the landscape of North Wiltshire and its locally distinctive characteristics shall be conserved and enhanced, development will be permitted if it does not adversely affect the character of an area and features that contribute to local distinctiveness.

“Development shall take into account:

Special Landscape Area (SLA)

Site C15 falls within the “The higher land of the Spye and Bowood Parklands” as designated in the Wiltshire and Swindon Structure Plan 2016. Appendix 4 of the Structure Plan stipulates that “any proposals for development should have regard to the need to protect landscape character and scenic quality.” This designation is as a result of the North Wiltshire Landscape Character assessment (June 2004). This assessment highlights that the views from the A342 are important to the perception of the area. It also states that the “overall objective for the area is to preserve and enhance the parkland and woodland character and retain the essentially rural character of the area”

Minerals Policy Statement 1 (MPS1) requires that mineral extraction on such a site would require ‘careful consideration’. It is impossible to see how any careful

28th October 2010 Derry Hill and Studley Preservation Group Page 36 of 58 planning and design could protect the surrounding rural area when a site is in a highly visible special landscape area and consists of best and most versatile agricultural land, that should be protected..

Policy HE3 (Adopted North Wiltshire Local Plan 2011 -7. Historic Environment Topic Area)

Site C15 is adjacent to Bowood Historic House and Gardens and as such is subject to HE3. This policy stipulates that “New development and advertisements within or adjacent to Historic Parks and Gardens which do not respect their character, appearance or setting, will not be permitted”. The Wiltshire and Swindon Structure Plan clarifies this further stating that the settings of historic parks” should be protected from inappropriate development, having regard for the scale and location of any development proposals and their impact on the character and features of historic importance of these sites”.

Economy

This initiative will not make Derry Hill and Studley more sustainable, quite the opposite.

The A342 is a tourist route and tourism is a major income for the area. The operation of a quarry would be completely out of place and would detract from the visual beauty. Add to this the congestion from the heavy good vehicles (HGVs) and the negative impact on road safety and the perception of the area will drop and the tourist income will decline. This will affect many individuals and businesses, two of note are:

Lansdowne Arms (Wadworth public house)

The A342 passes in extremely close proximity to this established and popular public house. The front seating area enjoys far reaching views of Chippenham and the surrounding area, which is frequently used throughout the day for the relaxing nature of its location. The intrusion of a significantly increased volume of HGVs would detract from the uniqueness of this location and thus impact viability of the Lansdowne Arms.

Bowood Estate – House and Gardens including Health and Leisure complex, Golf Club, Rhododendron Gardens

Bowood House and Gardens is a premier tourist location in Wiltshire. The gardens are recognised as one of the finest parks in England and it is described as an “oasis”. C15 is located adjacent to this park. The A342 is a main tourist route and

28th October 2010 Derry Hill and Studley Preservation Group Page 37 of 58 will have clear views of the site. Access to the Rhododendron Gardens is opposite C15 and the Grade 1 Mausoleum is located within 1km. In 2009 Bowood Estates opened a Country Hotel designed to protect the future of the estate by providing an ongoing income in conjunction with the Champion Golf Course. These facilities are down wind of C15 and will be blighted by dust and noise. This would have a serious impact on the viability of these facilities and therefore the viability of the whole estate.

Traffic & Transportation

MPS1 requires the promotion of sustainable transportation for extracted minerals. Calne Area 5 – Land North of Pitter’s Farm is located in a rural area away from rail, sea or inland waterway connections. As such the extracted mineral and returning landfill would be required to be transported solely by road. The A342 is a local HGV route and does not constitute a Primary HGV route. The nearest primary HGV route is the A350 which is over 7KM away.

The A342 at Old Derry Hill is 5.49m wide, with high banking stone walls either side, resulting in two HGVs unable to pass at two points as the full width of the narrow road can not be fully utilised – notably within the region of steepest gradient. This currently causes issues as one lane of traffic has to remain stationary for the other to move. This situation can only be substantially worsened by the introduction of quarry traffic and could dramatically hinder the emergency services during the industrial lifespan of a quarry and resultant landfill. It is believed that it would be difficult to widen the road due to the proximity of residents and the listed status of the walls.

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Gradient

The A342 at Old Derry Hill has a gradient of 18%. It is notable that this is a route that is closed during periods of cold weather. This is caused by the gradient and the water that freely flows across the road from the surrounding fields.

The Campaign to Protect Rural England (C.P.R.E) (October 2010) highlights that:

“The site is located on the A342 which is a extremely busy winding road with steep hills, sharp corners and blind bends make them wholly unsuitable and contrary to Section 6, 6.10, of the Development Control Policy document”

The A342 has a fatal accident history, two people being killed in 2005 at an adverse camber bend along the length of the road that adjoins C15. There are a further five collisions reported in the data provided for the last three years either on the A342 or at the junction of the A342 with the A4. In particular it would be necessary for fully loaded HGV’s to cross the busy and fast moving A4 from the A342 junction to head up hill towards Swindon.

Church Road, Derry Hill, is currently used as an access route to avoid the aforementioned junction. This has undergone traffic calming measures within the last 3 years with the addition of chicanes, road humps, a sleeping policeman and a reduction of speed from 30mph to 20mph. Derry Hill School is positioned on Church Road, during peak operational times the main thoroughfare is congested with vehicles and primary school parents and children. The main recreational playgrounds are to the South of the school adjacent to Church Road. This access route is wholly unsuitable for volume HGV traffic in terms of infrastructure, residential and pupil safety. We however suspect that this could become an unofficial route to avoid the complications of Old Derry Hill.

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Water Environment

The Cocklemore Brook is a short tributary of the Bristol Avon, some 2.5 miles (4.0 km) long. Its source is recorded as Pitters Farm from where it flows in a north and then westerly direction, passing underneath the former Wilts and Berks canal before joining the Bristol Avon near Lackham House, Lackham College. As a tributary of the Bristol Avon it contributes to the known unpolluted biological and chemical status of this important River.

Little is currently known of the water quality and aquatic biodiversity of the Cocklemore Brook. However, it is known that the biodiversity of aquatic organism’s declines with declining water quality, and that water quality is dependant on both ingress of pollutants and the variation in water flow between the years and with the seasons.

Sand extraction and subsequent landfill at Pitters Farm will have significant potential for adverse impacts to water quality and water levels. Due to the relatively short length of the brook from the current pristine greensand source, any impact on water quantity and quality from the Pitters Farm site would therefore have a direct impact on both the Brook and the River Avon, damaging the aquatic environment. This is contrary to current planning policy MDC3 for the identification of potential minerals sites.

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Appendix 1

Listed Buildings in the areas of C12, C13, C14, & C15.

10 11 12 13 Church of St Nicholas Pewsham House Grade II Grade II Grade II A342, Calne Without, Wiltshire Back Lane, Calne Without, Wiltshire Old Derry Hill, Calne Without, Wiltshire 11, A342, Calne Without, Wiltshire Copse Cottage 13 Pillars Lodge Grade II Grade II Grade II A342, Calne Without, Wiltshire A342, Calne Without, Wiltshire A3102, Calne Without, Wiltshire 12, A342, Calne Without, Wiltshire Cowage Cottages Pinhills Farmhouse Grade II Grade II Grade II A342, Calne Without, Wiltshire Calne Without, Wiltshire Calne Without, Wiltshire 14, A342, Calne Without, Wiltshire Cuffs Corner Pond Tail Lodge and Gates Grade II Grade II Grade II A342, Calne Without, Wiltshire Calne Without, Wiltshire Calne Without, Wiltshire 19 20 21 Derry Hill Farmhouse Queenwood Grade II Grade II Grade II A342, Calne Without, Wiltshire A342, Calne Without, Wiltshire Calne Without, Wiltshire 22, A342, Calne Without, Wiltshire East Farmhouse Ratford Bridge Grade II Grade II Grade II A342, Calne Without, Wiltshire Calne, Wiltshire Calne Without, Wiltshire 22 23 Farm Bridge North North East of Pond TailRumsey Lodge Farmhouse Grade II Grade II Grade II A342, Derry Hill, Calne Without, Wiltshire Calne Without, Wiltshire Black Dog Hill, Calne Without, Wiltshire 23, A342, Calne Without, Wiltshire Frog Hollow 69 Rumsey House Grade II Grade II Grade II A342, Calne Without, Wiltshire Old Road, Calne Without, Wiltshire Black Dog Hill, Calne Without, Wiltshire 25, A342, Derry Hill, Calne Without, WiltshireGranary at Loxwell Farm Sands Farmhouse Grade II Grade II Grade II A342, Derry Hill, Calne Without, Wiltshire Calne Without, Wiltshire Low Lane, Calne Without, Wiltshire 25 26 Greenstead 108 Stable Block to Rear of Lansdowne Arms Grade II Grade II Grade II 1 Moggs Lane, Calne Without, Wiltshire 108 Norley Lane, Derry Hill, Calne Without,A342, Wiltshi Derryre Hill, Calne Without, Wiltshire 38, Church Road, Calne Without, WiltshireHill View Stockstreet Farmhouse Grade II Grade II Grade II Church Road, Calne Without, Wiltshire A4, Calne Without, Wiltshire Calne Without, Wiltshire 39 40 Hilltop 21 Strict Baptist Chapel Grade II Grade II Grade II Church Road, Calne Without, Wiltshire A342, Derry Hill, Calne Without, Wiltshire Church Road, Calne Without, Wiltshire 4 5 Horsepride Well Studley Brook Farmhouse Grade II Grade II Grade II Old Derry Hill, Calne Without, Wiltshire A342, Calne Without, Wiltshire Black Dog Hill, Calne Without, Wiltshire 42, Church Road, Calne Without, WiltshireJasmine Cottage 9 10 Studley House Farm Grade II Grade II Grade II Church Road, Calne Without, Wiltshire A342, Calne Without, Wiltshire Calne Without, Wiltshire 43 44 Kennels Lodge Studley Lodge Grade II Grade II Grade II Church Road, Calne Without, Wiltshire Calne Without, Wiltshire 62 Old Road, Calne Without, Wiltshire 7, A342, Calne Without, Wiltshire Laggus Farmhouse and Cottage Terraces Balustrades and Steps to South and East of Bowood Grade II Grade II House A342, Calne Without, Wiltshire Calne Without, Wiltshire Grade II Calne Without, Wiltshire 75, Black Dog Hill, Calne Without, WiltshireLakeside Cottage The Boathouse Grade II Grade II Grade II Black Dog Hill, Calne Without, Wiltshire Calne Without, Wiltshire Calne Without, Wiltshire 76 77 Laundry Cottage and Gates The Coach House Grade II Grade II Grade II Black Dog Hill, Calne Without, Wiltshire Calne Without, Wiltshire Black Dog Hill, Calne Without, Wiltshire 87, Studley Lane, Derry Hill, Calne Without,Little Wiltsh Trodgersire 16 The Doric Temple Grade II Grade II Grade II

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Studley Lane, Derry Hill, Calne Without, WiltshireA342, Calne Without, Wiltshire Calne Without, Wiltshire Apple Tree Cottage 3 Loaf Cottage 2 The Estate Yard at Bowood House with Attached Grade II Grade II Gates A342, Calne Without, Wiltshire A342, Calne Without, Wiltshire Grade II Calne Without, Wiltshire 10 11 12 13 Lodge Piers and Railings to Rumsey HouseThe George Inn Grade II Grade II Grade II A342, Calne Without, Wiltshire Black Dog Hill, Calne Without, Wiltshire A342, Calne Without, Wiltshire Barn at Whetham Farm Milestone About 200 Metres South of JunctionThe Golden with LGatesane Grade II to Reybridge Grade II* A3102, Calne Without, Wiltshire Grade II A342, Derry Hill, Calne Without, Wiltshire A342, Calne Without, Wiltshire Barn to East of Studley Brook FarmhouseMilestone About 400 Metres West of JunctionThe Hermits with St Caveudley at North End of Lake Grade II Lane Grade II A4, Calne Without, Wiltshire Grade II Calne Without, Wiltshire A4, Calne Without, Wiltshire Barn to South East of Home Farmhouse Milestone on South Side Opposite NumberThe 327 Lansdowne Arms Inn Grade II Quemerford Grade II Calne Without, Wiltshire Grade II A342, Derry Hill, Calne Without, Wiltshire 359 Quemerford, Calne, Wiltshire Barn to South East of Lower BeversbrookMilestone Farmhouse on West Side About 150 MetresThe North Lodge East of Grade II Lane to Broads Lane Grade II A3102, Calne Without, Wiltshire Grade II A342, Calne Without, Wiltshire A3102, Calne Without, Wiltshire Bowood House Milestone on West Side Ou tside MilestoneThe Cottage Mausoleum Grade I Grade II Grade I Calne Without, Wiltshire A3102, Calne Without, Wiltshire Calne Without, Wiltshire Bridge on Estate Drive East of Pond TailMilestone Lodge Opposite Number 31 The Old Chapel Grade II Grade II Grade II Calne Without, Wiltshire A342, Derry Hill, Calne Without, Wiltshire A342, Calne Without, Wiltshire Calstone Mill Milestone Opposite Upper Cottage The Soho Inn Grade II Grade II Grade II Calne, Wiltshire A4, Calne Without, Wiltshire A4, Derry Hill, Calne Without, Wiltshire Cascade and Grottoes at North End of LakeNaish Hill Farmhouse The Village Hall Grade II Grade II Grade II Calne Without, Wiltshire Chippenham, Wiltshire Church Road, Calne Without, Wiltshire Cascade at South West End of Lake Northend Cottage 6 Toghill House Grade II Grade II Grade II Calne Without, Wiltshire A342, Calne Without, Wiltshire Calne, Wiltshire Christ Church Nuthills Farmhouse Top Farmhouse Grade II Grade II Grade II Church Road, Calne Without, Wiltshire A342, Calne Without, Wiltshire Studley Hill, Derry Hill, Calne Without, Wiltshire

Upper Cottage Walled Garden to North of Bowood HouseWell House to South East of Number 15 Grade II Grade II Grade II A4, Calne Without, Wiltshire Calne Without, Wiltshire A342, Calne Without, Wiltshire Upper Provender Mill Well House Whetham Farmhouse Grade II Grade II Grade II Lake View, Calne, Wiltshire A342, Calne Without, Wiltshire A3102, Calne Without, Wiltshire Whetham House Grade II Calne Without, Wiltshire

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Appendix 2 Details of archaeological artefacts in the CALNE CALUNA area

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Appendix 3

Location of Historical Finds

Map showing Prehistoric Neolithic & Mesolithic finds: green Beaker/ Bronze Age: pale blue Iron Age: purple Norman & Med: pale purple Post Med: red/pink Modern: orange/red

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Map showing Roman SRC (Seeking Roman Calne Project) finds: green Previously identified Roman sites not on SMR: red SMR Roman sites: yellow

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Appendix 4

Mr D Clark’s Nature Survey, October 2010.

Bats In Britain, bats benefit from a very comprehensive level of legal protection. Under the Wildlife and Countryside Act (1981 and subsequent amendments) it is illegal to intentionally kill, injure, take or sell a bat, posses a live bat or part of a bat, to intentionally, or in England and Wales, recklessly damage obstruct or destroy access to bat roosts. Under the Conservation Regulations it is an offence to damage or destroy breeding sites or resting places. Fines of up to £5,000 per bat affected and six months imprisonment are in place for these offences. Also all bats appear in “The Conservation of Habitats and Species Regulations 2010” this became law on the 1 st April 2010 in England and Wales.

The granary Grade II listed and bats roost, Loxwell farm C15

• Horseshoe ( Rhinolophus ferrumequinum) UK BAP priority species , cited as roosting in the Coach House, Studley, with the feeding grounds over the maize fields in C12 and C13 and surrounding woodlands, also cited in council documents for C 12-14 see scans appended. • Pipistrelle (Pipistrellus pipistrellus ). UK BAP priority species Photographed in a roost at Pitters Farm adjacent to C15, feeding grounds being the open land, woodland and ponds in and around C15 and cited in council documents for C 12- 14.

Pipistrelle bat Pitters Farm C15

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• Brown long eared ( Plecotus auritus ) UK BAP priority species , videoed in roost at Pitters Farm adjacent to C15, feeding grounds being the open land, woodland and ponds in and around C15 also cited in council documents for C 12-14.

Brown long eared bats roosting at Pitters Farm C15

Evidence on the floor, bat faeces wings and wing cases on the boiler room floor Pitters Farm C15

A discussion with the local representative from the Bats protection league has pointed out not only the roosts but the breeding and hibernating including the feeding grounds will also need protection. Badger (Meles meles ) Protected Badgers Act 1973, can’t kill injure take or disturb badger sets, several large sets are easy to see on the edge of Bowood and at least 2 in the Rhododendrons, in the woodland area of Pitters Farm and possible sites in the wooded area of C15, and cited in the other sites. Two sets identified by archaeological study in C13.

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Badger set Pitters Farm

Rooting in the wooded line through C15, Badger/wild boar, sightings of both, pits about 15” across

Deer Sightings of Roe deer across the Bowood area including C12-14. • Roe Deer ( Capreolus capreolus) reintroduced from Scotland after hunting extinction by the 1800’s. Water Vole ( Arvicola terrestris) a UK BAP priority species, from April 2008 they have been fully protected in England, this includes the vole its resting place it is an offence to kill capture destroy, and or obstruct them and or their breeding places as along C12 and likely in Pitters Farm next to C15. Brown Hare (Lepus europaeus) UK BAP Priority species, has been seen in the field around Pitters Farm since the field has been returned to grass meadow by the present owner in an attempt to recreate the original setting. C15. Mice are highly likely to be in this area and there are reports of sheds and out buildings having evidence of mouse habitation they could be one of several species C12-C15. Dormouse ( Muscardinus avellanarius) UK BAP species evidence of mice at Pitters Farm. Harvest Mouse ( Micromys minutes) UK BAP species evidence of mice at Pitters Farm. Reptiles, All native reptiles are protected in Britain under the Wildlife and Countryside Act of 1981. The law makes it an offence to intentionally kill, injure, sell or advertise to sell any of the six native species.

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• Slow worm , (Anguis fragilis ) U.K BAP priority species found in old road area C13 and C14. • Grass snakes , (Natrix natrix ) U.K BAP priority species Nest cited in old road C13 and C14.

Amphibians Newts, I have several mentions of newts in this area and have shown them various pictures including those of the Crested Newt ( Triturus cristatus), U.K BAP priority species .E specially noted is the amount of sightings of these in the ornamental ponds at Pitters Farm, whilst this isn’t there usual habitat there is a large relatively stagnant pond in the boggy woodlands that is suitable, this habitat will be lost if the aquifer at C15 is disturbed and the water course affected as there are at least 5 feeds into the stream and ponds from within the ground undoubtedly from the aquifer. There has also been sightings in ponds in Old Road between C13 and C14. Frogs and toads Frogs and toads are quite common place in this area especially near water, I have photographed a frog at Pitters Farm C15 that may be a rare Pool Frog but this would need further investigation.

Possibly a rare Pool Frog from Pitters farm C15 and right a common frog, Derry Hill.

• Common toad (Bufo bufo) is also a UK BAP priority species, and probably resident in the damper areas. Cited in gardens adjacent to C13 and C14.

Insects there are too many to list that would be affected by the works here are just a few that I have seen in Derry Hill and surrounding areas. • Large red damsel fly ( Pyrrhonsa nymphula ) and other members of the Dragon fly order.

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Red Damsel fly pyrrhosoma nymphula

• The Hornet mimic hoverfly( Volucella zonaria) once rare and is now growing in numbers but is still fragile.

Hornet mimic hoverfly Volucella zonaria Photo from the web as mine unusable, seen twice in this area this summer.

• The lesser stag beetle(Dorcus parallelopipedus )Old Road. This species relies on old rotting wood to survive. • Hawthorn shield bug (Acanthosoma haemorrhoidale) lives in deciduous areas and a popular food for bats. • Dock Bug ( Coreus marginatus ) Aptly named as feed on dock leaves.

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Dock bug Coreus marginatu

• White tailed bumble bee (Bomus lucorum) Bees are in decline across the country.

White tailed bumble bee Bomus lucorum

The areas around here may also support some of the following ; • Pearl-bordered fritillary ( Boloria euphrosyne ) U.K BAP priority species possible and classed as quite rare . • Small pearl-bordered fritillary (Boloria selene) U.K BAP priority species appears on the species action plan for Wiltshire butterflies 1998 as only two sites listed in wilts/hants if found could be very special. • Bee-hawk moth UK BAP priority species. • Hover Fly ( Eupodes nitens ) nationally scarce on the U.K BAP priority species list.

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Wiltshire County Recorders Report 2009-2010 Collection details cited from a survey conducted around the local areas including Spye Park a SSSI site covering Lichen, moss, Fungi, flies and small moths, This is evidence that the surrounding area does support a wealth of wild life we don’t even notice, Fungi and related species are extremely vulnerable and their presence of theses species where cited as such should warrant a thorough survey of the areas along the southern edge of C15 especially where this borders Pitters farm’s marshy areas’

“BRYOPHYTES ANNUAL REPORT 2009 Didymodon nicholsonii is a rather nondescript olive-green moss There are many species of bryophyte in North Wiltshire which have not been recorded for half a century or more but was not actually recorded from VC7 until it was found at Bowden Hill...... Dicranum majus , Plagiothecium undulatum and Rhytidiadelphus loreus all in one small area of the wood.. In addition Leucobryum juniperoideum was found in the same locality, new to VC7.(north wilts vice county).... Orthotrichum tenellum was growing on the bark of a willow.... also supported the diminutive epiphyte Syntrichia papillosa which is also very scarce in the VC... Nowellia curvifolia is a tiny, dark red leafy liverwort that favours rotting wood in very humid places. It is relatively common in oceanic areas of Britain but very rare this far east...... Deep among the willows we made another good find: the nationally scarce moss Platygyrium repens grows on trees there. It had previously only been known from a woodland near Wootton Bassett but has since been found on scrub during a Wessex Bryology Group visit to West Yatton Down. It is likely to be present elsewhere in the VC but is not the most obvious moss!

DIPTERA ANNUAL REPORT 2009 Ctenophora pectinicornis (fam. Tipulidae) (1f) nationally scarce, associated with dead wood, esp. Beech The following are relatively uncommon but have been previously recorded from Wiltshire and may have interest perhaps only to me! Sepedon spinipes (fam. Sciomyzidae) Chelifera precatoria (fam. Empididae) Dolichocephala irrorata (fam. Empididae) Cordilura albipes (fam. Scatophagidae)

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FUNGI (VC7) ANNUAL REPORT 2009 One relatively uncommon find for the year was the Scarlet Caterpillarclub: Cordyceps militaris that grows on the over-wintering pupae of larger moths, usually buried in mossy soil. There are only seven recorded finds for it in North Wiltshire from 1992 – 2008 and on only four sites. It was recorded twice in 2009, at Cadley Church churchyard and a new location for us on Chittoe Heath at Spye Park.... One of the two Red Data species( UK BAP priority species, Duane ) of fungi present at Stanton Country Park is The Flea’s Ear: Chlorencoelia versiformis (Chlorociboria versiformis as was). Closely related to the Green Elfcup Chlorociboria aeruginascens.. only six records of it in North Wiltshire, five at Stanton Country Park And one at Clouts Wood, a W.W.T reserve near Wroughton.

Mushrooms Loxswell farm and Pitters farm

MICROLEPIDOPTERA ANNUAL REPORT 2009 Cameraria ohridella on Horse Chestnut. This recent addition to the County List continues to spread and in many instances considerably disfigures tenanted trees.

SAWFLIES ANNUAL REPORT 2009 The notes below show four species recorded in Wiltshire for the first time and another species which had only been recorded once previously, in 1963 Ametastegia albipes (Thomson) – This tiny black species was found at Rowley Ponds, Bentley Wood on 12th May 2009, the only previous Wiltshire record having been at Blackmoor Copse in 1963,.... This species seems quite scarce in B Fenusella nana (Klug) – A female of this species emerged on 3rd May 2009 from a mine in a leaf of Betula collected at Spye Park on 27th July 2008. The first record for Wiltshire,.ritain. In addition to the 1963 record above there were 4 single records in the 1980s

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Nematus sylvestris Cameron – 3 larvae found on Salix cinerea/caprea hybrids at Ashton Keynes on 9th July 2009 have been identified from photographs as this species, later confirmed by rearing. The first Wiltshire record Pristiphora brevis (Hartig) – This is the only sawfly species, currently known in Britain, to use Thalictrum flavum as a larval host plant..(Upper Waterhay SSSI)... The first Wiltshire records of this very rare species which has only been found at a few other British sites”

Wiltshire County Recorders Report 2009-2010

Intrusion on Pitters Farm

Boundary tree line Pitters Farm to C15.

Aquifer fed natural streams flowing from wooded area Pitters Farm C15.

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Large pond possibly where Crested newts and Pool frogs breed and disperse from looking for new breeding areas to end up in the ornamental ponds Pitters Farm C15.

Biblography and reference material sources • www.arkive.org • REINHARD KIRSCH & KLAUS HINSBY • The Conservation of Habitats and Species Regulations 2010 • www.herpetofauna.co.uk Reptiles • www.glosnats.org.uk Wide base of all naturalists records • www.uksafari.co.uk wide base of all naturalists records • consult.wiltshire.gov.uk/portal/spatial_planning/mineralssiteoptions -for the details of the proposed sites • The guide to mammals of Britain and Europe • Collins gem: Insects Wiltshire County Recorders Report 2009-2010

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